Counterfeit Parts Policy

Technology Dynamics Inc. (TDI)
Nova Electric, Mid-Eastern Industries, Nova Battery Systems
100 School Street, Bergenfield, NJ 07621 / Phone 201-385-0500

Quality Management Procedures Doc No. QD40-110 Rev –

Title: Counterfeit Parts. Avoidance, Detection & Disposal

1.0 Purpose:
1.1 The objective of this procedure is to avoid counterfeit parts entering in TDI supply line and products, using recommendations and guidelines of SAE Standard AS5553

Counterfeit Parts are those Electrical, Electronics and Electromechanical (EEE) parts that are copied, substituted, recycled, refurbished or rejected but are represented as new products.

2.0 Scope:
2.1 This procedure is applicable to TDI procured EEE parts.

3.0 Responsibility:
3.1 Purchasing Dept is responsible for implementing this procedure.
3.2 QA Dept is responsible for creating & updating this procedure.

4.0 Procedure:
4.1 TDI is committed to design and built products that free of any counterfeit parts. This is achieved thru Purchasing from Correct Suppliers, Training Employees to Identify Counterfeit Parts and Quarantining & Reporting of counterfeit parts.

4.2 TDI will buy parts from Original Component Manufacturer (OCM) Or Their Authorized Suppliers. Such vendors are identified in TDI vendor list as Preferred Vendors.

4.3 When parts are not available from Preferred Vendor, only Approved Vendor will be used to source the parts, vendor will be asked to provide Certificate of Conformance (CoC) that includes Manufacturer name, address, part number and vendor certifying that parts supplied are new.

4.4 TDI Employees associated with Incoming Quality Control (IQC) and Production will be trained to visually identify parts that might not be original / new parts and could be suspect for counterfeit parts.

4.5 Shipments from vendors other than preferred vendors will get additional sample visual checks at Incoming Quality Control (IQC). Any suspect observations will be brought the notice of Purchasing Dept.

4.6 Production employees will visually check sample of parts they use in production. Any suspect observations will be brought to notice of Production Manager.

Quarantining & Reporting:
4.7 If it is suspected that there is a possibility of any part being a Counterfeit, such parts will be removed from Receiving Area, Stock Room or Production Floor and will be segregated in a separate area. Such parts will be clearly labeled with Red Tag for review by Material Review Board (MRB)

4.8 Purchasing & QA Departments will be informed about the suspect parts. QA Dept will further investigate the suspect parts and actions will be taken as warranted on case to case basis.

4.9 In case suspect parts are either confirmed or have high probability of being counterfeit then part supplier, part manufacturer and GIPED will be notified.

4.10 In case where customers received products with such counterfeit parts, customers will be notified of such incidents and arrangements will be made to recall such products for corrective actions. Any products in stock with such counterfeit parts will be reworked as per corrective action to remove counterfeit parts from finished goods.

Procedure End

5.0 Forms:
No Forms are assigned for this procedure.

6.0 References:
1. AS5553 Fraudulent / Counterfeit Electronics Parts. SAE Standard.