Policy on Avoidance, Detection, Mitigation, and Disposition of Counterfeit Electronic Parts

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1 Policy on Avoidance, Detection, Mitigation, and Disposition of Counterfeit Electronic Parts It is the policy of Giga-tronics Inc/Microsource, hereinafter referred to as Giga-tronics, to maximize the use of authentic, originally designed or qualified parts throughout the product life cycle. Wherever possible, Giga-tronics procures parts directly from the Original Component Manufacturer (OCM), or through the OCM authorized distribution chain. Giga-tronics utilizes SAE AS5553 as a guide for avoidance, detection, mitigation, and disposition of counterfeit electronic parts. In those cases where it is not possible to obtain electronic parts from the OCM or the OCMauthorized distributors due to component obsolescence and related issues, Giga-tronics has implemented a series of steps (refer to Appendix A) to avoid and detect the use of counterfeit parts in its products: 1. All independent parts distributors are assessed as part of the AS9100 supplier control procedures, which includes supplier surveys/audits and monitoring of supplier quality data to assess performance. 2. Giga-tronics, through its membership in GIDEP, reviews product alerts for potential counterfeit parts in the supply chain. 3. Requirements to suppliers. All electronic parts suppliers are bound with Giga-tronics purchase order clauses that contains the following requirements: a. Supplier shall ensure that Counterfeit Parts are not supplied to Giga-tronics. Counterfeit parts include Parts that do not contain the proper internal construction (die, wire bonding, etc.) consistent with the ordered part. Parts which have a different package style or surface plating/finish than the ordered parts. Parts that have been used, refurbished, or reclaimed, but represented as new parts. Parts that have not completed the OEM or OCM full production and test flow, but are represented as completed parts. Parts sold with modified labeling or markings intended to misrepresent part form, fit, function, grade, or manufacturing date. Parts sold as screened parts, but have not successfully completed screening. Revision MKF01025 Page 1

2 b. Suppliers of electronic parts other than the OEM/OCM or the OCM authorized distributors (i.e., from independent distributors) as a minimum shall be required to provide supply chain traceability and perform and furnish certification of authentication inspection/test per IDEA-STD-1010 (revision B minimum) standards. Additional testing and certification may be required (see section 4.c). c. If Giga-tronics determines that counterfeit parts have been furnished by any supplier under a purchase agreement, such parts shall be impounded, marked, and prevented from re-entry to the supply chain. The seller shall promptly replace such items with items acceptable to Giga-tronics, and the seller may be liable for all costs relating to impoundment, removal, and replacement. The seller of such items shall be obligated to disclose to Giga-tronics the source of the items. Giga-tronics may turn such items over to US Government authorities for investigation and reserves the right to withhold payment for suspect items pending results of the investigation. Giga-tronics shall report through the GIDEP and ERAI systems and databases all suspected counterfeit parts and their suppliers. 4. Parts verification. The following shall apply to electronic parts that have been supplied from other than the OEM/OCM or the OCM authorized distributors (i.e., supplied from independent distributors): a. Upon receipt, parts shall be subject to 100% visual inspection per the IDEA-STD requirements as a condition of acceptance. b. Issuance of certificate of conformance as defined in paragraph 3.b. shall be verified. c. Parts shall be segregated, controlled, and subjected to a Material Review process for further disposition. Depending on severity of the end-item application, customer requirement, or other risk factors, Giga-tronics may require more extensive authentication tests and certifications, including x-ray, XRF for termination finish, destructive physical analysis, thermal cycle testing, hermeticity testing, full electrical testing, component-level burn-in, and/or in-use functional testing. The Material Review disposition shall also include an appropriate sampling plan. 5. As a further screen against the inadvertent introduction of counterfeit parts, all Gigatronics end-items that contain electronic parts supplied from other than the OEM/OCM or the OCM authorized distributors shall be subjected to 100% infant mortality stress screening (burn-in) at elevated temperature, minimum 48 hours. 6. All Giga-tronics end-items are subjected to 100% performance testing and are fully warranted to meet specifications and conformance to customer requirements. 7. Customer notification. As required by customer contract or Purchase Order, Giga-tronics shall notify its customers and obtain approval of the use in its products of electronic parts Revision MKF01025 Page 2

3 that have been supplied from other than the OEM/OCM or the OCM authorized distributors. 8. Any Giga-tronics end-items that are subject to customer-specific counterfeit avoidance requirements shall be internally tracked throughout the manufacturing process, including rework, via order flags or similar methods to assure that all elements of this policy and any additional customer requirements have been incorporated. 9. Giga-tronics shall conduct periodic counterfeit avoidance awareness training to Quality Assurance, Procurement, Engineering, and Manufacturing Engineering personnel. Revision MKF01025 Page 3

4 APPENDIX A Item # Title Reference/Description IDEA-STD-1010 Acceptability of Electronic Counterfeit inspection standard, supporting the AS5553 standard. Components Distributed in the Open Market PU04 Qualifying/Reviewing & Verifying Supplier Performance Independent Distributors: Independent distributor buys shall be made from only IDEA member suppliers that have incorporated IDEA-STD-1010 (revision B minimum). Suppliers are required to be ISO-9001 or AS9120 certified. All active Independent Distributors shall be fully surveyed/audited under the Giga-tronics Survey form PUF04015 and will be maintained in our survey records. All Independent Distributor buys for inventory are to be routed through Giga-tronics QA inspection and parts with the Certificate of Compliance records shall be submitted for assessment against the IDEA-1010 standard to ensure proper compliance. AML(Approved Manufacture List) parts are to be supplied to Gigatronics in good condition without improper markings, physical damage, non-esd packaging, contamination, compliance to selected date code restrictions as noted on the PO & QA observed counterfeit suspected parts clauses. Giga-tronics Independent Distributor PO s shall stipulate performance and certification of authentication inspection per IDEA-STD-1010 (revision B minimum) standard. Giga-tronics Independent Distributor PO s shall stipulate the following: if traceability from OCM cannot be clearly established then additional testing by the Independent Distributor must be performed to mitigate the risk of counterfeiting. Such testing may include, but is not limited to the following; Solderability testing, Fluorescent Dye Penetrate, XRF Analysis, X-Ray, marking permanency testing, Acoustical Microscopy (AM) testing, de-lidded/de-capped, submit part photographs and submit part samples for further Giga-tronics /Microsource testing evaluation. Revision MKF01025 Page 4

5 QU01 Receiving Inspection Process Refer to Section 2: For COTS (Commercial Off The Shelf) component parts, purchased from an independent distributor, Procurement will flag the parts for QA for inspection against the IDEA-1010 Acceptability of Electronic Components Distributed in the Open Market standard. Use the Counterfeit Avoidance Inspection Checksheet, QUF07079 for this purpose. QUF04018 Supplier Quality Assurance Requirements Giga-tronics flow-down quality clause requirements: P28 Counterfeit Material Seller warrants against counterfeit material being sold to Buyer (Gigatronics/Microsource) for a 1 year period coverage from the date of the receipt. The counterfeit terms includes all material altered or misrepresented from the original authorized source. Seller shall immediately notify the Buyer when the Seller becomes aware or suspects that it has furnished counterfeit material, and shall disclose the source of the items. Seller shall promptly replace confirmed counterfeit material with the genuine material. This clause also includes subtier flow down. Any suspect materials, determined to be counterfeit, will be impounded by Giga-tronics and scrapped. P29 Independent Distributors Preferred suppliers are to conform to the latest AS5553 Counterfeit Electronic Parts; Avoidance, Detection, Mitigation, and Disposition quality standard and are required to have IDEA (Independent Distributor Electronic Association) certification and actively utilize the most recent IDEA-STD-1010B inspection standard, or greater. Suppliers must have either ISO or AS9100 certification. Seller is to warrant against any counterfeit or no pulls/no used parts. Seller is required to specify supply chain traceability to the OCM that identifies the name and location of all of the supply chain intermediaries from the part manufacturer to the direct source of the product to the seller. If this traceability Revision MKF01025 Page 5

6 QUF07079 Counterfeit Avoidance Inspection Checklist is unavailable, or the documentation is suspected of being falsified, a documented risk assessment is required. Guidance and information regarding supply chain traceability are provided in Appendix C, Supply Chain Traceability, within the AS5553 standard. Refer to requirement 4.1.2, section f. Giga-tronics may request evidence of authentication either of supply traceability or of the supplier s risk mitigation efforts, as described above, for our own risk mitigation purposes. Giga-tronics checklist, modeled after the example shown within the IDEA-STD standard. Revision MKF01025 Page 6