Employees, Suppliers  and  Business Partners are obliged to   implementation, oversight and respection of this Counterfeit material prevention policy applicable at Iwamet Sp. z o. o. 

The most important rule is to have and maintain the secure supply chain, which guarantees the most effective method of preventing counterfeit components entering the industry. 

Counterfeit parts – Unauthorized duplication, imitation, substitutes or modified parts (for example, materials, parts, components) that are knowingly placed/entered instead of the part made by the original or authorized manufacturer. Examples: parts with falsified marking (e.g. permanent marking, stamp, etc.) or a label on a given product, serial number, date code, grade, accompanying documentation (also in relation to the actual characteristics of the product, e.g. incompatible chemical composition, properties despite the fact that the material certificate specifies otherwise, etc.) or the characteristics of such a product, etc. 

Fraudulent activities – Deceit, trickery, dishonest practice, or breach of confidence, intentionally perpetrated for profit or to gain some unfair or dishonest advantage. This includes but is not limited to falsification of information, intentional omission, false pretenses, and deliberate misuse of qualified resources or certification/qualification/authorization. 

Potential consequences of fraudulent activity – risk of releasing nonconforming parts to the Customer,  potential to allow unsuitable parts into service, further processes without any knowledge, may have a significant impact on functionality of the part f.e. stamping the traveller by level 2 NDT which is showing the evidence that the part was inspected to the drawing requirement, however in reality the inspection never took place. This kind of situation can allow defects to go undetected where an appropriately processed part would have identified defect, stopping the part from continued processing and from ultimately being utilized on an aircraft.  

The basic principles are: 

Purchasing 

– monitoring reports / information on counterfeit parts from external sources, i.e. the Internet, internally from the company or directly from suppliers or customers. 

– purchases only from Suppliers approved in accordance with 

an internal purchasing procedure 

– purchases directly from manufacturers (and if this is not possible, then purchases from distributors on the List of Approved Distributors) 

– the requirement to provide certificates issued by manufacturers in the case of purchases from distributors. 

– verification of delivered documentation authenticity, stamps, signatures, authorizations  

Training 

– increasing staff awareness through on-the-job and refresher training, presentation of examples of potentially non-conforming counterfeit parts, fraudulent activities. 

Production process 

– control of the product purchased supplied from external sources, in particular by verifying the documentation received with the delivery in terms of its correctness, paying attention to: 

• authenticity and completeness of the documentation required by the order, 

• legibility of records, stamps,  

• unauthorized corrections made, 

• annotations made, 

• verification of labeling of delivered materials 

– monitoring the obsolescence of parts by archiving them in the event of a new revision 

– withholding and reporting suspected or detected counterfeit parts – applying quarantine 

– application of the principles of identification and traceability (including serialization of parts if required) 

– inspection of proper use of authority media (AAM) like stamps, signatures, passwords, authorizations 

Testing and prevention 

– applying controls, audits to verify the methods of detecting counterfeit parts 

Post-delivery/after detection activities 

– immediately informing the Customer about the risk of  counterfeit component inclusion in the product sold /fraudulent activity detection 

– cooperation with the client in determining the course of proceedings with a counterfeit product and undertake the investigation to discover the source of counterfeit part 

* All Suppliers  and  Business Partners are obliged to  transfer above  rules  to  theirs sub suppliers  and  business  partners. 

Any violations of the above rules should be reported by employees to their supervisor based on the violations report (appendix no 1) or similar document initiated at supplier/business partner. 

Counterfeit parts or suspected counterfeit parts/ fraudulent activities detections shall be reported to the appropriate government authorities and suppliers, customers, external interested parties f.e certification bodies, Nadcap and other (*if applicable) in order to prevent from spreading and as well to Iwamet in case of direct impact on the business.