Policies

AME Auto Ltd Anti-Counterfeit Policy

1.1     PURPOSE

This policy details AME Auto Ltd’s (AME Auto’s) approach to the prevention and management of counterfeit material in our business and across our supply chain.

1.2      SCOPE

The scope of the policy extends across all supply chain activities within AME Auto, namely supplier selection and purchasing.

1.3     POLICY STATEMENT AND REFERENCES

AME Auto’s Anti-Counterfeit Management Policy complies with the UK MOD Counterfeit Avoidance Policy and DEF STAN 05-135: Avoidance of Counterfeit Materiel, and details our commitment to zero tolerance of counterfeit goods.

Our Anti-Counterfeit Policy has also been updated in line with the Authority provided Counterfeit Avoidance Maturity Model to shape our procedures in line with good practice, and since the update it has been reviewed and approved by AME Auto’s Management Team.

1.4     CONTROLS TO MANAGE RISK

Through the application of our Anti-Counterfeit Management Policy we shall ensure:

  • Purchases are made directly from the Manufacturer or Manufacturer approved sources
  • A management representative is appointed with the responsibility and authority to ensure that risk of counterfeit materiel is managed through the supply chain.
  • If counterfeit materiel is found, this occurrence is reported to the supplier and appropriate authorities, with effective measures implemented to prevent use or supply chain re-entry.
  • Products meet the required specifications set out by our customers.

1.5     ROLES AND RESPONSIBILITIES

Our Managing Director has 33 years’ experience supporting supply services in this sector, and they have formed AME Auto’s Anti-Counterfeit Policy. The Managing Director sits on the executive board of The Society of Motor Manufacturers & Traders (SMMT) and has done so for seven years. As such, they have an extensive knowledge of the threat counterfeit items and materials pose to product performance, reliability and safety. The policy’s implementation shall aim to manage the risk of counterfeit materiel infiltrating the supply chain, and prevent the delivery of such items to the MOD.

The Managing Director is wholly accountable for the policy and its implementation under the Authority’s supply service. He shall remain up-to-date with emerging and current best practice standards, including future guidance published by the Anti-Counterfeiting Forum, containing best practice for OEMs, distributors and component manufacturers.

The Managing Director is supported in their role by our experienced MOD Buyer who has a B.Eng. Hons degree in Engineering and 25 years’ experience within the industry. Our Buyer shall be responsible for the ground level implementation of our policy. They shall have the responsibility and authority within our organisation to:

  • Ensure that the arrangements required to manage the risk of counterfeit materiel in both the supplier organisation and supply chain are implemented and maintained.
  • Report to top management any concerns regarding counterfeit materiel within the supplier organisation and supply chain.
  • Promote awareness of the risk of counterfeit materiel in the supplier organisation and the supply chain.

Our Buyer shall be the Point of Contact for customers and suppliers and meetings shall review each stakeholder’s performance against their application of DEFSTAN 05-135.

1.6     COMPETENCE, TRAINING, AWARENESS & COMMUNICATION

Our procurement team are trained in our Anti-Counterfeit Policy and best practice procedures, ensuring we procure authentic, conforming materiel from reliable sources. Training aligns with DEFSTAN 05-135; it includes understanding the wider impact of counterfeit materiel (safety, performance, and reliability risks), and our control measures and methods to manage risk and avoid counterfeit materiel, including: certifications of conformity, traceability, testing and inspections.

In addition, our warehouse operatives complete Anti-Counterfeit training, enabling them to use measuring tools and conduct informed visual inspections at goods in, identifying suspected materiel before it is stocked. For critical materiel with high safety, performance, and reliability risks, these inspections are heightened, with operatives having access to the required customer specifications, including manufacturers drawings. Suitably Qualified and Experienced Personnel (SQEP) shall then inspect the part against the specification, using appropriate measuring tools. These tools include (but are not limited to): Dial Indicators, Digital Measuring Tools, Angle Finders, Gauges, Edge and Centre Finders, and weighing scales.

To further ensure counterfeit materiel does not re-enter the supply chain, occurrences of counterfeit materiel are communicated to:

  1. The Customer.
  2. Supplier of the Materiel.
  3. The owner of the Intellectual Property Rights of the genuine materiel (where possible).
  4. Appropriate information / data gathering organisations including, but not limited to:
    1. The Society of Motor Manufacturers and Traders (SMMT).
    1. Anti-Counterfeiting Forum.
    1. National Law Enforcement Authorities (Police and Trading Standards).

1.7     REFERENCES

For further information please see:

David Smith

Managing Director

October 2021

Environmental Policy

This Policy Statement outlines my endorsement and approach to environmental management within
AME Auto Ltd and intends to communicate to all personnel. At AME Auto we regard environmental issues to be especially important and we shall aim to limit the
environmental impact which our business has, wherever feasibly possible.
For regulatory as well as corporate social responsibility reasons, we shall commit to environmental
protection and prevention of pollution and shall fulfil our applicable legal/compliance obligations.
We shall endeavour to operate in a sustainable manner, achieving our business objectives, without
compromising the ability of future generations to meet their own needs. A key aspect of sustainability is
for all organisations, including ourselves, not to consume natural resources and produce waste/pollutants
at a level that will have a significant future effect on the environment.
Awareness of the aspects of our own operations that can have an impact on the environment shall be
maintained (eg; use of electricity, sustainable purchasing choices, waste production, etc). We shall also
endeavour to influence others outside of our organisation, especially if there is opportunity within
services provided for substitution to less environmentally damaging options.
Considering our significant environmental aspects and the principles laid out by this environmental policy
statement, through our management processes we define and monitor environmental objectives and
targets, against which continual improvement can be demonstrated.
I have prepared this statement as my commitment to environmental management at AME Auto. This
message shall be communicated and understood throughout the company and I expect that all persons
carrying out work upon our behalf, share these values.
This policy statement shall be made available to the public, upon request and subject to annual review to
ensure its continued suitability.

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