POLICY for AVOIDANCE of COUNTERFEIT MATERIAL in the SUPPLY CHAIN
The purpose of this policy is to define actions to be taken by Carwood for the avoidance of counterfeit materiel in the business supply chain.
This policy covers all purchases and items acquired by the business including the parts, components and equipment that are subsequently sold on or included in the manufacture and testing or examination of products produced by Carwood.
REFERENCES, ABBREVIATIONS AND DEFINITIONS
All references, abbreviations and definitions that apply to this policy are as stated in the Defence Standard 05-135 Issue 2 dated 14th July 2019, Avoidance of Counterfeit Materiel sections 3, 4 and 5.
STATEMENT OF POLICY
Carwood will not knowingly procure, use or supply any counterfeit item or material. Carwood shall have arrangements in place as detailed below to manage the risk of counterfeit material in the supply chain. An Anti-Counterfeiting Management Plan (ACMP) shall be produced as required in accordance with Defence Standard 05-135 Avoidance of Counterfeit Materiel.
ARRANGEMENTS FOR MANAGEMENT OF RISK
The risk of acquiring counterfeit material is managed by:
Assessment – of likelihood and criticality of encountering counterfeit materiel in the supply chain for a particular product, part or application.
Avoidance – through application of the Supplier Selection Process and the Approved Supplier List, the business will only acquire products and services from known, reputable and traceable sources. The business policy is to purchase directly from the original manufacturer whenever possible and to flow down the requirement to manage counterfeit material where risk is identified.
Detection – by inspection of goods and materials where required by the Approved Supplier Grading process, any new or potentially risk bearing suppliers will have their supplied goods inspected. In addition, all goods inwards staff and technicians will be required to be vigilant for counterfeit material using their experience, training & awareness.
Elimination – any instances of counterfeit material will result in quarantine of the items and reporting of detected instances to the customer, industry and the appropriate authorities. Counterfeit material will not be returned to the supplier. Instances of counterfeit material detection shall be communicated to the IPR holder as known, the supplier, the customer if in receipt, relevant organisations, the police and Trading Standards.
ROLES & RESPONSIBILITIES
The Board shall determine this policy and ensure that it is available, communicated, understood and implemented by relevant staff.
The Quality Director has responsibility and authority to ensure the arrangements required to manage the risk of counterfeit material are implemented and maintained. The Quality Director shall report any concerns to the Board immediately and document them on the monthly quality (QMS) report. The Quality Director shall determine the process for test and verification of suspected counterfeit material on a case by case basis commensurate with risk and criticality in relation to safety and performance. All staff shall follow this policy and associated Anti-Counterfeit Management Plans and promote awareness of the issues concerning counterfeit material in the business supply chain.
COMPETENCE, TRAINING, AWARENESS & COMMUNICATION
All staff shall receive Quality Awareness training that include this policy and its implications for the business. The training shall be compulsory and recorded on the staff training matrix on the Management Information System (MIS). Awareness and effectiveness shall be monitored through the Quality Improvement and Audit processes in accordance with the level of risk assessed as part of the internal audit planning programme as defined in the Quality Management System (QMS). This policy shall be available to all staff through publication on the Management Information System (MIS). This policy shall be made available to third parties on request and published on the Company web site.
CARWOOD PRODUCT PROTECTION
Carwood shall apply unique serial numbers on all manufactured or re-manufactured products and shall actively enforce its registered trademark. It shall control production, packaging and documentation to avoid misrepresentation of products in the supply chain.
For more information: