GENTEX Direct Supplier Manual User Manual

GENTEX Direct Supplier

Product Information

Specifications

• Product Name: Direct Supplier Manual – Master
• Publication Date: April 2023
• Number of Pages: 12

Preface

Gentex Corporation is a world-class manufacturer that aims to be a smarter organization. Their mission is to provide superior products and services through continuous improvement and innovation. Gentex prioritizes customer satisfaction and believes in operating sustainably, adhering to environmental, social, and governmental best practices.

Gentex Corporate Philosophy
Gentex’s corporate philosophy revolves around continuous improvement, innovation, and a commitment to quality. They believe that every aspect of the business should participate in the process of continuous improvement. Incremental improvements are made to enhance customer value over the product’s lifespan.

Supplier Sustainability Expectations
Gentex places importance on social responsibility and incorporates environmental, social, and corporate governance issues into its decision- making processes. They operate by applicable laws and seek adherence to international human rights conventions, including the prevention of child labor, forced labor, and human trafficking. Suppliers will be required to complete sustainability assessments. Gentex also encourages suppliers to adhere to the United Nations Global Compact Principles, which include defending human rights, implementing protective labor policies, practicing environmental responsibility, and anti-corruption measures.

Product Usage Instructions

Step 1: Acknowledgement of Receipt
Before using the Direct Supplier Manual, suppliers must complete the Acknowledgement of Receipt form. This form confirms that they have received the manual, understand their obligations and requirements, and agree to abide by them. The form includes fields for supplier information, contacts, and a signature.

Instructions:

1. Fill in the Supplier Name, Business Address, and Contacts sections.
2. Provide the name, phone number, and email address of the Manufacturer Representative for both Inside Sales and Outside Sales.
3. Print your name and sign the form to acknowledge receipt of the manual.
4. Date the form with the current date.
5. Submit a copy of the completed form to [email protected].

Step 2: Reading and Understanding the Manual
It is essential to thoroughly read and understand the Direct Supplier Manual before engaging in any business transactions with Gentex Corporation. The manual contains important information about obligations, requirements, and duties that suppliers must adhere to.

Instructions:

1. Review each section of the manual carefully.
2. Take note of any obligations, requirements, or duties specified.
3. Ensure a clear understanding of all the terms and conditions mentioned.

Step 3: Compliance and Implementation
Once suppliers have read and understood the Direct Supplier Manual, they must comply with all the obligations, requirements, and duties outlined in the manual. This includes following Gentex Corporation’s Terms & Conditions and maintaining a strong commitment to quality and continuous improvement.

Instructions:

1. Refer to the manual whenever engaging in business transactions with Gentex Corporation.
2. Adhere to all specified obligations, requirements, and duties.
3. Maintain compliance with Gentex Corporation’s Terms & Conditions.
4. Continuously strive for quality improvement in products and services.

FAQ

• Q: What is the purpose of the Direct Supplier Manual?
  A: The Direct Supplier Manual provides suppliers with information about their obligations, requirements, and duties when conducting business with Gentex Corporation. It serves as a guide to ensure a mutually beneficial and successful relationship between the supplier and Gentex Corporation.

• Q: What should I do if I have questions or need clarification about the manual?
  A: If you have any questions or need clarification regarding the Direct Supplier Manual, contact the Manufacturer Representative for Inside Sales or Outside Sales. They are available to provide assistance and address any concerns you may have.

• Q: How often is the Direct Supplier Manual updated?
  A: The Direct Supplier Manual is subject to updates and amendments as necessary. Suppliers are encouraged to regularly check for updates on Gentex Corporation’s website or through official communication channels to ensure they have the most up-to-date version of the manual.

Direct Supplier Manual Acknowledgement of Receipt

I / we have received the Gentex Corporation Supplier Manual and certify that we have read and understand all obligations, requirements, and duties as amended, and agree that they, along with the Gentex Corporation Terms & Conditions, are binding on our relationship and transactions with Gentex Corporation.
The undersigned by their signature represents and warrants that he/she has authority to execute this agreement as the binding obligation of his/her employer.

Contacts:

Please complete and return a copy of this form only to [email protected].

Preface

Gentex Corporation (“Gentex”) has developed this manual to give guidance and direction to all our suppliers and their affiliated companies. Supplier, on behalf of itself and its affiliated companies, agrees to comply with all provisions and terms referenced in this manual. This manual is utilized by Gentex personnel to promote equality in the way we work with suppliers. We believe it is imperative that all suppliers to Gentex are treated equitably and that each supplier understands what is expected of them prior to producing products or contracting work with Gentex.

Gentex Corporate Philosophy

• Gentex’s stated mission is to be a smarter organization; a world-class manufacturer with superior products and services driven by a supportive work culture that encourages people to innovate, excel, and continually improve every aspect of the business.
• Our goal is to maximize customer satisfaction. Gentex believes this can best be achieved through an unwavering commitment to quality that is fueled by sustained continuous improvement. Gentex’s long-term prosperity is ensured only when product value, service, and customer responsiveness are continually enhanced. Consequently, no part of the organization is immune from participating in the never-ending process of continuous improvement.
• Innovation is a Gentex hallmark. Incremental improvements ensure that each development continues to enhance customer value over the life of the product.
• Gentex’s priority is to operate in a sustainable manner committed to environmental, social, and governmental/legal best practices.
• Gentex understands suppliers play an integral part in maximizing our customers’ satisfaction. Gentex believes that through open lines of communication with the entire supply chain, we can maximize the quality of the product while maintaining excellent delivery, cost, and unparalleled service to our final customer.

Supplier Sustainability Expectations

• At Gentex, social responsibility has been the focus of our business from the start. From aerospace products to fire protection warning devices to automotive products and features that protect drivers and their passengers as well as pedestrians from road hazards, Gentex has always been in the business of safety.
• In alignment with our Board of Directors, Gentex incorporates environmental, social, and corporate governance issues into our decision-making processes and our business policies, operating under all applicable laws and seeking adherence with international human rights conventions in defiance of child labor, forced labor, and human trafficking. To evaluate suppliers fairly, the Company will begin requiring completion of sustainability assessments.
• Suppliers are encouraged to review our corporate sustainability report http://www.gentex.com/corporate/sustainability. which we update as our programs continually improve, to align the policies and practices that guide our environmental, social, and corporate governance requirements and industrial best practices. Suppliers are encouraged to use recycled and/or sustainable materials whenever possible. Commitments to carbon neutrality that align with Gentex will become required by all suppliers as we must work together to achieve this goal.
• Furthermore, we expect our suppliers to join us in striving to adhere to the United Nations Global Compact Principles, including the defense of human rights, the implementation of protective labor policies, environmental responsibility, and anti-corruption practices. For more information, please review www.unglobalcompact.org/AboutTheGC/TheTenPrinciples/index.html.
• Additional supplier expectations related to matters of corporate sustainability are located throughout this document. Please review them carefully

Gentex Visitor Policy

Due to the proprietary nature of the business, Gentex has established policies and procedures that all visitors agree to follow as a condition of access to Gentex premises. Visitors must comply with all check-in and check-out procedures established for the facility they are visiting. All visitors must register and display a valid visitor identification badge when entering all internal areas, and any other area designated as badge-only. Visitors agree to maintain strict confidentiality of all Gentex proprietary information, remain with their designated Gentex sponsor at all times, and are prohibited from using cameras or any other photographic/video devices while on the premises.

Gentex Environmental Commitment

Gentex Corporation places a high priority on conducting its business in a sustainable manner that places the least practical burden on the environment while protecting the health and safety of our team members and partners.
Gentex has been working toward this vision since 1999, when we began the establishment of an environmental management system based on the ISO 14001 international environmental management standard. ISO14001 outlines a structured management system to achieve and demonstrate sound environmental performance by controlling the impact that our activities, products or services have on the environment.
As our partner, it is important to us that you understand your role in helping us achieve this vision. Toward that end, Gentex has prepared an Environmental Policy that establishes the foundation for our environmental management system that communicates your responsibilities as a Gentex partner.
Gentex requires all suppliers when submitting the Production Part Approval Process (“PPAP”) for production material to declare that the product submitted does not contain any materials defined on the Global Automatic Declarable Substance List. A listing of hazardous materials can be found at www.gadsl.org.

Supplier Relations

Gentex Corporation supports Best-in-Class supplier relations in meeting our needs and the needs of our customers. The focus of Best-in-Class is to work with leaders in the industry that are the most competitive in cost, quality, service and technology. Best-in-Class is characterized by objective cost targets, long-term commitments, and continual open communication between Gentex and the supplier.

Supplier Responsibilities

• The supplier will work with Gentex to support Gentex’s sustainability initiatives and to apply sustainability initiatives in the supplier’s operations as defined in the Gentex Sustainability Update report.

• The supplier will maintain Gentex confidentiality and sign a non-disclosure agreement.

• The supplier will not allow registrations to be filed on any component, especially electronics-related, that are discussed with Gentex. This would include requests for pricing, sampling and/or production components.

• Supplier will be third party registered to all necessary Quality System Specifications which may include, but not limited to:

  • ISO-9001:2015
  • IATF 16949:2016
  • VDA 6.1:2010
  • ISO-IEC 17025:2015
  • AS9100D

• If the supplier is not currently certified to IATF 16949:2016, then they are expected to show evidence of working toward certification per IATF 16949:2016 requirement 8.4.2.3 and must identify their current quality system state in the Gentex Supplier Assessment form as applicable.

• Gentex reserves the right to audit the supplier’s quality system at any time on-site at the supplier’s manufacturing, sales, technical, or distribution location upon twenty-four (24) hour notice.

• The supplier will inform Purchasing of all activities that may affect the total product quality, delivery and cost.

• Supplier will inform Purchasing of changes in economic or other conditions that might affect purchasing decisions.

• Supplier will notify Quality and Purchasing of any issues that relate to the ability to produce acceptable quality material within the pre-determined delivery window. Examples include unqualified processes, capacity issues, process issues, raw material availability, etc.

• The supplier will notify Quality and Purchasing of any issues that relate to the ability to produce acceptable quality material which may have been sent to Gentex or is in transit to Gentex.

• Supplier will negotiate purchasing agreements and all sales only with the Purchasing Department or other persons with delegated purchasing authority.

• The supplier will conduct negotiations ethically, without attempts to influence through offering valuable personal gifts or entertainment.

• The supplier will make available all technical, engineering, systems, policies, services, and other support to improve Gentex’s present or future use of the supplier’s products or services.

• Supplier agrees that the Gentex Corporation Terms & Conditions apply to the purchase of all products and services delivered by Supplier.

• Supplier will utilize the AIAG-approved Production Part Approval Process and execute this process as directed by Quality.

• The supplier will provide products and/or services per customer-specific requirements as communicated through prints, Gerber files, specifications, or any other written correspondence provided by Gentex purchasing, engineering, or quality team members.

• The supplier will maintain appropriate documentation and record retention to provide evidence that necessary measures are being taken and regularly reviewed by the supplier to ensure compliance with SC and CC characteristics as called out on Gentex prints and following AIAG requirements. SC and CC characteristics will be defined on Gentex prints and will be identified in the following ways:
  Critical Characteristic (Regulatory Requirement) – this item could potentially impact the safety of the end item.
  Special Characteristic (Product or Process Requirement) – this item is critical to the form, fit or function of the end item.

• The supplier will provide material certifications that demonstrate compliance with all performance specifications.

• The supplier will require its sub-tier suppliers to comply with ISO 9001:2015 record retention requirements (AS9100D).

• The supplier will package to protect the product during shipment and maintain the integrity of the product during storage.

• The supplier will label the product per Gentex labeling instructions.

• Software-specific suppliers to Gentex will meet minimum process, documentation, and quality specifications as deemed necessary by Gentex leadership and/or the software development team. Standards that software suppliers may be held to include but are not limited to: SPICE, SQI 2004, ISO/IEC 12207, CMMI, or others as requested by Gentex through project-specific requests. The software standard(s) that a supplier will be held to will vary by project or program and will be communicated to the potential supplier by purchasing leadership, or a software team member and agreed upon in writing before award of business.

• Supplier will work with Gentex to develop the means for annual cost reduction goals.

• Supplier is expected to maintain 100% on-time delivery.

• The supplier is expected to maintain a PPM of zero.

• The supplier will be responsible for complying with all international customs regulations. U.S. Customs requires 100% accurate shipments. In the case of over or under-shipments versus the shipping documentation, Gentex will notify Customs and make the appropriate adjustments with Customs and the supplier. If you invoice Gentex in a foreign
  currency, Gentex will remit payment at the rate of exchange at the time of payment.

• The supplier will provide proof of liability insurance to the Gentex Director of Corporate Facilities before providing contractual work at a Gentex facility.

• The supplier will declare any hazardous materials that are provided to Gentex. A list of these materials can be found at
  www.gadsl.org.

• The supplier will respond with accurate and timely information to solicitations regarding supply chain touch points, C-TPAT assessments, supply risks, use of conflict minerals, country of origin information and other relevant supply inquiries.

• Supplier is expected to use and/or implement any software systems and processes requested by Gentex regarding Gentex orders. If Supplier fails to use said systems, then Supplier assumes all risks, and shall further indemnify and hold Gentex harmless from all errors, omissions, delays, liabilities, and other damages that may result from Supplier’s use of non-acceptable channels. Gentex’s receipt of, or response to, information submitted through non-acceptable channels shall not relieve the Supplier of its obligations herein

Supplier Diversity

Gentex is an equal-opportunity employer. Gentex is committed to diversity in all aspects of its business, including Gentex’s diversity, equality, and inclusion initiatives. Our commitment is to maximize their participation through the development of mutually beneficial business relationships, which will ensure that quality materials and services are provided to the corporation in a timely and cost-effective manner.
Gentex, at its discretion, will develop mentoring relationships with key diverse suppliers to help develop business systems and encourage them with new technologies and future growth. We understand that the commitment to these businesses not only benefits the supplier, but it also benefits the greater business community.

Gentex Ethics Statement

• Gentex employees will avoid the intent and appearance of unethical or compromising practices in relationships, actions, and communications.

• Gentex employees will refrain from any private business or professional activity that would create a conflict between personal interests and the interests of Gentex.

• Gentex employees will refrain from soliciting or accepting money, loans, credits, or prejudicial discounts, and the
  acceptance of gifts, entertainment, favors, or services from present or potential suppliers that might influence, or appear to influence, Gentex Purchasing decisions. All such actions are strictly prohibited. Gentex employees will promote positive supplier relationships through courtesy and impartiality in all phases of the purchasing cycle.

• Gentex employees, directors, and officers will abide by the Gentex Corporation Code of Business Conduct and Ethics adopted by the Board of Directors on February 26, 2004, and located on the Gentex website at www.gentex.com/Code-of-Ethics.pdf

• Suppliers shall comply with the above requirements or their adopted requirements which are substantially similar to those herein.

Gentex PCN Notification Requirements – Components

Scope
This document details the requirements for notification of a product or process change by a supplier to Gentex Corporation. A change shall be considered anything impacting the availability, quality, material, performance, reliability, manufacturing location, manufacturability, or any other component characteristic deemed critical to use in Gentex’s end product. The requirements listed below apply to components that have been granted PPAP approval by Gentex.

Definitions

• End of life (EOL) – any discontinuation of a product
• Major Change – Form, Fit, or Function impacted
  • Examples: die layout, wafer fab process
• Minor Change – No impact to Form, Fit, or Function
  • Examples: Site relocation, bond wire material, mold compound
• Indirect Change – Changes that do not impact the part directly.
  • Shipping packaging materials, tape orientation, label update
• AEC Qualification – Qualification by the change qualification section of the applicable Automotive Electronics Council (AEC) specification.
• Material Comparison – An A to B comparison of the proposed and current material.
• Characterization Report – An A to B characterization comparison of the pre and post-change product.
• SAT Analysis – An A to B scanning acoustic tomography (SAT) comparison of the pre and post-change product.
• Counterfeit Parts – Counterfeit material that has been confirmed to be a copy, imitation or substitute that has been represented, identified, or marked as genuine, and/or altered by a source without legal right with intent to mislead, deceive or defraud

Requirements

• Throughout the pre-production, production, and service life of any product, the Supplier shall ensure the integrity of the product provided to Gentex. Supplier shall take all necessary measures to ensure materials and/or products supplied to Gentex have been procured or manufactured through the appropriate means, tested, validated, and documented as such to comply with all applicable standards. Supplier shall notify Gentex’s Vice President of Quality in writing immediately if any product that has shipped to Gentex is suspected of being counterfeit or containing counterfeit materials. Appropriate actions to resolve any such concern will be determined by Gentex based on the severity of the concern.
• Gentex expects that all plastic injection molding suppliers shall provide components that meet or exceed SPI commercial molding tolerances or an equivalent. In instances where specified tolerances cannot be met, it is the responsibility of the Supplier to notify Gentex engineering and supplier quality.
• After PPAP approval has been granted by Gentex, suppliers shall notify Gentex of changes via email.
• All product or process changes shall be sent to [email protected].
• Supplier shall not make any changes without complying with the minimum requirements specified in the table below and the Gentex Corporation Terms and Conditions unless other specific written agreements have been executed with Gentex.

After Gentex has completed a review of the proposed changes, additional items may be required prior to change approval. EOL notifications must be sent at least 1 year prior to the planned LTB (last time buy) date.

Timing and data requirements

| Major| Minor| Indirect
Minimum notification (Months)| 12| 9| 6
Material Comparison| •| •|
Characterization Report| •| •|
AEC Qualification| •| •|
SAT Analysis1| •| •|
Product Samples| •| •|

1. Material changes only.

Non-Conformances
Gentex may create a non-conformance (NC) notification when supplier-provided material or components are suspect and need to be quarantined. The NC notification will be sent with a red, yellow, or green response level – see below. Gentex will determine if the product is defective. Material and components are defective when:

• Material is out of specification
• Material is packaged improperly
• Material is labeled improperly
• Material has exceeded the predetermined shelf life
• Material does not meet form, fit, function, or appearance intent
• Material is damaged upon receipt at Gentex
• Material deviates from approved PPAP submission
• Material arrives with improper documentation from offshore suppliers – This includes a .pdf of the following: Packing list, Bill of Lading, and Invoice.
• Material does not meet design intent

1. When defective material is found, Gentex reserves the right to apply financial ramifications.
2. When defective material is found, if Gentex production schedules and material availability do not allow, Gentex will not allow the supplier to replace suspect material or sort on site. Gentex will complete the sort or rework operation at a cost to the supplier of $50/man-hour, plus any additional expense incurred due to the sort or rework. These expenses could include but are not limited to, additional component damage, increased cycle time, downtime, or expedited freight costs during the sort or rework operation. If suspect parts do not fall into the previously defined categories, a joint meeting will be held with Gentex Supplier Quality, the Gentex Buyer, and the supplier to determine proper PPM and financial ramifications.
3. When material does not meet specification, packaging requirements, or design intent, Gentex requires the supplier to follow the 8D process and provide corrective action(s). The NC notification will provide specific due dates for initial containment response and root cause/permanent corrective action. An initial response is typically required within 1 day. All 8D reports must be submitted to the requestor. If Gentex does not receive the initial response and short-term corrective action/containment within the specified time, Gentex has the option of initiating a third-party sort of all incoming suspect material. These costs will be billed to the supplier by the third-party sorting company. The containment will be lifted only after the short-term corrective action and containment plans have been submitted and accepted by Gentex, and Gentex is receiving certified material.
4. Similarly, if the final corrective action is not submitted by the ‘problem-solving response due date’ listed in the NC notification, Gentex has the option to initiate third-party sort and bill the supplier until the corrective action(s) has been submitted and approved. When necessary, suppliers may file for extensions to corrective action deadlines with Gentex Supplier Quality. If the supplier has issues or concerns with the NC notification, the designated Gentex supplier quality engineer should be contacted.
5. All corrective actions shall include any updated documentation such as control plans, FMEAs, work instructions, process flow diagrams or any documents specified in the 8D. Include pictures of corrective action evidence if applicable. Typical containment activities include 100% sorting and rework activities. When containment activities occur, all products flowing into Gentex must be marked with a 2” x 2” or larger green label. The label must state “100% CERTIFIED PRODUCT. INITIAL _, DATE , NC# .” The label must be placed next to the shipping label and it must be visible and easily readable. This label must be applied to the finished product until the NC and appropriate corrective actions are closed.

Gentex Corrective Action Report

• A template for 8D is included with each NC notification and may be used to document the steps taken to address the NC. The supplier may use their own 8D document if the required information is included.
• D3 should list containment actions. These must be in place to ensure that products in transit, at Gentex, and at the supplier’s facility will meet the quality criteria. D4 should describe the root cause(s) of occurrence and detection causing the defective material. D5 should define permanent corrective action(s) that will be put in place to ensure the problem and root cause(s) are addressed. D6 should describe the plan to implement and execute the items listed in D5. D7 should describe the preventative action(s) that have been implemented in the process, procedures, or systems to prevent recurrence. D8 should list the peripheral items that D6 and D7 should and will also be applied to. Any questions regarding the corrective action report should be directed to the designated Gentex supplier quality engineer.

International Shipping Requirements

International Contracts – Minimum Requirements
Contracts and the Packaging, Labeling, and Shipping Manual (located at: http://www.gentex.com/corporate/supplier-information/supplier documents for international trade are essential documents that outline Gentex’s responsibilities and obligations to our customers and our customer’s obligations to Gentex. These documents are part of our record-keeping responsibilities and may be reviewed by U.S. Customs in an audit.
When shipping product internationally there are different requirements and considerations than when shipping product domestically. Often, there is not only a contract that has been approved by our legal group but rather two or three key documents that outline our agreements with foreign suppliers. These documents may include commercial invoices, emails, purchase orders, etc.
The quote and the commercial invoice must outline all the key information necessary to the transaction. Key requirements include the following:

• The quote and commercial invoice should include, at a minimum:
  • Full description of the merchandise (“spare parts” is not acceptable)
  • Quantity and quality
  • Warranty provisions
  • Price
  • International Commercial Terms
  • Sold-to and ship-to party, if they are not the same.
• List the currency in which Gentex is to pay. Many countries including Canada and Australia use the dollar sign, therefore, to avoid risk, indicate “USD” in front of the dollar sign to confirm Gentex is making payment in U.S. dollars.
• Indicate the Incoterm 2020 on the commercial invoice. The Incoterm 2020 and named place noted on the Gentex purchase order must be used. Any deviations from the noted Incoterm or named place must be requested and approved by Gentex personnel in advance of the shipment’s departure. For more information on Incoterms, consult the Incoterms 2020 book available from the International Chamber of Commerce, or contact Gentex Supply Chain Management.
• Include information on legal documents required for international trade. Many products and/or countries have different documentation requirements and they should be reviewed to ensure freight is not held in Customs for needed information.
• Include a termination date on any quotes; international trade contracts do not expire unless a date is clearly indicated

Gentex makes every effort to comply with all import and export regulations. If you have any questions on the information required for shipments, please contact the Gentex Supply Chain Management Department at 616-772-1800.
Upon shipment of product to Gentex, all international suppliers must send a pre-alert to the responsible Gentex Buyer or Material Planner.

Commercial Invoice

Requirements
A commercial invoice must be produced for each entry submitted to U.S. Customs, and must meet the following general conditions:

• Documents must be in English

• List the full legal name and address of the company (or person if not a company) selling the goods. Avoid abbreviations.

• List “Sold to” and “Ship to” parties

• A detailed description of the merchandise. Include common nouns and adjectives in the description to aid in HTS classification verification.

• List the value of the merchandise and type of currency

• Purchase order number, purchase order line number, and purchase order shipment number (as specified on purchase order)

• List quantity and weight

• Country of origin of merchandise

• Country of export, if different from country of origin

• Itemized separately, if applicable:

  • Rebates or discounts
  • Freight and insurance
  • Commissions
  • Cost of packing
  • Addition to Value/Assist Declaration

• When multiple invoices are included in a shipment, number the bottom of each page of the invoice beginning with invoice 1. If an invoice consists of multiple pages, number the bottom of each page beginning with page 1. If the shipment contains multiple invoices with multiple pages per invoice, number the bottom of each page with the number of invoices and the page number of the invoice. For example, if a shipment covers one invoice with one page and a second invoice with 2 pages, the numbering shall be as follows:
  inv. 1 page 1
  inv. 2 page 2
  inv. 2 page 3

• List the name of a responsible person from the exporting company with knowledge of the transaction

Instructions
Coordination between Gentex Buyers and suppliers will ensure that all information required on the commercial invoice will be available from the time the order is placed until documents are received in-house at Gentex. In addition, all parties involved must communicate any changes to the commercial invoice that impacts the information to be submitted to U.S. Customs.

Consequences
Accurate and detailed information on the commercial invoice allows an importer to properly classify and value imported merchandise. Incorrect information may result in an incorrect duty rate or improperly valued merchandise resulting in delays in delivery and possible penalties.

Regulation of Wood Packing Material

• All wood packing material (WPM) must comply with the International Standards for Phytosanitary Measures (ISPM) Regulation of Wood Packaging Material in International Trade. The purpose of the regulation is to significantly reduce the risk of introduction and spread of most quarantine pests that may be associated with wood packing materials.
• Regulated WPM includes but not limited to wood crates, boxes, packing cases, dunnage, pallets, cable drums, and spools/reels.
• ISPM-15 lists exceptions including WPM made entirely from thin wood (6mm or less in thickness) or made wholly of processed wood material such as plywood, particle board, oriented strand board or veneer that has been created using glue, heat or pressure, or combination thereof.
• The WPM must display a visible, legible, and permanent mark certifying treatment. The mark must be approved under ISPM-15 to indicate that the article has been subjected to an approved measure.
• If the WPMs used in a shipment are found to be non-compliant with these requirements and monetary penalties are assessed, Gentex will seek recoupment of all said monetary penalties.

Supplier Contents Reporting

• Gentex’s valued customers require us to submit certificates of origin to take advantage of preferential duty programs. When Gentex provides this information, we are legally required to maintain documentation regarding the material (harmonized tariff classification and country of origin) used to make Gentex products.
• In order to maintain that data, Gentex will send its production material suppliers solicitation requests regularly. These requests may include any of the following: NAFTA Certificate of Origin, American Automotive Labeling Act Report, Manufacturer’s Affidavit, Certificate of Origin, or Traced Value Reporting.
• As a Gentex supplier, you must respond and provide the appropriate information. Failure to do so will impact your supplier performance rating.

Transportation Security Administration (TSA)
Beginning on December 3, 2012, TSA mandates all U.S. inbound cargo on passenger flights will need to be 100% screened. This is a result of the 9/11 Commission Act signed by President George Bush. This 100% screening rule is based on the piece level of the shipment. Suppliers are obliged to pack the goods for a long journey utilizing master cartons.

Customs-Trade Partnership Against Terrorism (C-TPAT)

• C-TPAT is a partnership program between US Customs and Border Protection (CBP) and the trade community to strengthen border security and international supply chains. Gentex partners including customs brokers, freight forwarders, and international suppliers are strongly encouraged to become members of C-TPAT (or another credible and/or mutually recognized security program), but at a minimum must comply with the security measures outlined in C-TPAT. A complete summary of this information is available at https://www.cbp.gov/border-security/ports-entry/cargo-security/ctpat.
• C-TPAT’s security criteria categories are Security Vision & Responsibility, Risk Assessment, Business Partner Security, Cybersecurity, Conveyance Security, Seal Security, Procedural Security, Procedural Security, Agricultural Security, Physical Access Controls, Physical Security, Personnel Security and Training & Awareness.
• Gentex partners will be required to complete C-TPAT membership and knowledge declarations and C-TPAT self-assessments regularly. In addition, Gentex or approved third parties may perform on-site C-TPAT audits at business partner locations.

Substance of Concern (SoC) Management Standard
The supplier will work with Gentex stakeholders to ensure all supplier products comply with the substance of concern standards, laws, and regulations. This internal standard is located at: http://www.gentex.com/corporate/sustainability.

Conflict Minerals Reporting Requirements
Conflict Minerals are known as the “3TG” regardless of their origin and are defined as:

• Columbite-tantalite (also known as Coltan): The ore from which Tantalum (Ta) is extracted
• Cassiterite: The ore that is the most common source of Tin (Sn)
• Wolframite: The ore from which Tungsten (W) is extracted
• Gold (Au)
• Other minerals may be added by the Secretary of State

The exploitation and trade of conflict minerals originating in the Democratic Republic of the Congo (DRC) or adjoining countries (collectively called the “Covered Countries”) has been used to finance violence and human rights abuse. The United States conflict minerals reporting requirement is an effort to ensure that required companies are exercising reasonable inquiry and due diligence within their supply chains to ensure that financial support is not being funneled to these conflicts. Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act requires issuers to annually disclose whether any conflict minerals necessary for the functionality of a product or necessary for the production of a product have originated in the Covered Countries. If any conflict minerals originated in those countries, the issuers are required to submit a “Conflict Minerals Report” that includes a description of the measures taken to exercise due diligence on the conflict minerals’ source and chain of custody. Gentex and our customers are required to provide the annual disclosure. Suppliers shall comply with Gentex’s reasonable country of origin inquiries requesting conflict mineral information. Suppliers are required to cascade conflict minerals inquiries to the previous level/tier in the supply chain, back to the smelter, and report back to Gentex, the required information regarding conflict minerals. Suppliers must focus on obtaining and reporting complete and accurate information from all previous tiers in the supply chain. Suppliers are expected to undertake due diligence within their supply chains and are strongly encouraged to provide only 3TG-containing products to Gentex, where the 3TG was sourced from smelters and refiners conformant with the Responsible Minerals Assurance Process (RMAP) assessment protocols. Gentex’s Conflict Minerals Policy is located at: http://www.gentex.com/corporate/sustainability.

Assistant General Counsel

Joe Matthews – Vice

President Purchasing

002| July 10, 2019| Added QMS levels and QMS standard revisions, CC & SC requirements, Software requirements, Environmental Commitment Supplier Responsibilities section; Added Counterfeit Parts definition and requirements to Gentex PCN Notification Requirements – Electronic components Responsibilities section; Added Regulation of Wood Packing Material to International Shipping Requirements; Updated C-TPAT section; Removed Cargo Security Requirements for Shipping to the United States; Updated Conflict Minerals section. Added Substance of Concern

Section; Added Revision Summary.

| Scott Ryan – General Counsel

Joe Matthews – Vice President Purchasing

003| February 18, 2020| Changed PCN Notification Requirements section to include all components and not just electronics. Removed the words all from the C-TPAT section referring to Gentex partners.| Scott Ryan – General Counsel

Joe Matthews – Vice

President Purchasing

004| September 2021| Clarified affiliate language, made Supplier Relations and Supplier Responsibilities their own section, added software systems requirements language, and added SPI commercial molding

tolerances language for plastic injection molding suppliers.

| Scott Ryan – General Counsel

Joe Matthews – Vice

President Purchasing

005| April 2023| Supplier Sustainability Expectations updated, Terms and Conditions language update with link made to acknowledgment form,| Scott Ryan – General Counsel

Randy Pappal – VP

Purchasing & Supply Chain

References

• GADSL | The GADSL is the result of the efforts of a global team from the automotive, automotive parts supplier (tier supplier) and chemical/plastics industries who have organized the Global Automotive Stakeholders Group (GASG).
• Sustainability | Gentex
• The Ten Principles | UN Global Compact

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