1.0 Purpose:
This procedure describes the Anti-Counterfeit Control Plan at Alvatek Electronics, LLC ("Alvatek") in compliance with AS6496 Fraudulent/Counterfeit Electronic Parts; Avoidance, Detection, Mitigation, and Disposition.

2.0 Scope:
This procedure applies to all employees.

3.0 Responsibility
The Director of Quality is responsible for the final review and approval of this procedure. Employees with responsibilities for purchasing, receiving or verifying parts shall also be responsible for compliance to this plan.

4.0 Detailed Procedure: 4.1 Anti-Counterfeit Policy
The following policy has been reviewed and approved by executive management.

Anti-Counterfeit Policy
Alvatek has adopted this Anti-Counterfeit Policy to eliminate the impact of counterfeit products on Alvatek and its customers. This is a zero tolerance Policy against knowingly and intentionally trafficking in counterfeit goods.

To support this policy of ensuring that there is a low risk of counterfeit products entering our supply chain, Alvatek maintains processes to ensure purchases are only made directly from the Manufacturer or Manufacturer approved sources. This is accomplished through conformance with SAE AS6496 Fraudulent/Counterfeit Electronic Parts: Avoidance, Detection, Mitigation, and

Disposition – Authorized/Franchised Distribution.
Should a suspect counterfeit or counterfeit product be found, Alvatek shall quarantine such material and report the finding to the supplier and appropriate authorities. This policy shall be communicated, understood, implemented, and maintained at all levels of the Organization. This policy shall be posted on Alvatek’s Web Site. It is also contained in this plan where it shall be available for the customer’s records. This Policy shall also be communicated to all employees through meetings and postings.

4.2 Anti-Counterfeit Control Plan
This plan has been developed to address all the requirements of AS6496 and give sufficient detail and/or references to other plans, procedures or records. This plan is for customers and Alvatek employees. It shall be posted on Alvatek’s Anti-Counterfeit Web Site. It is Alvatek’s plan to only perform Authorized Distribution.

4.3 Customer Related Processes

4.3.1 Disclosure of Non-Authorization
It is Alvatek’s plan to only source products from the OEM or Authorized Distribution. If this plan is changed and Alvatek agrees to perform unauthorized distribution, Alvatek shall notify the customer at the time of quote. When authorization is terminated, customers with outstanding orders shall be contacted.

4.3.2 Provision of Manufacturer’s Warranty
In accordance with Manufacturer distribution agreements, Alvatek shall pass on applicable warranty and support such warranty.

4.3.3 Distribution Agreements
Alvatek shall have a documented distribution agreement with the Manufacturers Alvatek distributes. Such agreements are considered proprietary and not subject to review by third parties unless mutually agreed upon by both the Organization and Manufacturer. Alvatek shall have a letter from the manufacturer that attests to the existence of a distribution agreement between Alvatek and the Manufacturer.

4.4 Register of Suppliers
Alvatek maintains a register of suppliers in compliance with AS9100C.

4.4.1 Purchase Restrictions
Alvatek shall only purchase parts for resell from the Manufacturer or from the Manufacturer’s Authorized Distributor. When Alvatek purchases from an Authorized Distributor the distributor’s authorization with the manufacturer shall be verified and documented.

4.4.2 Purchasing Preference
Alvatek has a preference to purchase Parts for resale directly from the Manufacturer. See PTAM-PR-002 Product Purchasing.

4.4.3 Purchases Outside of a Distribution Agreement
It is Alvatek’s plan to only source material from OEMs or Authorized Distribution.

4.4.4 Counterfeit Electronic Part Control Plan Requirement
The Director of Quality shall maintain records of other Authorized Distributors adherence to AS6496.

4.5 Traceability, Record Retention and Retrievability
Alvatek retains and maintains records of product origin per AS9100C. They are maintained for 10 years.

4.5.1 Military Parts
When Alvatek distributes Military Parts the documentation required by MIL-STD-790 and JESD31 shall be provided to the customer with each order. Military Parts at Alvatek are the Parts authorized by the Manufacturer through MIL-STD-790 and authorized through the Defense Logistics Agency (DLA).

4.5.2 Commercial and Industrial Parts
Commercial and Industrial Parts delivered by Alvatek shall have a Certificate of Conformance on the Alvatek Packing List.

4.5.3 Provision of Traceability
Under normal circumstances Manufacturer provided records of product origin are not provided to customers on Commercial and Industrial Parts. When warranted by special circumstances or contract, Manufacturer provided records of product origin shall be provided to customers.

4.5.4 Retention Period
Manufacturer provided records of product origin are maintained for 10 years. Records from Manufacturers and other Authorized Distributors shall be maintained as received. Scanning programs shall be suitable to produce readable copies of original forms. If any scanned document is not readable, the original documents shall be retrieved or reproductions from the Manufacturer shall be used. When record retention times required by customers exceeds 10 years, the organization shall be able to accommodate reasonable request for extended retention. Types of records and medium of storage shall be negotiated between Customer and Organization.

4.5.5 Certificate of Conformance
Alvatek’s Certificate of Conformance is printed on each and every packing list. The Certificate of Conformance contains language as follows:

CERTIFICATE OF COMPLIANCE – Alvatek Electronics, Inc. is an independent/authorized distributor of the products furnished on this shipment and hereby certifies that the products are new, unused and were purchased solely from the original manufacturer or though the manufacturer’s authorized distribution. The original manufacturer warrants and certifies that the products they produce meet their specifications. Evidence of this warranty and certification is maintained at the manufacturer and/or at Alvatek. This pack list is the Evidence of Conformity that this shipment meets the requirements of Alvatek’s Quality Management System and/or Customer Purchase Order requirements agreed on between Alvatek and Customer. Environmental compliance per producer documentation. The packing list with the Certificate of Conformance as a unit is considered the whole Certificate of Compliance. This Packing List with Certificate of Conformance includes the follow data:

  1. The name and address of both the Organization and the Customer
  2. The Manufacturer’s name
  3. Manufacturer’s part number
  4. Quantity
  5. Date code (if provided by the Manufacturer and required by the Customer)
  6. Lot code (if provided by the Manufacturer and required by the Customer)
  7. Customer purchase order number
  8. Ship date to Customer
  9. Authorized Distributor Statement of Conformance
  10. Signature of Responsible Party (Electronic Signature is acceptable)
  11. Country of Origin
  12. Customer part number (if known and required)

4.6 Control of Suspect, Fraudulent and Confirmed Counterfeit Parts
Alvatek has several processes imbedded into the QMS that evaluate and minimize the risk associated with potential counterfeit product infiltrating into Alvatek’s inventory.

4.6.1 Customer Returns Return Policy

  1. Alvatek’s Return Policy is described in our Terms and Conditions section 1a. Returns:
    Customer must notify Alvatek within 90 days from date of shipment of any defective product. (See Alvatek’S LIMITED WARRANTEE for further information.) Returns are normally accepted when completed within 30 days of the ship date. If Alvatek agrees to accept a return, return freight charges must be prepaid by customer. Alvatek shall not accept COD shipments. Some products may require return directly to the manufacturer. Contact a sales representative for a Return Materials Authorization Number and addressing instructions prior to returning product. The foregoing statements concerning Returns do not apply to NON-CANCELABLE/NON-RETURNABLE PRODUCTS. (See the NON-CANCELABLE/NON-RETURNABLE PRODUCTS section in these terms.)
  2. Alvatek shall issue an RMA to a customer when a Return is authorized.
  3. Per Alvatek Terms and Conditions section 1.b Counterfeit Product Prevention Clause:
    Only products originally shipped from Alvatek or from a supplier at Alvatek’s direction (drop-ship) shall be returned to Alvatek. All others shall be promptly quarantined and disposed of or returned to the customer. By a Customer returning products to Alvatek, the Customer certifies that the products were purchased from Alvatek and there has been no substitution in whole or part of same product from another supplier, distributor or other such source of the product. The return should be in the original packaging (manufacturer or Alvatek), in unused condition (except defective). ESD sensitive products should not be opened except under controlled conditions.
  4. Returns from known Independent Distributors or Brokers are not allowed and when found shall be scrapped. Return Verification
The majority of customer returns are scrapped. They are scrapped per internal controls that limit risks based on the customer, the cost of the parts, packaging issues and signs of use or alteration. They are scrapped instead of being verified for economic reasons.

  1. Parts that are not scrapped automatically shall be verified against traceability records. This can include lot and/or date code when available from the Manufacturer.
  2. For further information on Returns processes, see Returns procedures or contact the Director of Quality.

4.6.2 Supplier Shipments
Manufacturers and other Authorized distributors are very low risk for counterfeit. Therefore inspection shall consist of count, kind, condition and documentation. The Director of Quality shall monitor this risk and revise this plan when warranted. Alvatek shall review documents supplied from the supplier with the shipment and ensure the shipment is from the intended supplier per the Purchase Order.

4.6.3 Disposition of Parts Deemed Suspect, Fraudulent or Counterfeit
Suspect Fraudulent and Counterfeit parts are treated as non-conforming product per AS9100C and dispositioned per non- conformity procedures in Returns and Products.

  1. Records of the dispositions shall be maintained.
  2. Suspect Parts may be returned to the Manufacturer for analysis and disposition to confirm their status as counterfeit or not counterfeit.
  3. Confirmed Counterfeit Parts shall not be returned to the Customer and may be retained for investigative or training purposes. The Organization shall quarantine the Parts for 5 years, or longer, if required by legal requirements.
  4. After 5 years or when legal requirements allow, the confirmed Counterfeit Parts shall be scrapped per 4.8.

4.6.4 Re-stocking Prohibition
Suspect, Fraudulent or confirmed Counterfeit Parts shall not be reintroduced into the supply chain, restocked nor returned to the Manufacturer in a stock rotation.
The Organization shall not restock product into its Authorized Inventory that was not purchased from the Authorized Distribution Channel.
4.6.5 Packaging and Repackaging Parts Sold to Customers Alvatek shall send part in Manufacturer sealed packaging when the quantity ordered is closer to standard manufacturer package quantity. When Manufacturer packaging cannot be sent, Alvatek shall package the product in standard commercial packaging or when required by manufacturer, the manufacturer’s specified packaging. Traceability on the repackaged parts is maintained by the System. The traceability shall be printed on labels and packing list as available from the Manufacturer.

4.7 Training
Employee in Asset Management, Products and Warehouse shall be trained on their processes to prevent counterfeit. This training shall be documented in training requirements per applicable position.

4.8 Scrap Control in Authorized Distribution
Scrap Control is documented in the AS9100C scrap procedures. WHRV-PR-026 Stock Rotation Scrap and WHSA-PR- 063 Warehouse Scrap Disposition.

4.9 Inventory Control Plan
Alvatek has an inventory control system which provides for traceability of all stock movements. Customer Returns shall be traceable per section

4.9.1 Segregation of Product
Alvatek intention is to only be authorized, if unauthorized stock is received by Alvatek, Alvatek shall treat it as suspect and scrap appropriately.

4.9.2 Inventory Access
Warehouses where inventory is kept shall have ID card access. Visitors shall be escorted.

4.9.3 Traceability of Returned Parts
Customer returns are traced in the inventory control system. Customer Returns are not commingled with new and used parts. There is sufficient capacity to exclude customer returns. Records of customer returns are maintained.

4.10 Reporting
Reporting on confirmed counterfeit parts shall be authorized by the Director of Quality. The Director of Quality shall make appropriate reports to executive management, affected Customers and affected Manufacturer. Confirmed counterfeit can only be determined by the Manufacturer.

4.11 Audits
This anti-counterfeiting plan and referenced processes are listed and scheduled for internal audit. This also makes the plan part of Alvatek’s QMS and subject to our third part registrar to AS9100.

4.12 Counterfeit Awareness
The Director of Quality is responsible for keeping informed on current counterfeiting information and trends, including detection and avoidance techniques contained in appropriate industry standards, and using such information and techniques for continuously upgrading internal processes.

4.13 GIDEP Participation
The Director of Quality shall ensure Alvatek is a member of GIDEP. The Director of Quality shall screen GIDEP reports and other credible sources of counterfeiting information to avoid the purchase or use of counterfeit electronic parts.

4.14 Obsolete Parts
In the context of this plan “Obsolete electronic part” means an electronic part that is no longer in production by the original manufacturer or an aftermarket manufacturer that has been provided express written authorization from the current design activity or original manufacturer. It is Alvatek’s plan to only perform Authorized Distribution. Therefore obsolete parts are not processed by Alvatek.