Counterfeit Mitigation Program


This document describes counterfeit part risk mitigation procedures and requirements for Jelliff Corporation suppliers. Suppliers are instructed to review this document and contact Jelliff Corporation with any questions. Suppliers must return a signed and dated copy to Jelliff Corporation.

1. Scope

This document applies to Jelliff Corporation suppliers and their respective sub suppliers.

3. Definitions

3.1. Suspect Part – A part in which there is an indication by visual inspection, testing, or other information indicating the item may have been misrepresented by the Supplier or Manufacturer and may in turn meet the definition of a Counterfeit Part.

3.2. Counterfeit Part – A part identified as a copy or substitute without the legal right or authority to do so or a part whose material, performance, or characteristics are knowingly misrepresented by a Supplier in the Supply Chain. The Counterfeit Parts include but are not limited to:

3.2.1. Parts not containing the proper internal construction that is consistent with the desired, producer, or ordered part.

3.2.2. Used, refurbished, or reclaimed parts represented as new product.

3.2.3. Parts with a different package style, type, or surface plating / finish than the product ordered.

3.2.4. Parts not successfully completing the full production and / or test flow of the Original Component Manufacturer (OCM) that are represented as completed product.

3.2.5. Parts sold or delivered as upscreened product that have not successfully completed the upscreening process.

3.2.6. Parts sold or delivered with modified labeling or markings intended to misrepresent the form, fit, function, or grade of the intended product.

Note: Parts sold as refinished, upscreened, or uprated and have been identified as such are not considered counterfeit product.

3.3. Original Component Manufacturer (OCM) – An organization that designs and/or engineers a part and has obtained the intellectual property rights to that part.

3.4. Authorized Supplier/Distributor – OCM authorized sources of supply for a specific part that have a contractual agreement to stock, repackage, sell, and distribute OCM product. Authorized distributors normally offer the product for sale with a full OCM flowthrough warranty.

4. Responsibility

Suppliers and their respective sub suppliers are required to comply with the procedures defined in this document.

5. Procedures

5.1. Supplier shall maintain a Counterfeit Part Risk Mitigation Process internally and with its sub-suppliers. Upon request, suppliers shall provide evidence of their Counterfeit Part Risk Mitigation Process to Jelliff Corporation.

5.2. Supplier shall purchase material directly from OCMs or from OCM Authorized Distributors and shall request approval from Jelliff Corporation if material required to satisfy the Jelliff Corporation order cannot be procured from these sources. Supplier shall present complete and compelling support for any request to procure from sources other than OCMs or their Authorized Distributors and include in the request all actions completed to ensure the materials thus procured are not counterfeit.

5.3. Supplier is not authorized to deliver any material procured from sources other than OCMs or OCM Authorized Distributors without submission of the aforementioned request and written authorization from Jelliff Corporation. Upon receipt of authorization from Jelliff Corporation, supplier shall segregate and provide traceability identifiers (i.e. Date Code, Lot Code, Serial number) for all material delivered to Jelliff Corporation that has been procured from sources other than OCMs or OCM Authorized Distributors.

5.4. Supplier shall have preventative controls in place to assure compliance with Procedure 5.2 and 5.3. Evidence of preventative controls must be provided to Jelliff Corporation upon request. Jelliff Corporation may request on site audit/verification as required.

5.5. Supplier shall ensure this procedure is communicated to and enforced with all lower tier suppliers that provide materials in support of any Jelliff Corporation order.

5.6. Upon initial detection of suspect or confirmed counterfeit materials, supplier shall ensure all material is marked, contained, and NOT shipped to Jelliff Corporation. Supplier shall immediately notify Jelliff Corporation if they become aware of or suspect that material delivered in accordance with a Jelliff Corporation purchase is suspect or counterfeit.

On behalf of the below identified business (the “Company”), I certify to Jelliff Corporation

Corporation the Company is in compliance with the Jelliff Corporation “Supplier Counterfeit Material Avoidance Procedure.”

Company Name __________________________ Title _______________________ Signature ____________________________ Date __________________________