Issue Date: 22/10/12 Page 1 of 1 TABLE OF CONTENTS

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1 P R O C E D U R E S M A N U A L

2 Title: CONTENTS AND ISSUE STATUS Issue Date: 22/10/12 Page 1 of 1 TABLE OF CONTENTS PROCEDURE NO DESCRIPTION ISSUE QP01 Control of documents 1 QP02 Control of records 1 QP03 Competence, Awareness and Training 1 QP04 Sales Order Processing 1 QP04-BPS Sales Order Processing 1 QP04-BTS Sales Order Processing 1 QP04-SB Sales Order Processing 1 QP04-UTS Sales Order Processing 1 QP05A Supplier Selection 1 QP05B Material Purchasing 1 QP05C Back to Back Purchasing 1 QP05D Goods In 1 QP06 Picking & Material Despatch 1 QP07 Calibration 1 QP08 Customer Satisfaction 1 QP09 Internal audit 1 QP10 Control of non-conforming product 1 QP11 Corrective and preventive action 2 Signature: Management Representative

3 QP01 Title: DOCUMENT CONTROL Issue No: 2 Issue Date: 22/10/12 Page 1 of 1 To ensure that all documentation is to the current issue. Management Representative 1. Document Approval 1.1 New document drafts are submitted to the Management Representative for review to ensure compliance with ISO 9001 and approval. The date is entered onto the document and an issue no allocated. The same issue number is allocated to all the pages of a multi-page procedure. The issue number is entered onto a master list. Documents include the Business and procedures manuals and work instructions. 2. Standards 2.1 A Register of Standards is maintained. The issue status of International standards is kept up to date through the BSI PLUS system. 3. Document Distribution 3.1 A hard copy of Manuals is held in the Divisional Offices. An electronic copy is available on the system. 4. Amendments and Control of Obsolete Documents 4.1 Details of amendments to documents are reviewed for compliance with ISO 9001 and approved. The amendments are highlighted in italics and entered in the document amendment table. The document is reviewed and approved as above and the issue number is raised on the master list. 4.2 Superseded documents are archived, marked or destroyed. Illegible documents are destroyed. Issue Date Amendment 2 22/10/12 Control of drafts and review of amendment to ISO 9001 added

4 QP02 Title: CONTROL OF RECORDS Management Representative 1. Record Storage 1.1 A quality records list is maintained showing all the quality records. 1.2 Records are legible and identifiable to the product as appropriate. 1.3 Records are stored in such a way that they are easily retrieved and in facilities that protect them from damage or loss. 1.4 Product records are retained for minimum of 6 years and QA records for 3 years. 1.5 Records which are older than the retention period can be disposed of. Records should only be disposed of with the authority of the Management Representative. 2. Backup 2.1 The system is backed up to tape. A copy of data is also kept off-site. Data is protected by antivirus software which is updated automatically.

5 QP03 Title: COMPETENCE, AWARENESS AND TRAINING To ensure that all personnel involved in activities affecting quality are suitably qualified. HR Manager 1. Competence 1.1 A Competence Matrix is maintained, detailing the competencies required by the company and possessed by personnel. A training record is also raised for each employee, along with evidence of qualification and experience. 2. Training 2.1 Staff competence is reviewed at least annually and training is arranged for any shortfall. 2.2 The training received is detailed onto the training record. The training is evaluated and details entered on the record. If the training was unsatisfactory further training is arranged. 2.3 Skills and training are reviewed when personnel change responsibilities / jobs. 3. Awareness 3.1 Each new employee receives an induction covering the details on the induction record. The induction record is updated and signed by HR and the employee on completion.

6 QP04 Title: SALES To ensure that Customer requirements are clearly understood and reconciled with the quotation. Sales Managers 1. Quotation Procedure 1.1 Review the enquiry and drawings, liaising with the Customer to obtain missing details or to resolve any problems. 1.2 Identify the parts required and calculate the prices and raise the quote in SAP. Send the quote to the customer. 2. Order Review Procedure 2.1 Enter the details of the order into SAP, allocating the next sequential sales order no. 2.2 Compare the details of the order with the quotation documentation and resolve any discrepancies with the Customer. 2.3 Ensure there is the necessary drawing/bill of material/instructions for the job. 2.4 If required by the customer, raise and send an acknowledgement. 2.5 Raise a Picking Note and send to the Warehouse. 3. Order Amendment 3.1 On receipt of a written order amendment, check the quality / delivery implications. Resolve any problems with the Customer and amend the sales order and picking note as appropriate.

7 QP05A Title: SUPPLIER SELECTION To ensure that suppliers are capable of meeting order requirements. Quality Manager 1. Procedure 1.1 Select suppliers initially on the basis of their potential to supply product or service to the required specification and on the following minimum criteria: - Calibration services to demonstrate traceability to national standards - Product for re-sale suppliers must be able to meet contract material spec & other national / international approval standards - Special process sub-contractors and test houses should be approved to ISO 9001 or equivalent. Where this is not possible the supplier will be evaluated on its performance. - Other suppliers will be approved on the basis of their performance 1.2 Compile and maintain an Approved Suppliers List listing all the suppliers and subcontractors who provide goods or services used in connection with Customer orders. 1.3 Grade the suppliers into one of the following categories: Grade A - At least 5 deliveries and no significant deficiency in quality or delivery Grade B - Quality or delivery to be more closely monitored Grade N New suppliers 1.4 Re-evaluate suppliers at the Management Review Meeting on the basis of their performance. Re-grade the suppliers as appropriate. 1.5 Where a supplier s performance is consistently poor, audit them and agree with the supplier a schedule of improvements to an acceptable standard. Delete from the Approved Suppliers List any supplier whose performance is consistently poor and who shows no sign of improvement.

8 QP05B Title: MATERIAL REPLENISHMENT PURCHASING Issue No: 1 Issue Date: 29/06/12 Page 1 of 2 To ensure that materials are sourced as necessary Stock Buyer 1. Procedure 1.1 MRP Run SAP MRP to establish material for order / reorder. Using criteria: Current Stock Levels Rates of Sales Outstanding Purchase & Sales Orders Mill minimum Production Quanities Lead Times Comparison of cost prices with current market selling price levels 1.2 MC86 Maintain Product Group 1.3 ZGIM Run Forward Sales Forecasts at the beginning of each month (for stock orders) & download to MRP. Every quarter, the programme is run for all materials (indent and stocks) which has to be completed by the dates advised by the mills. 1.4 MRP - MD01 Run MRP on line MD01. This programme is run DAILY to support the material movements generated by both sales and receipts. 1.5 ME57 Run Assignment Program (Restricted Option) ME57 - This programme is run DAILY. 1.6 ME21N Raise Purchase Order ME21N - using Suppliers on Approved Suppliers List (M:\\BU- UKSV001\all\Access\Calibation.mdb). Purchase Order With Reference (Sales related POs) Create Purchase Order with reference to a Purchase Requisition - ME21N Stand Alone Purchase Order Create Purchase Order with no reference to a requisition - ME21N

9 QP05B Title: MATERIAL REPLENISHMENT PURCHASING Issue No: 1 Issue Date: 29/06/12 Page 2 of Check & Adjust Pricing Conditions The originator of the purchase order is responsible for checking the pricing conditions. Both Bohler and Uddeholm pricing tables are maintained at the mill and automatically updated within SAP locally as prices change. 1.8 Check & Adjust Delivery Time EDI orders are adjusted automatically in SAP via ZPURN 1.9 Check & Adjust Valuation Type The Purchase Manager checks for anomalies daily Check & Adjust Import Duty Information Inform Purchasing Manager if information is missing or incorrect Header / Item Text Enter relevant Header / Item text Send via external printer to Eschmann Purchase order is sent via external printer direct to Eschmann. Confirmation received Send via EDI Send Purchase to mills via EDI: Hagfors - Sweden Kapfenberg - Austria Murzzushlag - Austria Confirmation Recieved Receive Confirmation from Supplier via EDI and/or Printer U656. Send via Fax To all other suppliers. Confirmation Received Receive Confirmation from Supplier via Fax Passed to Originator to Check Details

10 QP05C Title: BACK TO BACK PURCHASING To ensure that materials and back to back orders are sourced as necessary Purchase Manager 1. Procedure 1.1 A Purchase Order is created in SAP using details from the customer s purchase order. 1.2 The order detail required at this point is : Supplier Name, Article code, Quantity required Press "Enter". SAP will automatically fill in projected delivery date and purchase price. Review and amend dates and prices as appropriate. Also, check that article codes are correct against customer order requirements. 1.3 If all is now ok save the order. The purchase order prints off automatically in the office. 1.4 The printed order is then faxed / ed to the Supplier 1.5 For orders to Ternitz, the saved order is then sent via EDI to the mill. 1.6 An order confirmation is received from the mill and any amendments / updates are made using SAP. 1.7 The confirmation is matched to the original purchase order. The matched paperwork is kept in the purchase office for approximately 1 month, before moving into the administration area.

11 QP05D Title: GOODS IN PROCEDURE To ensure that materials are inspected before storage Purchase Manager & Warehouse Supervisor 1. Procedure 1.1 Notification of Shipping - Receive Packing Lists & Invoices from Supplier Eschmann: Hagfors / Kapfenberg / Murtz: Laser printer in Logistics Office Ternitz: Print in Purchase office EDI Mills - Automatic notification of weights, Heat No and trailer No, advised in P/O history Hagfors, Kapfenberg Non EDI Mills - Create a manual 103 SAP transaction on MIGO 1.2 Alien Suppliers (Local) - Current Alien & Sub Contract Goods Inwards do not use the bar coding function. Goods are delivered into the Goods Inwards area and placed in a SISO area within Goods Inwards. Suppliers paperwork which is received with the goods is signed and dated by the warehouse operative and is then sent to Logistics. 1.3 Goods Receipt - Using MIGO receive the goods into SAP, a Picking Note & Delivery Note is then raised (and an invoice if the order is for Export) the order then follows the despatch procedure. STOCK TO STOCK - Sub con Orders using MIGO receive goods into SAP, a label No is given to stock and ZCIM is created on SAP. 1.4 ZTRANS & Z105 - Create a ZGRL ( White sheet ) 1.5 Paperwork - For Toolsteel materials attach copy of Packing Lists and ZGRL to Report on Shipment. For Stainless Tube attach copy of ZGRL to Report on Shipment -See Appendix 5. Pass paperwork to Warehouse Goods Inwards. Logistics/Admin to keep a record of all paperwork and date sent to Goods Inwards 1.6 Advice of Delivery - Each transport company 'books in' their delivery with Logistics as per Delivery Timetable. This is then sent to the warehouse daily as advice of incoming deliveries. 1.7 ZUSI orders - Back orders - The material is shelved. The order will then follow the "ZUSI procedure". 1.8 Paperwork - Once all items have been actioned, the warehouse operative signs the Report on Shipment indicating if there are any discrepancies, and writes on the date the shipment is cleared in the warehouse. All paperwork is then returned to the Logistics/Admin Office. 1.9 Checking for Discrepancies -Once the delivery is completed by the warehouse, Logistics check for discrepancies in ZCIM using Single piece number Filing - The completed Shipping paperwork is then filed in the Logistics/Admin office in Trailer No order

12 QP06 Title: PICKING & MATERIAL DESPATCH PROCEDURE To ensure that materials are inspected before storage Purchase Manager & Warehouse Supervisor 1. Procedure 1.1 Picking Notes are generated via SAP by the sales office, and then printed directly into the warehouse Office. 1.2 Using the Picking Note recording database. The details of the picking note are recorded: Picking Note number Number of items Number of pieces Date received into warehouse Route Number 1.3 Picking notes are then placed in a tray waiting action by Warehouse Supervisor. 1.4 Prioritising, using the customer's required delivery date, the Warehouse Supervisor allocates the orders to one of four areas within the warehouse. 1.5 The Warehouse Operative collects Picking Note from Warehouse Office. 1.6 Material is picked / weighed and marked with: Customer Name, Picking Note number, Line item number, Delivery area code, Cast/Heat number, If small pieces, placed in a bag then a despatch label is attached 1.7 Picker collects Picking Notes from Warehouse Office, then material is picked according to the Single Piece allocation on the Picking Note and placed by a suitable saw. 1.8 Material is cut according to either the customer requirements as indicated on the picking note or the standard cutting tolerances of: Up to 600 mm diameter / thickness = -0 mm / +3 mm Above 600 mm diameter / thickness = -0 mm / +5 mm 1.9 Material is then measured dimensionally (see Gauges) and for squareness then weighed and marked as in 1.6 above If small pieces placed in a bag, then a despatch label is attached and any other additional requirements are identified on the picking notes instructions.

13 QP07 Title: CALIBRATION Scope: All instruments used to measure production components. QSHE Coordinator 1. General Instructions 1.1 Identify each instrument with a unique identification number. 1.2 Indicate on the calibration schedule the instrument details, the frequency of calibration and when each instrument is due for calibration. 2. Calibration 2.1 Send the instrument to an approved test house in accordance with the Calibration Schedule. 2.2 Examine the test certificates to ensure that the calibrated items are within the acceptance tolerances specified on the schedule. If acceptable, update the schedule. 2.3 Ensure that the instrument has a label indicating when it is next due for calibration. 2.4 If the results of calibration indicate the need to change the frequency of calibration, alter the frequency on the schedule. 3. Non-Conforming Instruments 3.1 Segregate and label any instruments that cannot be adjusted to read correctly. If the instrument cannot be repaired and re-tested, segregate and dispose. 3.2 Assess and document as appropriate the validity of previous measurements taken with the non-conforming instrument. Re-verify as necessary. 3.3 Attach a label with 'Calibrate before use' on instruments which are not in current use but are retained nevertheless.

14 QP09 Title: INTERNAL AUDIT To ensure that all processes are compliant and effective Management Representative 1. Audit Procedure 1.1 Maintain a Quality Audit Schedule detailing the sections of the quality system which are to be audited and when. This allocation must take into account the importance and status of the procedure being audited. Each process and element of ISO 9001 must be audited at least once a year. 1.2 Ensure that the Auditor is independent of the section being audited and has received appropriate training. 1.3 Review all the relevant processes and associated documents to check their accuracy and effectiveness. Take random samples and ensure that they and the associated records comply with procedure and ISO 9001 requirements. 1.4 Detail the corrective actions required for deficiencies and the target completion date on the nonconformity report and sign. 1.5 Enter the results of the audit onto the Audit Report Form. After the audit, review the audit with the auditee. 1.6 Review outstanding non-conformities with the auditee at each internal audit. When the necessary corrective action is effective, enter the detail of the corrective action and close the nonconformity by entering the closed date. Delete the report number from the internal audit schedule. 1.7 Review the results of the audit at management review.

15 QP10 Title: CONTROL OF NONCONFORMING PRODUCT To ensure that all nonconforming product is segregated and investigated Operations or Production Manager 1. Procedure 1.1 Monitor Processing for Non-conformance The Warehouse Operative monitors processing by continuous inspection, stops processing if nonconformities are identified or suspected and informs Warehouse Supervisor. 1.2 The Warehouse Supervisor Stops production if appropriate while non-conformance is investigated. Suspect materials are contained and suspect material tagged using the HOLD Label, identifying responsible and any relevant information. Suspect material is segregated from conforming material by placing it in the Quarantine Racks. The Technical Services Manager is informed. 1.3 The Technical Manager investigates to determine the extent of the problem by tracing back to the last point of known control and conformance and identifies nonconforming product in the plant and any that may have left the facility. 1.4 A Stock Transfer Sheet is generated requesting the Warehouse Supervisor to remove nonconforming material from all departments and move it to Quarantine Inspection location 1.5 The Warehouse Supervisor ensures all material is identified with a HOLD label showing the relevant details and contact name of Technical Services Manager. Logistics Administration are informed sending the completed Stock Transfer Sheet. 1.6 All nonconforming material identified is transferred to QI location on SAP, also amending the Single Piece file. 1.7 The Technical Manager reviews suspect or nonconforming material and determines disposition (may include rework, scrap or acceptance under concession). 1.8 All nonconforming material to be scrapped is removed from SAP records. 1.9 If nonconforming material has been shipped, the customer is notified of the problem The customer may decide to order a recall, authorise rework, or further investigation of the material, may issue an authorisation to allow its use or another option determined by the customer acceptable to Böhler Uddeholm UK Limited top management.

16 QP11 Title: CORRECTIVE AND PREVENTIVE ACTION Issue No: 2 Issue Date: 20/07/12 Page 1 of 1 Management Representative 1. Corrective Action 1.1 Enter the details of an internal deficiency, customer complaint or return into the NCR Sharepoint Platform. For instructions in the use of the Platform see the User Guide. 1.2 Investigate the problem, take the necessary corrective action and enter the details into the NCR. Review stock, WIP, bought and delivered items for similar defects. 1.3 Analyse the cause of the problem and take the necessary action to prevent recurrence. Apply the required controls to ensure that the action is effective. This action should be commensurate with the magnitude of the problem and the risk involved. Enter the details into the NCR. 1.4 Monitor the corrective action until satisfactorily completed. On completion sign off the Effectiveness section of the NCR. 2. Preventive Action 2.1 Preventive action is taken through careful review of customer requirements, training and regular equipment maintenance. 2.2 Review audit, corrective action, customer satisfaction and process reports for adverse trends and review market and QMS changes for any potential sources of preventive action. Determine and take the necessary preventative action and apply the necessary controls to ensure that it is effective. Record the actions taken. 2.3 Report on corrective and preventive actions to the management review meeting. Issue Date Amendment 2 20/07/12 NCR Sharepoint Platform added