KOLLMORGEN. Title: Standard Operating Procedure Counterfeit Parts

Transcription

1 Approved By: Elliott Major Date: Page 1 of 9 Rev ECO Date Approve Rev ECO Date Approve A R01_ DWL B R01_ DWL C R01_ DWL D R01_ DWL 1.0 Purpose This document describes the process and due diligence performed by Kollmorgen to prevent the purchase and / or use of Counterfeit Parts and meet the requirements of the AS5553 Standard for Counterfeit Electronic Parts, Avoidance, Detection, Mitigation, and Disposition. Even though the AS5553 Standard was written for counterfeit electronic parts, Kollmorgen includes the process applicable to motors in Sections 9.0 to Scope This document applies to the procurement activities at Kollmorgen to the extent specified herein. 3.0 Documentation Links and References AS5553, Counterfeit Electronic Parts, Avoidance, Detection, Mitigation, and Disposition ISO9001, Quality Management System Requirements 4.0 Definitions 4.1 Suspect Part A part in which there is an indication by visual inspection, testing, or other information indicating the item may have been misrepresented by the Supplier or Manufacturer and may in turn meet the definition of a Counterfeit Part. 4.2 Counterfeit Part A suspect part identified as a copy or substitute without the legal right or authority to do so or a part whose material, performance, or characteristics are knowingly misrepresented by a Supplier in the Supply Chain. The Counterfeit Parts include but are not limited to: Parts not containing the proper internal construction that is consistent with the desired, producer, or ordered part Used, refurbished, or reclaimed parts represented as new product Parts with a different package style, type, or surface plating / finish than the product ordered Parts not successfully completing the full production and / or test flow of the Original Component Manufacturer (OCM) that are represented as completed product.

2 Approved By: Elliott Major Date: Page 2 of Parts sold or delivered as upscreened product that have not successfully completed the upscreening process Parts sold or delivered with modified labeling or markings intended to misrepresent the form, fit, function, or grade of the intended product. Note: Parts sold as refinished, upscreened, or uprated and have been identified as such are not considered counterfeit product. 4.3 Aftermarket Manufacturer A manufacturer meeting one or more of these criteria: A manufacturer authorized by an OCM to produce and sell replacement parts. The supplied parts originate from an OCM or are produced using OCM tooling or intellectual property The manufacturer produces parts using tooling or equipment manufactured by and traceable to an OCM that was properly stored until use. The parts are subsequently assembled, tested, and qualified using processes meeting the technical specifications without violating the intellectual property rights, patents, or copyrights of the OCM The manufacturer produces parts by emulation, reverse engineering, or redesign using processes matching the OCM specification. The parts must meet the Customer needs without violating the OCM intellectual property rights, patents, or copyrights. Note 1: The Aftermarket Manufacturer must label or otherwise identify a part to ensure the as shipped product is not mistaken for the product manufactured by the OCM. 4.4 Approved Supplier Suppliers who are formally assessed and determined to have a low risk of providing counterfeit product. These suppliers are incorporated and listed in the Kollmorgen ERP System as an approved supplier. 4.5 Authorized Supplier Aftermarket manufacturers (reference Section 4.3) and OCM authorized sources of supply for a specific part. 4.6 Broker / Independent Distributor Brokers are Independent Distributors searching the industry to locate parts based on Customer need. Independent Distributors procure new parts with the intent of selling or redistributing the parts into the market. These parts are purchased from an OEM, excess inventory, contract manufacturer, or another Independent Distributor. A Broker or Independent Distributor have no contractual agreement with the OCM.

3 Approved By: Elliott Major Date: Page 3 of Certificate of Conformance (C of C) A separate document the supplier provides to formally declare the purchase order requirements are met. This separate document may include information relative to the manufacturer, distributor, quantity, and the date code. This separate document must be signed and dated by an associate authorized to represent the Supplier. 4.8 Certificate of Conformance and Traceability (C of CT) A certificate of conformance applicable to some military specifications requiring documented traceability of the product from the Qualified Parts List / Qualified Materials manufacturer through the product delivery to the Government. 4.9 Government Industry Data Exchange Program (GIDEP) A cooperative activity between the Government and industry participants seeking to reduce or eliminate resource expenses by sharing technical information essential for research, design, development, production, and operational phases of the life cycle of the system, facility, or equipment ERAI A privately held global trade associates who monitors, investigates, reports, and mediates issues affecting the global supply chain of electronics including the supply of counterfeit and substandard parts Packaging Component packaging refers to the manner the electronic parts are packaged in preparation for use. There are four basic types of packaging: (A) Bulk, (B) Tray, (C) Tube, and (D) Reel Refinished Using a plating process method after manufacture to alter the original plating composition on a part lead or a lead wire Refurbished Subjecting parts to a process to brighten, polish, or renovate the item in an effort to restore the item to a like new condition. Refurbished parts may have the leads realigned and tinned Uprated Assessment resulting in an extension of a parts rating to meet performance requirements for an application where the part is used outside the specification range of the manufacturer Upscreened Additional part testing performed to produce parts verified beyond the specification parameters of the manufacturer.

4 Approved By: Elliott Major Date: Page 4 of Used Electrically charged parts removed from a prior application. Parts should be examined for nonstandard packaging, mixed lots / dates, parts from various sites, scratches, bends, test dots, faded marking, chemical residue, or other signs of use. Used parts may be sold with a limited warranty. Programmable product may still contain partial or complete programming capability that may affect part functionality. Used parts marketed as such should be declared accordingly. Note 1: Other definitions are available for review in Section 3.3 of the AS5553 Standard. 5.0 Responsibility Purchasing, engineering, materials, quality, and other designated associates are responsible to comply with the requirements and processes identified in this document. 5.1 Purchasing is responsible to procure the correct electronic part using the applicable drawing, specification, description, or other information to meet the intended use. Purchasing is responsible to reference and / or attach the following statement to each purchase order. Seller shall not deliver any Product to Buyer containing any Counterfeit Parts as defined in Buyer s Standard Operating Procedure Counterfeit Parts (SOP-76) as such procedure may be amended from time to time. 5.2 Engineering is responsible to ensure the drawing, specification, process, or other description identifies the applicable type, class, style, part number, manufacturer, or other related information so the correct part or product is identified. 5.3 Materials associates may be responsible to examine, inspect, select, kit, and / or maintain the parts to identify or mitigate the receipt and / or use of counterfeit parts. 5.4 Quality is responsible to control parts identified as counterfeit and report the counterfeit parts to other potential users and Government investigative authorities. The Supplier Portal contains the Counterfeit Parts Procedure (SOP-76) and the Supplier Terms and Conditions at: Select the Service and Support Tab Kollmorgen Partners from the drop down and Supplier Forms or Supplier Terms and Conditions (T & C 38 is for Counterfeit Parts). Seller shall indemnify and hold harmless Buyer and its officers, directors and affiliated companies from any and all losses, damages, claims, costs and expenses for Seller s failure to comply with SOP-76.

5 Approved By: Elliott Major Date: Page 5 of Procedure / Process Description 6.1 Purchasing, planning, and design associates assess the availability of original or authentic product in support of manufacturing operations. 6.2 Purchasing must examine every potential source of supply to assess the risk of receiving counterfeit parts. Assessment may be a survey, audit, product alert review, and a review of the supplier quality data to determine performance. Note 1: Purchasing should obtain parts directly from an OCM, approved distributor, authorized resell organization, or franchised aftermarket supplier. These companies are reviewed and approved by the original component manufacturer. These companies should be referenced in the Kollmorgen ERP System as an approved supplier. The approved supplier list will control whom Kollmorgen purchases from on electronic components. A specific process involving Quality must be followed when making additions to the approved supplier list, reference Form SOP76.1. Note 2: Purchasing should obtain parts from an independent distributor or part broker ONLY as a last resort. Purchasing must contact Quality for guidance to determine if Kollmorgen must obtain documented permission from the Customer on the use of an independent distributor or part broker before processing the purchase order. Kollmorgen must retain this approval per the Control of Records document, RAD-003. Purchasing must document a reason whenever a part is procured from a source other than the OCM or authorized supplier. Reasons for deviation and all customer approvals must be documented as an attachment on the respective purchase order. When purchasing from an Independent Distributor, purchasing will specify supply chain traceability is required to the OCM, approved distributor, authorized resell organization, franchised aftermarket supplier, or aftermarket manufacturer. The traceability should identify the name and location of all supply chain intermediaries from the OCM to the direct source of the product to the Seller. Purchasing must update receiver notes to ensure the shipment is delivered directly to the buyer for to verify the traceability documents. If traceability is unavailable or the documents are suspect as being falsified, a risk assessment as defined in AS5553 Appendix E and B must be completed as appropriate, reference Form SOP Purchasing must maintain a list of approved suppliers to minimize the risk associated with the supply and / or receipt of counterfeit parts. Suppliers referenced in the Kollmorgen ERP System are considered approved. Note 1: As an aid, purchasing may reference Appendix B of the AS5553 Standard for additional purchasing process guidelines related to electronic parts. Appendix B includes guidelines related to the purchasing process, the supplier selection / approval process, Supplier auditing activities, and multiple risk mitigation flow diagrams

6 Approved By: Elliott Major Date: Page 6 of 9 Note 2: Purchasing may reference Appendix C of the AS5553 Standard for guidelines and information related to Supply Chain Traceability. At a minimum, the OCM, distributor, or aftermarket manufacturer should be required to provide certificates of conformance and acquisition traceability. These certification requirements must be clearly identified on the purchase document as deliverable data. 6.4 The electronic component requirements for the product may be identified from a review of the Customer purchase order, specification, or flowdown requirements. Purchasing must request this certification and traceability data as a deliverable item. 6.5 Purchasing must specify the flowdown requirements from the Counterfeit Parts Procedure applicable to the supplier or subcontractor. Purchasing must perform some level of risk assessment if the supplier or subcontractor does not maintain a documented counterfeit part control plan compliant to the AS5553 Standard. 6.6 The purchase order must specify the applicable requirements of the Counterfeit Part Procedure to the supplier to minimize the risk of receiving counterfeit parts. The language should include requirements to ensure conforming, original, and authentic parts are provided. The purchasing document may list certification or traceability requirements, test and / or inspection results, Quality System requirements for the supplier, a statement of financial responsibility, the length of obligation, and any penalties associated with fraud. Note 1: Additional guidelines related to Procurement Contract Requirements are available to review in Appendix D of the AS5553 Standard. 6.7 Per the specified inspection or test instructions, associates receiving or processing the parts must examine the product to ensure the drawing, specification, type, class, style, marking, part number, manufacturer, date code, or other related information is present and correct to detect or identify suspect or counterfeit parts. When the evidence indicates the material may be suspect or counterfeit parts the lot of product is placed on a nonconforming material document. The purpose is to identify, separate, and segregate the nonconforming parts to the proper location, reference the Control of Nonconforming Material, RAD-016. Note 1: If the procurements are made to a Broker or Independent Distributors or when there is a reason to doubt a part is authentic, additional test or inspection activity must be performed to detect counterfeit parts. Additional guidelines for Product Assurance may be reviewed in Appendix E of the AS5553 Standard.

7 Approved By: Elliott Major Date: Page 7 of 9 The guidelines relate to test / inspect activity, documents, packing, visual inspection results, and test results to verify parts meet the specified requirements. Appendix E references flow diagrams as an aid to determining part compliance and to reduce the risk of using counterfeit parts in any manufacturing operations or functions. Note 2: Additional guidelines for Material or Surplus Material are available to review in Appendix F of the AS5553 Standard. The guidelines in Appendix F relate to scrap product, surplus product, return product, and suspect or confirmed counterfeit parts. 6.8 When further investigation removes all doubt the parts are suspect or counterfeit, the nonconforming material document may be dispositioned Accept. The reason for accepting the product must be recorded on the document as a reference to the due diligence work and / or activity performed. 6.9 Purchasing, quality, and operations may aid supplier quality in the disposition of suspect or counterfeit parts. Kollmorgen may contact legal counsel and review the reporting process listed in the AS5553 Standard, Appendix G, for guidance A suspect and verified counterfeit part must be reported to Management and must remain at Kollmorgen. Management should contact legal counsel and review the reporting process listed in the AS5553 Standard, Appendix G, for guidance Management is responsible to determine how the counterfeit part occurrence is reported internally, to Customers, to the Government, the Government Cooperative (GIDEP), other industry reporting programs (ERAI), and criminal authorities using the reporting process listed in the AS5553 Standard, Appendix G. 7.0 Verification of Due Diligence Electrical Components / Electronic Product Kollmorgen considers the due diligence applied to the material purchase successful when this procedure is followed and when finished product meets the test or inspection requirements identified for the product or the standard work established for the product. A failed Electrical Component or Product does not mean the instance was caused by a counterfeit part. Kollmorgen must verify the cause of the nonconformance and disposition the defect per the Control of Nonconforming Material document RAD-016. This procedure will apply if the deficiency is suspected or attributed to a counterfeit part. Note 1: The Guidelines for Reporting Counterfeit Parts for electronic or motor parts are listed in Appendix G of the AS5553 Standard. Kollmorgen Management is responsible to determine the action to pursue if a counterfeit part is identified, detected, or verified. Management should consult all corporate legal resources available to avoid, minimize, or mitigate risks related to counterfeit parts. Appendix G of the AS5552 Standard lists the contact information of private, military, Government, regulatory, or criminal investigation services.

8 Approved By: Elliott Major Date: Page 8 of Electronic, Finished Electronic Product, or Electronic Component Parts Kollmorgen may require documentation or process verification to ensure compliance to the Kollmorgen SOP for Counterfeit Parts for Electronic, Finished Electronic Product, or Electronic Component Parts as directed to obtain this information by our Customers. 8.1 Purchasing will specify a Certificate of Conformance from the Supplier is delivered with the product or material. 8.2 Purchasing will issue the order document to the supplier listed on the drawing. 8.3 Purchasing will issue the order document to an approved distributor identified by the original part manufacturer or another resource when applicable. 8.4 Purchasing will issue the order document only to surveyed and / or approved A and B level suppliers identified by Kollmorgen. 9.0 Counterfeit Part Verification Activities for Motor Parts The AS5553 Standard addresses Counterfeit Electronic Parts, Avoidance, Detection, Mitigation, and Disposition. Kollmorgen will perform the activities outlined in Sections 9.0 and 10.0 of this procedure to address counterfeit raw material purchased for motor parts, subassemblies, or completed motors. The Materials Engineer or Supplier Quality performs or directs a laboratory, organization, or service to perform tests on purchased raw material included in motor parts, subassemblies, or complete motors. Results are maintained in accordance with the procedure for the Control of Records, RAD Semi-annual Testing On Site Verification Semi-annually, raw materials are selected to perform on site tests to verify composition, electrical mechanical chemical properties, or compliance with methods established by an organization like ASTM, ANSI, ASTM, SAE, or Military / Industrial Standard Annual Testing Outside Laboratory, Organization, or Service Verification Annually, raw materials are selected to perform off site tests to verify composition, electrical mechanical chemical properties, or compliance with methods established by an organization like ASTM, ANSI, ASTM, SAE, or Military / Industrial Standard Test Results The Materials Engineer or Supplier Quality review the test results to determine if the material tested meets the requirements identified Acceptable Test Results The Materials Engineer or Supplier Quality contacts the Purchasing Leader and the Operations Manager when the material meets the test requirements. Test results are maintained according to the procedure for the Control of Records, RAD-003.

9 Approved By: Elliott Major Date: Page 9 of Failed Test Results The Materials Engineer or Supplier Quality contacts the Purchasing Leader and the Operations Manager when the material does not meet the test requirements. The Materials Engineer, Supplier Quality, the Purchasing Leader, Operations Manager, and other associates deemed necessary determine the action to perform or implement when the material does not meet the test requirements. Test results and the actions taken are maintained according to the procedure for the Control of Records, RAD-003. Note 1: The Guidelines for Reporting Counterfeit Parts for electronic or motor parts are listed in Appendix G of the AS5553 Standard. Kollmorgen Management is responsible to determine the action to pursue if a counterfeit part is identified, detected, and / or verified. Management should consult all corporate legal resources available to avoid, minimize, or mitigate risks related to counterfeit parts. Appendix G of the AS5552 Standard lists the contact information of private, military, Government, regulatory, or criminal investigation services Verification of Due Diligence Motors, Finished Motors, Motor Parts Kollmorgen considers the due diligence applied to the material purchase successful when this procedure is followed and when finished product meets the test or inspection requirements identified for the product or the standard work established for the product. A failed Motor, Finished Motor, or Motor Part does not mean the instance was caused by a counterfeit part. Kollmorgen must to verify the cause of the nonconformance and disposition the defect per the Control of Nonconforming Material document RAD-016. This procedure will apply if the deficiency is suspected or attributed to a counterfeit part Motors, Finished Motors, and / or Motor Parts Kollmorgen may require documentation or process verification results to ensure compliance to the SOP Counterfeit Parts for motor parts, subassemblies, or completed motors when directed to obtain this information by a Customer.