Supplier Requirements

The purpose of this manual is to provide an overview of the requirements and expectations that AssembleTronics llc, its Brands, subsidiaries and affiliates “ATRON” has for its suppliers. As a supplier, you play an integral role in our ability to continuously provide products of the highest quality level possible to our customers. This manual is intended for all suppliers of ATRON Circuit Inc, its affiliates and subsidiaries, which will be simply referred to as ATRON throughout the document.

1.1 Supplier Exemptions

ATRON recognizes that the requirements imposed on a supplier may vary based on the type of Good or Service provided. This comprehensive set of requirements is broken in to three different supplier types, which drive the expectations for supply base:

1) Direct Material Suppliers

• Suppliers that provide materials that are an integral part of the finished product. These suppliers must adhere to this entire set of requirements and are not exempt from any defined requirement. This includes, but is not limited to direct material components, flux, solder, adhesives, production chemicals, lubricants, etc.
• For avoidance of doubt, material (or component) distributors that do not manufacture but supply materials that are an integral part of the finished product are also classified as Direct Material Suppliers. Such distributors are also required to drive their manufacturing source(s) to the requirements specified in this document and report to ATRON of any deviations observed.

2) Indirect Material Suppliers

• Suppliers that provide material or goods which do not become an integral part of the finished product. These Indirect Material Suppliers are exempt from certain Supplier requirements which are denoted throughout this manual by a [1]
• Suppliers of materials that are directly used in or on production may not be exempt and are treated as a Direct Material Supplier. Some products include but are not limited to flux, solder, adhesives, production chemicals, lubricants, etc. Questions regarding these requirements should be directed to your ATRON contact.

3) Indirect Service Providers

Service providers refer to any entity providing services including any outsourced activities, to ATRON. The Indirect Service Providers are exempted from certain requirements specified in this manual, as denoted by a [2]. However outsourced partners, who provide services which impact performance of finished products (e.g., product rework, component programming, laboratories, warehousing, repackaging etc.,) are not exempted from these requirements unless they are one-off buys or have written agreements for exemption, with ATRON site requesting for the specific service. Likewise, service providers who have influence on ATRON’s employees’ welfare and safety are exempted from these requirements except for section 6.14 and Section 7 and such services providers include:

1. labor dispatching contactor: labor agencies who provide direct labor to ATRON facility either on contract or on permanent basis
2. commute transportation providers: vendors who provide regular transportation services for ATRON employees, to and from the workplace
3. catering service providers: vendors who provide regular meals to ATRON employees within the facility, e.g. canteen services
4. dormitory contractors: vendors who provide facilities for the staff to stay as part of the employment
5. maintenance providers: vendors who provide regular maintenance services like building or equipment maintenance services
6. security service providers: vendors who provides security to ATRON premises

Additionally, some industries or business sectors that ATRON serves may necessitate placing additional requirements upon suppliers. Appendix A of this manual provides a listing of some examples of these additional requirements by industry or market sector. All industry or market sector specific requirements that apply to each supplier will be communicated through documents including but not limited to this manual, purchase orders, written procedures, terms and conditions or quality agreements / contracts. Suppliers must make all reasonable efforts to comply with all specified ATRON requirements.

Also, if the supplier has Master Service Agreements (MSA) or other commercial agreements as in section 4 in place, those agreements will supersede all related clauses mentioned in this Supplier Requirements Manual

However, all suppliers are required to be in full compliance with all product, legal and regulatory requirements that apply to the countries that they are doing business with no exceptions.

Questions regarding any requirement should be directed to your ATRON Site Purchasing Manager or respective Supply Chain Development Manager, Divisional or Global Commodity Manager or Category Manager.

Built on a foundation of empowered employees, ATRON strives to be the world’s leading global manufacturing solutions partner.

ATRON’s unique combination of global expertise, ingenuity, analytics and financial performance has contributed to the success of the world’s most well-known brands.

We help companies design, build and take their products to market quickly, affordably and efficiently. But more than that, ATRON helps customers intelligently design their supply chains to be agile, economical and effective even in uncertain times.

For more information on ATRON, please refer to our website http://www.atrongroup.com/

3.1 ATRON Environmental Policy

As a socially responsible organization, ATRON endeavors to conduct its business in an environmentally responsible manner.

3.2 Supplier Environmental Expectations

ATRON has expectations for our suppliers in regard to their environmental impact. Suppliers to ATRON are expected to:

3.2.1 Have a documented and implemented environmental management system in place that spans their entire organization and is based on and compliant to ISO14001.

3.2.2 Be aware of and in compliance with all applicable environmental regulations and laws.

3.2.3 Employ Design for Environment techniques aimed at minimization of energy and materials use and environmental impact [1]

3.2.4 Endeavor to adopt and support the principles of ATRON’s Environmental Policy

3.2.5 Deploy these expectations within their supply chain

3.2.6 When visiting or working in ATRON facilities, follow local ATRON site environmental and safety requirements

3.2.7 Provide Material Safety Data Sheets (MSDS or SDS) for all supplied substances. This includes all substances brought onto ATRON premises. Material Safety Data Sheets or SDS and Hazardous Labels must be provided in the local language for the ATRON receiving site. [1][2]

3.2.8 Provide Material Composition Data. See section 6.7 for more information. [1][2]

3.2.9 Support ATRON’s Environmental Management System. Supplier participation is essential for ATRON to fulfill the requirements of its Environmental Management System. [1][2]

4.1 Non-Disclosure/Confidentiality Agreements

In the event Suppliers intend to disclose or receive confidential information in anticipation of and/or pursuant to providing products or services to ATRON, Suppliers will enter into a Non-Disclosure Agreement with ATRON prior to disclosing or receiving confidential information.

4.2 Purchase Agreements [2]

Suppliers who provide tangible, non-licensed products to ATRON are encouraged to enter into Purchase Agreements with ATRON before starting business.

4.3 Consulting Agreements [1]

Suppliers who provide consulting services to ATRON are encouraged to enter into ATRON’s Consulting Agreement.

5.1 System Foundation[1][2]

Suppliers are required to have a fully documented and implemented quality system that is focused on defect prevention rather than defect detection compliant to ISO9001 standard.[1][2]

Suppliers that are outside of ATRON’s direct sourcing control must meet any applicable ATRON customer requirements regarding registration and at a minimum are encouraged to document and implement a quality management system that is compliant to the ISO9001 standard. Achieving registration is highly encouraged.[1][2]

5.2 Third Party Registration requirements[1][2]

Some market segments (see Appendix A for a listing of these market sectors) that ATRON serves or other business needs may require our suppliers to already have or obtain third party registration to one or more additional quality standards (ISO/TS 16949, ISO 13485, ISO14001, etc…). Suppliers will be informed of any additional registration requirements that apply and the necessary evidence that will need to be provided to prove compliance, through this manual or other documentation.

5.3 Acceptance Sampling Plans[1][2]

The acceptance level for all sampling plans shall be zero defects (i.e. C=0).

5.4 Indirect Material Suppliers and Service Providers

Indirect Material Suppliers and Service Providers shall deliver Goods and Services in accordance with a Signed Agreement in addition to any ATRON business or site- specific requirements communicated with the supplier in writing. In the absence of a Signed Agreement, the terms and conditions on the Purchase Order will prevail.

6.1 Contact Information

Suppliers are expected to provide support to ATRON to facilitate rapid response to delivery, quality or unresolved issues. A primary and backup contact(s), as well as escalation contact(s), should be identified to provide this level of support and their contact information provided to ATRON. Any changes to the contact information should be communicated at the time of change.

6.3 Component Traceability – Labeling / Packaging[1][2]

Suppliers are required to have an effective material control system in place that at a minimum includes production lot identification (the lot code number assigned to each particular product run), date of manufacture (date code) and traceability of all parts and materials utilized in the manufacturing process. Records must be maintained and readily available for every production lot code / date code produced providing traceability capability.

6.3.1 Labeling[1][2]

Product shipped to ATRON must be labeled at a minimum with part number, po number, quantity and date/datecode. Additionally,

1. For moisture sensitive products, packaging and labeling in accordance to JEDEC specification J-STD-033 is required.
2. Products that are deemed ESD Sensitive must be packaged and labeled per JEDEC specification JESD625 “Requirements for Handling Electrostatic-Discharge-Sensitive Devices”.
3. Date sensitive products must be identified as such and additionally identified as date sensitive and label must contain “use by” or “expiration” date.

6.3.2 Packaging[1][2]

The supplier shall ensure that packaging is used that is effective in protecting product through point of use from any potential damage. Packaging should conform to current industry specifications (e.g. JEDEC, EIA) as well as all applicable current governmental and regulatory regulations. Copies of JEDEC Specifications are available from JEDEC at www.jedec.org. Copies of EIA specifications are available from Information Handling Services at www.global.ihs.com.

Each individual media carrier (e.g. reel, bag, tube, tray, box, etc…) may contain no more than 2 date codes. More than 2 date codes require ATRON agreement and approval. The date code(s) within each carrier must be clearly identified.

6.4 Component Date Code Limitations [1][2]

Component date code limitation (the time between the date of manufacture by the manufacturer and receipt at ATRON on inbound components is two 2 years, except for the following:

1. Customer specific limitations apply – will be communicated to supplier as applicable
2. Components having lead finishes that typically exhibit poor storage life – 12 months
3. Finishes such as silver (Ag) and Palladium Silver (Pd-Ag) that do not use a Nickel (Ni) barrier – 12 months
4. Moisture sensitive components – 12 months from the bag seal date
5. PCB’s with final finish of ImAg, ENIG, OSP or ImSn – 6 months
6. PCB’s with final finish of HASL– 12 months

6.5 First Article Approval / Production Part Approval Process [1][2]

First Article and / or Production Part Approval may be required prior to the first shipment of production material to ATRON or when a product undergoes a change. If this is required, suppliers will be informed of the documentation and data that will need to be submitted to receive approval to ship production material. Some examples of documentation and data that may be requested include:

1. Submission Warrant
2. First Article Inspection Report
3. Process Flow Diagram
4. Process Failure Mode Effects Analysis
5. Process Control Plan
6. Process Capability Studies
7. Measurement System Analysis Results
8. Dimensional Data
9. Material composition data
10. Physical Samples (i.e. Color, Texture, Appearance, Others)

If a specific format is required to be utilized for reporting, it will be communicated at the time of request for submission. In the event that a submission cannot be approved, the supplier will be informed of the discrepancies and required to submit corrective action. Once corrective action(s) is complete and the discrepancies has been corrected, the supplier must contact the ATRON Requestor to schedule a date for re-submission.

Questions regarding PPAP submission requirements or submission status should be directed to the ATRON contact requesting submission.

Copies of all requested First Article and PPAP submissions must be maintained by the supplier and be readily available for review upon request.

6.6 Process Sign Off [1][2]

Products may be selected to go through a Process Sign Off review prior to production approval. This review is conducted at the supplier’s manufacturing location(s) to assess production readiness to meet ATRON quality and volume requirements. Items that are typically reviewed during a Process Sign Off review include:

1. First Article and/or Production Approval documentation
2. Review of the actual production process (Receiving through Shipping) and product
3. Run at rate (production volume achieved in a measured period of time)
4. Equipment / Process Capability
5. Measurement Systems Analysis
6. Preventive / Predictive Maintenance
7. Process documentation (Work instructions, SPC charts, Visual Aids, etc…)
8. Training Plans and Records

Suppliers will be notified as early as possible of any product that is selected for Process Sign Off review and approval. Timing for this review and the areas to be covered will be coordinated with the supplier. Issues identified during the review must be corrected in order to close out the Process Sign Off and receive full production approval.

6.7 Component Composition Reporting / Environmental Compliance [1][2]

Suppliers must comply with all applicable governmental, regulatory and environmental requirements (including those of the country where products are manufactured as well as where it is shipped to ATRON). This applies to the design, manufacture and delivery of products to ATRON.

Suppliers are required to have processes in place to monitor changes in applicable governmental, regulatory and environmental requirements, determine the impact of the changes to their operations and products that are supplied to ATRON and take appropriate actions to ensure continuing conformance.

Suppliers are responsible for compliance to Banned and Restricted Substances (BaRS) requirements. These requirements apply to all materials, parts, components and products supplied for ATRON Circuit, Inc., including its Subsidiaries and Affiliates (“ATRON”). The ATRON BaRS requirements are available at http://www.atrongroup.com/portals/ATRON-bars-requirement.html.

Additionally, many countries are preparing or have already enacted legislation requiring producers and importers of certain products (including electronic products) to arrange for the return and recycling of products at the end of their useful life. ATRON is proactively focused on the environment and is committed to working closely with our suppliers to reduce the amount of environmentally relevant substances in our customer’s products.

All suppliers are required to prepare and submit full disclosure material composition data in the ATRON requested format for every part number that is supplied to ATRON. The format that must be used will be communicated to the supplier by a ATRON representative.

This requirement applies to all current and pending part numbers being supplied to ATRON. For part numbers (currently supplied) that undergo a change to fit, form or function, a Product Change Notice (Refer to Section 6.10) and updated full material disclosure report / declaration must be submitted. ATRON strongly recommends proper change management protocol is followed. Suppliers should include a part number change process for any material change for effective traceability and tracking.

If a specific commodity and/or supplier are determined to be at risk, ATRON may request, from time to time, suppliers to submit updated material composition data reports / declarations.

Suppliers are requested to establish a central point of contact for this reporting activity. This person should be the focal point for coordination of these reporting activities throughout the suppliers’ organization.

Suppliers are strongly encouraged to proactively ensure that all of their parts are reported to ATRON. To submit a report proactively (not as a result of receiving and responding to a specific request for reporting from a ATRON representative), please e-mail your submittal to the following e-mail address:

qc@atrongroup.com

In the event that a particular part number requires prioritization or expedited reporting, you will be contacted directly and expected to complete and submit the information in the time frame requested. All requests for reporting must be completed in the time frame requested.

The latest submission on record at ATRON will be considered the current version. It is the responsibility of all suppliers to ensure that the latest version of material composition data for all products that they supply to ATRON has been submitted.

Supplier performance in reporting will be considered as a factor for future sourcing decisions.

Questions regarding this requirement should be directed to your ATRON contact.

6.8 Conflict Minerals [2]

Certain regions, where several minerals used in the electronics industry originate, have been identified as “conflict” regions. The Democratic Republic of the Congo and adjoining countries are identified as conflict regions due to reported human rights abuses, environmental concerns and actions against citizens. Certain minerals that originate (are mined) from this region have been identified as “conflict minerals” and include gold (Au), tantalum (Ta), tungsten (W) and tin (Sn). Suppliers are required to undertake due diligence in reviewing / assessing their supply chain to assure that these minerals, if they are contained within the product supplied, are not sourced from mines that are in this conflict region which are controlled by non-government military groups, or unlawful military factions (“Conflict Minerals”).

Additionally, suppliers are expected to:

• Have in place (and provide information about upon request) a conflict free sourcing policy and controls for assuring only conflict free minerals are procured
• Monitor their supply chain as reasonably necessary to help avoid procuring “Conflict Minerals”
• Provide, upon request, supporting data / information confirming status and compliance.
• Support the Electronic Industry Citizenship Coalition activities / initiatives in this area

6.9 Product/Service Quality Concern Resolution

Suppliers are responsible for the quality of the product that they supply to ATRON. Product quality concerns can lead to disruptions in ATRON’s manufacturing operations, additional costs being incurred and potentially impact our customer. Additional costs incurred as the result of a supplier quality concern may potentially be subject to a request for cost recovery.

Once the quality issue is identified and depending on the impact to ATRON business, ATRON may notify Suppliers of a request for corrective action. If requested, suppliers are expected to:

1. Institute immediate containment action(s) for product within their facility(ies), in transit and at ATRON facilities.
2. Submit an initial containment plan to the ATRON requestor within 24 hours of notification.
3. Provide “certified” product as requested
4. Submit an initial failure analysis and corrective action report within 5 days of notification
5. Provide verification and recurrence prevention actions / evidence within 10 days
6. Provide a final corrective action report with supporting data within 30 days of notification. Continue containment activities until corrective action closure confirmation has been received from ATRON.
7. Provide additional support as agreed to

Any exceptions to the requirements stated above must be approved by the ATRON Requestor in writing prior to the due date.

Questions regarding these requirements should be directed to your ATRON contact.

Suppliers may be sent a template to be used for the completion of a requested corrective action. If no template is provided, the suppliers’ format can be used if it contains the minimum elements listed below.

a. Identification of the Corrective Action Team

b. Problem Description (5W, 2H)

c. Interim Containment Action

1. Actions Taken

2. Data showing effectiveness

d. Root Cause (s)

1. Root Cause for Occurrence

2. Root Cause for Not Detection

d. Corrective Action(s)

e. Verification – Verification of the effectiveness of the corrective action(s) taken

f. Preventive Action(s) – Actions taken to prevent recurrence

Depending on the nature of the defect observed by ATRON, the supplier may also be asked to provide a 3 Way- 5 Why Analysis.

For material suppliers, in the event that the implemented containment action(s) is not effective, additional containment action(s) must be initiated and may result in being placed on Controlled Shipping Status. Suppliers will be notified when a product is placed on Controlled Shipping Status, including the reasons why it is being requested. This notification will include specific requirements for containment and conditions for removal of the status.

Controlled Shipping Status is designated into 2 categories.

• CS1: This level of containment requires additional controls to be put into place by supplier upon the request of ATRON. The containment activities typically take place within the supplier’s facility (ies) and, as applicable, at their sub- supplier’s facility (ies). The containment actions should take place outside of the manufacturing process prior to shipment, unless other specific arrangements are made. The supplier is required to submit an updated containment plan, outlining additional actions that they propose to employ, to ATRON for review and approval.

• CS2: This level of inspection is typically implemented when all other containment actions have failed to isolate defects from getting to ATRON. This level of containment requires the use of an independent third-party source. In all cases, ATRON approval of the third-party source to be employed must be requested and received.

For material suppliers, if non-conforming product requires return, the supplier will be contacted with the pertinent information regarding the return and asked to provide a Return Material Authorization (RMA) number. This number will be used for tracking purposes and should be included in the corrective action report. Response is required within 24 hours of the receipt of a request for a RMA number and should include any necessary instructions for shipment.

Suppliers are strongly encouraged to initiate corrective action for all quality issues regardless of whether a corrective action response is requested by ATRON.

6.10 Shipment of Suspected Non-Conforming Product [2]

In the event that a suspect that non-conforming material has been shipped, they are required to immediately contact the effected ATRON site(s) to inform them of the following:

1. Part number
2. Quantity impacted
3. The suspected non-conformance
4. Lot number(s) impacted
5. Date code(s) impacted
6. Ship date, carrier, tracking number, etc.

Suppliers are expected to contain the suspect product, arrange for the shipment and receipt of “certified” replacement product to protect production requirements and the return of all suspect products.

6.11 Product Change Notices [1][2]

Product Change Notices are the mechanism that suppliers must use to inform ATRON of a proposed product changes, product discontinuations, end of life, etc… The information received in the notice is reviewed to determine its impact. Suppliers are required to submit a Product Change Notice for any proposed change including the following:

1. Change in manufacturing process
2. Change in material or change in material source
3. Change in manufacturing location
4. Change in part construction / design (i.e. Die Shrink)
5. New or modified tooling
6. End Of Life

Submission of a Product Change Notice to ATRON does not indicate approval of a proposed product change. ATRON reserves the right to reject any proposed change, require additional information or data to be supplied or seek customer(s) concurrence prior to granting approval. The supplier will be notified if any of these conditions apply to a proposed product change and the requirements for obtaining approval. Suppliers must maintain records of the date of implementation in production of each change.

For every Process Change Notice submitted, suppliers are required to review the impact to material composition and submit an updated full material disclosure report / declaration. Refer to Section 6.7.

To submit a Product Change Notice request, suppliers must send it via e-mail to: qc@atrongroup.com and/or purchasing@atrongroup.com. The guidelines for submitting a Product Change Notice are:

• Notices can be in any format (e.g. Word, Excel, PDF, etc…)
• The supplier logo and contact information must be included in the document
• Notices must describe the type of change proposed (e.g. End Of Life, Product Change, Manufacturing Location Change, etc…)
• A unique notice number must be generated for each Product Change Notice
• Each Product Change Notice must be dated
• For End of Life notices, the Last Time Buy Date and Last Ship Date must be included
• For all other change notices, the implementation date must be included
• Each notice must contain all part numbers that are impacted

6.12 Deviations from Specifications and/or Requirements

Suppliers are expected to ship product and services that fully meets all applicable specifications and requirements. Product that does not fully meet these requirements cannot be shipped unless prior written approval is received from ATRON in the form of a completed and signed deviation. Deviations are issued for a specific quantity or time period. Suppliers must strictly adhere to this specified limit. ATRON reserves the right to reject any request for deviation. Questions regarding deviations should be directed to your ATRON site contact.

6.13 Supply Chain Management [1][2]

Suppliers to ATRON are expected to have systems in place for the qualification and management of their suppliers that ensures the quality of the products that they receive. The system employed should encourage defect prevention. Suppliers must verify that their sourced suppliers are in compliance with all customer, product, legal, regulatory and environmental requirements that apply to the design, manufacture and delivery of materials and components. Sourced supplier performance should be measured and periodically reviewed with improvement actions identified / taken where appropriate.

6.14 Social and Environmental Responsibility[1][2]

Suppliers, in all of their activities, must operate in full compliance with the laws, rules and regulations of the countries in which they operate and also in full compliance with the Responsible Business Alliance(RBA) Code Of Conduct. Suppliers shall be committed to ethical conduct and respect for human rights in accordance with the principles of internationally recognized social and ethical conventions, for instance the United Nations’ Universal Declaration on Human Rights, International Labour Organization’s (ILO) Conventions and Recommendations and have internal guidelines in place to do so. The Universal Declaration on Human Rights document along with other United Nations documents pertaining to human rights can be found on their website at www.un.org. Copies of ILO Conventions and Recommendations as well as research tools for finding national and international laws can be found at the ILO website www.ilo.org.

The Responsible Business Alliance(RBA) Code Of Conduct outlines standards to ensure that working conditions in the electronics supply chain are safe, that workers are treated with respect and dignity, and that manufacturing processes are environmentally responsible. The Responsible Business Alliance(RBA) Code of Conduct can be found at http://www.responsiblebusiness.org/standards/code-of-conduct/

ATRON regards this as a total supply chain initiative. Therefore suppliers must also require their own suppliers to acknowledge and implement this code.

Suppliers are expected to support ATRON and / or Responsible Business Alliance (RBA)requests for Self-Assessment Questionnaire (SAQ) completion or on-site assessment (i.e. Validated Audited Process). Suppliers are requested to inform ATRON of any requested / planned Responsible Business Alliance assessments (VAP) and to provide a link to or a copy of the assessment results.

Suppliers are required to initiate corrective actions for any findings that may arise from these assessments and provide copies of these corrective actions including evidence of completion to ATRON.

Questions regarding this should be directed to your ATRON contact.

6.15 Site Visits [1][2]

Suppliers shall allow ATRON’s employees or representatives to visit all manufacturing facilities of Supplier or its subcontractors in which the Products are being built or assembled; provided that, (a) ATRON gives Supplier reasonable advance notice of each visit; and (b) such visit does not unreasonably disrupt the manufacturing capability of Supplier or subcontractor, or violate any safety or clean room procedures.

6.16 Product conformance data [2]

Suppliers may be requested to provide data showing product conformance to specifications and requirements. The content and submission requirements / frequency will be communicated to the supplier. Suppliers are expected to comply with ATRON requests to provide this information.

6.17 Business Continuity and Pandemic Preparedness Plans [1][2]

Suppliers are required to have in place a Business Continuity Plan, including Pandemic Preparedness. This plan should focus on protecting employees, maintaining operations, alternate supply in the event of enforced closures and extend to your supply chain. These plans should be exercised (tested) periodically to identify any potential problems or gaps, with corrective actions taken as necessary. These plans must be made available upon request.

There are sources that have published guidance available on key elements of these plans including their development and monitoring. A partial list of these sources includes:

• Center for Disease Control – http://www.cdc.gov/
• World Health Organization – http://www.who.int/en
• http://flu.gov
• Berkeley Lab – http://www.lbl.gov

6.18 Lithium Batteries [2]

As lithium batteries pose serious (sometimes catastrophic) hazards during transportation, specific regulations regarding the packaging, labelling, handling and marking of lithium batteries and lithium battery shipments have been enacted to minimize this risk. Suppliers to ATRON of lithium batteries must ensure that they are in compliance with all applicable laws and regulations regarding the packaging, handling, marking, labelling and transportation of these devices. Additionally, suppliers of lithium batteries are required to submit to ATRON a signed Supplier Statement of Compliance. This document can be obtained through your ATRON Site Purchasing Manager or by sending a request to purchasing@atrongroup.com.

ATRON employs an evaluation process for suppliers being considered for addition to ATRON Supply Chain strategies lists. Examples of methods used to consider sources for addition to these lists include:

1. Customer Recommendation
2. Third party quality system (i.e. ISO9000, QS9000, ISO/TS 16949, etc…) registration and completion of a self-assessment
3. Completion of an on-site assessment
4. A combination of the above

The requirements that need to be satisfied in order to be added to the list are communicated to suppliers that are being considered for addition. Corrective actions for items identified during this process are expected to be completed and submitted to ATRON in an agreed to time frame. The timeliness and quality of provided responses are also considered in the evaluation process.

The supplier evaluation process utilizes a series of documents that are available to our suppliers through your ATRON Site contact. ATRON reserves the right to send one of more of the following supplier evaluation documents depending on the business nature as part of supplier qualification or any ongoing risk assessment processes and in such cases, the responsible ATRON person shall get in touch with suppliers separately and guide through these assessment process, as and when this is required which includes:

1. Supplier Self-Assessment
2. EICC Self-Assessment
3. Logistics Self-Assessment
4. Supplier Acknowledgement Form
5. Supplier Baseline Surveys

ATRON employs a Supplier Performance System to measure the performance of our suppliers in the following areas:

1. Delivery
2. Quality
3. Service

The performance of each supplier in these categories is evaluated. Suppliers whose performance is deemed to need improvement in one or more categories may be requested to perform one or more of the following activities:

1. Prepare and submit a corrective action plan to address any category that is identified as needing improvement
2. Support and participate in joint supplier development initiative(s)
3. Present corrective action plans to ATRON site(s) and / or corporate leadership to achieve required performance

Ongoing performance results are used to evaluate our suppliers continuing ability to provide products that meet our expectations. A supplier’s status on an Approved Manufacturer List(s) can be impacted by ongoing performance issues.

Suppliers can obtain access to the Supplier Performance System (via ATRON Business Connect) in order to review their own performance scorecards. Suppliers are encouraged to proactively manage and continuously improve their performance. Information regarding access to the Supplier Performance System can be obtained from your ATRON site contact, Global Commodity Manager, Divisional Commodity Manager or Global Supplier Development Engineer / Manager.

8.1 Surveillance Audit [1][2]

Surveillance Audits may be periodically conducted to evaluate continuing ability to fulfill requirements and expectations. Surveillance audits can include the following:

• Request for supplier completion and submission of an updated Self Assessment Questionnaire
• On-site assessment
• Both a and b

Suppliers will be notified in advance of the need for completing a surveillance audit and are requested to provide the necessary support for completion.

Suppliers are expected to have a process in place for continuous improvement and should focus on continued reduction in variation, improvement in efficiencies and elimination of waste. Note: Continuous Improvement can only take place once all product and customer requirements (including process capability) have been fully and consistently fulfilled.

ATRON is committed to maintaining the highest ethical and legal standards. We strive to comply with both letter and spirit of the laws and regulations in each country in which we do business. We conduct our day-to-day business in an honest and ethical manner with everyone. As a supplier of ATRON, you share a responsibility to help prevent bribery and corruption.

All suppliers will adhere to all applicable laws and regulations governing such Party’s conduct in connection with any Agreement, including, without limitation, the United States Foreign Corrupt Practices Act, the UK Bribery Act, and any laws or regulations of the U.S. Department of Commerce Bureau of Industry and Security and will not export or re-export any technical data or products received from a Discloser, or the direct product of such technical data, to any proscribed country listed in the U.S. Export Administration regulations unless properly authorized by the U.S. government.

12.1 Automotive Industry

Suppliers of components and services to ATRON that are used in automotive products are required to meet the following additional requirements:

a. Quality System Requirements [1][2]

1. Registration of the employed quality system to ISO9001:2015 is required. ISO registration must be from Certification body from an IAF MLA and ISO/IEC 17021 accredited third party

2. Suppliers shall develop a roadmap for achieving IATF 16949 certification from IATF recognized certification body. The timeline for achieving this certification should be determined in collaboration with ATRON Purchasing or Supply Chain representative for Automotive sector. Such roadmaps may include:

b. Certification to ISO 9001 with compliance to Customer defined QMS requirements (i.e. Minimum Automotive Quality Management System Requirements for Sub-Tier suppliers) through second-party audits.

1. Certification to ISO 9001 with compliance to IATF 16949 through second-party audits
2. Certification to IATF 16949 by an IATF recognized certification body.
3. A copy of the current registration certificate must be provided upon request. Suppliers are also requested to provide ATRON with the latest revision certificate for certification renewals or when amendments are made.
4. Suppliers whose registration certificates are either placed on probation or revoked must notify ATRON in writing within 24 hours of occurrence. ATRON reserves the right to request a copy of the supplier’s corrective action plans to address the non- conformances that led to probation or revocation.
5. Suppliers are required to notify ATRON in writing if a change in registrars is planned.
6. Suppliers of automotive product-related software, or automotive products with embedded software (if applicable) , shall provide evidence of implementation and maintenance of a Software Quality assurance process for their products upon request.

c. Production Part Approval[1][2]

1. Suppliers are required to fulfill the requirements of the Production Part Approval Process Manual which is available for purchase through the Automotive Industry Action Group on their website www.aiag.org. The level of evidence (Level 1, 2, 3, 4 or 5) that is required for submission will be communicated to the supplier.
2. Level 3 shall be the default level for all submissions unless otherwise specified.
3. Suppliers are required to update as necessary all applicable items in their PPAP file to reflect the production process, regardless of whether ATRON requests a submission.
4. Suppliers can create their own forms for PPAP submissions provided that the entire content of the forms contained in the PPAP Manual is included. Electronic forms are also available for purchase through the Automotive Industry Action Group.
5. Suppliers are required to maintain copies of all completed PPAP packages and ensure that they are readily available for review upon request.

d. Contingency Plans – Suppliers are required to prepare contingency plans to ensure flow of product in the event of an emergency (i.e. utility interruptions, labor shortages, equipment failure, fire, field returns, etc).

e. These plans should be available for review at ATRON’s request. [1][2]

f. Automotive Suppliers are approved by a multidisciplinary team in ATRON and requirements sent to suppliers by different functional teams for purpose of qualification.

12.2 High Velocity Sector

Any additional requirements will be communicated by individual ATRON Business Unit or ATRON Site. Questions regarding these requirements should be directed to the individual Business Unit or ATRON site making the request.

12.3 Telnet Sector

Any additional requirements will be communicated by individual ATRON Business Unit or ATRON Site. Questions regarding these requirements should be directed to the individual Business Unit or ATRON site making the request.

12.4 Computing & Storage Sector

Any additional requirements will be communicated by individual ATRON Business Unit or ATRON Site. Questions regarding these requirements should be directed to the individual Business Unit or ATRON site making the request.

12.5 Healthcare and Life Sciences Sector

1. The expectation for suppliers to the Healthcare sector is that “Good Manufacturing Practices” (GMP) are followed along with fulfilling the requirements of and holding third party registration to ISO 9001:2015. [1][2]
2. Supplier periodic Self Assessments and/or Site Assessments may be required to be completed to fulfill regulatory requirements. Suppliers will be notified in advance of the need to conduct an assessment and are expected to support their completion. Suppliers are expected to provide corrective actions, upon request, based on the results of these assessments.
3. Suppliers may be requested to provide component verification information in the form of First Article Inspection Reports (FAIR) or ATRON Product Part Approval Procedure (JPPAP). Suppliers will be notified if and when this information is needed. Suppliers are expected to support these requests. [1][2]
4. Any additional requirements will be communicated by individual ATRON Business Unit or ATRON Site. Questions regarding these requirements should be directed to the individual Business Unit or ATRON site making the request.
5. Changes and Change Notification: Suppliers product may be used in life critical products and therefore they must always behave with the safety of the patient and human element in mind. Suppliers must not make any assumptions as to the acceptability of or non-critical nature of any change to a component. Please review the inclusive nature of section 6.11 of this manual (Product Change Notices). Suppliers must assure that that the requirements in section 6.11 are followed without exception. ATRON’s Healthcare mission is to provide a safe pair of hands that allows our customers products to improve the safety and cost of health care. [1][2]
6. Suppliers must notify ATRON within one business day of the initiation of any regulatory inspections, or regulatory actions related to the contracted product or the facility in which the contracted product is manufactured, packaged, stored or tested. Suppliers must notify ATRON in advance of any pre-announced regulatory agency inspections or regulatory action associated with the contracted product or the facilities in which it is produced. Suppliers must provide ATRON with regulatory inspection cGMP observations with the potential to impact the production of ATRON product. ATRON must be considered regarding responses to observations related to ATRON products prior to submission to the regulatory agency. [1][2]
7. All materials intended to be used for healthcare products are to be procured, from authorized channels unless an exception is approved in writing by the customer, and with evidence of traceability back to the manufacturer. Authorized channels include: A) Manufacturer Direct; B) an Authorized Franchised Distributor or C) ATRON-Approved Independent Distributor, where evidence of traceability back to the manufacturer is readily available and will be provided. For ATRON-Approved Independent Distributor purchases, traceability evidence must be readily available upon request. Material that cannot be sourced in line with these requirements must be authorized through notification and written approval of the applicable healthcare customer. The request for customer approval will include any pertinent steps taken to determine material acceptability (i.e. Physical Inspection, Control Plan Tests, etc.). Documentation of the results of these mitigation steps must be provided to the healthcare customer. [1][2]

12.6 Industrial and Energy Sector

Any additional requirements will be communicated by individual ATRON Business Unit or ATRON Site. Questions regarding these requirements should be directed to the individual Business Unit or ATRON site making the request.

12.7 Defense and Aerospace Sector

1. ATRON customer approved sources may be required to be used by ATRON’s suppliers. In the event that this applies, the requirement will be communicated to impacted suppliers and suppliers have to provide evidence of conformance.
2. Suppliers need to ensure that all applicable requirements, including key characteristics are communicated to their sub-suppliers.
3. Suppliers may be requested to provide a full or partial First Article Inspection Report (FAIR) at start of production or upon or when the following occurs:

1. Lapse in production for two years or as specified by the customer
2. Change in manufacturing process,
3. Change in material or change in material source,
4. Change in manufacturing location
5. Change or modified tooling
6. Changes made to product design
7. Change in inspection methods, Changes in product design include any change which affects the revision / mod level of the product. Additionally, a copy of the initial FAIR may be requested on first shipment to JDAS. FAIR submissions should meet AS9102 requirements or as specified by the customer. Specific requirements for submission will be communicated to the supplier should submission be required. [1][2]

12.8 Market Mid Sector

Any additional requirements will be communicated by individual ATRON Business Unit or ATRON Site. Questions regarding these requirements should be directed to the individual Business Unit or ATRON site making the request.

12.9 Business Automation Sector

Any additional requirements will be communicated by individual ATRON Business Unit or ATRON Site. Questions regarding these requirements should be directed to the individual Business Unit or ATRON site making the request.

12.10 Home and Energy Management Sector

Any additional requirements will be communicated by individual ATRON Business Unit or ATRON Site. Questions regarding these requirements should be directed to the individual Business Unit or ATRON site making the request.

12.11 Clean Technology Sector

1. Suppliers may be requested to provide a First Article Inspection Report (FAIR) at start of production or upon changes made to product design. Specific requirements for submission will be communicated to the supplier, should submission be required. [1][2]
2. Suppliers must notify ATRON of any product that they provide that has a shelf life of less than 2 years, from the date of manufacture. [1][2]
3. Suppliers must provide a Certificate of Conformity (CofC) with each shipment to ATRON. [1][2]
4. Onsite Support[1][2] – In the event that it is determined that supplier onsite support is needed, the supplier will be contacted, provided with information regarding the basis of the need and the time frame for which it is being sought. In the event that onsite support cannot be provided, suppliers are requested to work with the ATRON requestor to find a mutually acceptable alternative.
5. Any additional requirements will be communicated by individual ATRON Business Unit or ATRON Site. Questions regarding these requirements should be directed to the individual Business Unit or ATRON site making the request.

Last updated June 2018