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Page 1: Doing Business With - Benteler Automotive Supplier Portal · The Benteler Group is internationally active with its business divisions Automotive, Steel/Tube and Distribution. Since

October 28, 2011 Page 1 of 44

Title Page

Doing Business With

North American Operations

Version Date: October 28, 2011

Page 2: Doing Business With - Benteler Automotive Supplier Portal · The Benteler Group is internationally active with its business divisions Automotive, Steel/Tube and Distribution. Since

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Preface The purpose of this book is to offer information and guidelines to suppliers, henceforth known as “Supplier”, when doing business with Benteler Automotive Corporation, , Benteler Automotive Canada Corporation and Benteler de Mexico S.A. de C.V., henceforth known as “Benteler”. Introduction to Benteler The Benteler Group is internationally active with its business divisions Automotive, Steel/Tube and Distribution. Since its foundation in 1876, four generations of the family have contributed to shaping the Group, which is still in family ownership today. Operating under the Benteler name, the business is not only one of the largest independent automotive suppliers, but also one of the most important steel tube manufacturers in Europe as well as one of the leading stock holders and processors of steel tubes and stainless steel tubes. Benteler employs over 23,000 employees in 38 countries at 150 locations.. Supplier Code of Conduct Benteler’s values and principles of conduct are regarded by us as being important criteria for long-term successful cooperation. We therefore encourage our partners to introduce and implement similar principles as detailed herein. Social Responsibility & Legal Compliance Benteler seeks to be socially responsible. We respect the generally accepted customs of the countries in which we are active. Thus, we demand that our employees, business partners and the society at large operate with the utmost integrity. Particularly, we reject all forms of forced and child labor. We do not support discriminatory practices based on nationality, skin color, gender, age, religion, disability or private lifestyle. Antitrust Law & Competition Law We support fair competition within the confines of the law. Any allocation of territory, customers, or any agreements on prices or exchange of information on prices, delivery conditions or delivery capacity is not permitted. Non-compliance with competition laws will result in loss of business with Benteler. International Trade Benteler will observe all applicable international agreements, national laws and regulations concerning the control of international trade and financial transactions, as well as those relevant doctrines relating to imports and exports. Environmental Protection Protection of natural resources and the environment is an essential part of our daily corporate culture. By involving all of our suppliers in this mission, we seek to promote an environmentally-friendly ethos. The measures we have taken to ensure environmentally-friendly work cover our entire product range and all production processes. We take into account the complete life cycle of our products from the use of raw materials through to development, production and operation up to the point of disposal and recycling. Data Protection We respect the protection of the privacy and confidentiality of business data and company secrets. All our employees are encouraged to keep all matters confidential and to ensure that information is not made available to any third party that are not involved with the issues relating to the program.. . We expect the same protection from our supply base. Relationships with Business Partners Agreements with our business partners are made in a complete, understandable and written form. Suppliers and service providers are selected on a competitive basis only. We conduct all business exclusively in the interest of the Benteler Group and not for any personal or private reasons or motivation. There have been internal procedures implemented to oversee that this is followed. All employees if the Benteler Group, their spouses, and their immediately family members are not permitted to accept or give any gifts or other personal benefits from or to business partners only in exceptional cases.

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During the holiday season, business partners often send or expect gifts. In order to prevent future conflicts, our suppliers, service providers and consultants are being requested, if they wish to show their appreciation, to make a donation to a charitable organization. Exceptions in handling such gifts are only possible, if accepting respectively giving does not infringe any federal/state laws, and if:

• The monetary value of the gifts presented is negligible, • The items concerned show company advertising (such as mugs, calendars and the like)or • A refusal to accept or give is considered as impolite in the particular region or country

However such gifts do not become the property of the employee but have to remain within the corporation. Invitations (e.g. business lunch/dinner, entertainment and events) by or to business partners must be customary to business and serve a business purpose only. They must not be of inadequately high value and should take place within the usual cooperation (i.e. lunch during a meeting or a reception on the completion of an event or project). If it cannot be declined for specific reasons to accept or give gifts (whose monetary value cannot be disregarded), and if they are not violating the current legislation, a solution for these items must be determined in conjunction with the manager. In case of acceptance i.e. donating them to a charitable organization, and in case of giving, the explicit prior approval of the line manager is necessary. In case of doubt any acceptance of gifts or granting of benefits must be approved by the line manager.

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Document Flow Chart

Benteler Supplier Management Process

A 1.0 Requirements tobe a BentelerSupplier

A 3.0 PurchaseDocuments

C 1.0Logistics Agreement

- EDI req.- Barcode labels- Packaging specs

C 1.4Trade datarequirements.

C 1.5Transportation

B 1.1 – 1.3APQP - MS A: Sourcing- MS B: Prototyping- MS C: Design Freeze- MS D: Production

Preparation- MS E: Production

Release

K1 (Business Potential Phase)

K2 (Pre Production Phase) K3 (Production Phase)

New SupplierEvaluation &Approval

SupplierSourcing

SupplierAPQP

SupplierPPAP

SupplierPerformanceVerification

B 4.0Part Re-qualification.

B 5.0Supplier ProcessAudits

B 8.0Supplier PerformanceKPI

B 8.1Focus Supplier

Program

RFQ & e-auction

A 1.2TechnicalReview

A 1.3FeasibilityAssessment

A 2.0Benteler eSourcing portal.

B 1.4PPAP- MS F: PPAP

Approval

Post SOP

A 4.0Invoicing/ Packing Slips

B 2.0Ongoing ProductionQuality

B 3.0Part/ Batch Traceability

B 6.0Change Management

B 7.0Rejected Material

C 1.1SystemRequirements

- EDI req.- Barcode labels

C 1.4Trade DataRequirements

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Table of Contents Title Page ....................................................................................................................................... 1 Preface ............................................................................................................................................ 2 Introduction to Benteler ............................................................................................................... 2 Document Flow Chart................................................................................................................... 4 Table Of Contents ......................................................................................................................... 5 Section A - Purchasing .................................................................................................................. 8

A 1.0 Requirements to be a Benteler Supplier ......................................................................... 8 A 1.1 New Supplier Assessment................................................................................................ 8 A 1.1.1. Supplier Assessment Package...................................................................................... 8

A 1.1.2 MRO, Capital & Tooling Suppliers.......................................................................... 8 A 1.1.3 Supplier Financial Assessment ................................................................................. 8 A 1.1.4 Quality Certification Check ...................................................................................... 8 A 1.1.5 Product Liability and Recall Cost Insurance Requirement for Serial Suppliers... 8

A 1.2 Technical Review ............................................................................................................. 9 A 1.3 Feasibility Sign-Off .......................................................................................................... 9 A 1.4 Step-down PPM targets identified at new sourcing award. .......................................... 9 A 2.0 Benteler eSourcing Portal................................................................................................ 9 A 2.1 eRFQ: Online inquiries.................................................................................................... 9 A 2.2 eAuction: Reverse auctions ............................................................................................. 9 A 2.3 eAuction: Data Exchange................................................................................................ 9 A 2.4 Risk Score Finance ........................................................................................................ 10 A 2.5 Benteler APQP ............................................................................................................... 10 A 3.0 Purchase Documents ..................................................................................................... 10 A 3.1 Purchase Orders ............................................................................................................. 10

A 3.1.1 Information on a Purchase Order........................................................................... 10 A 3.2 Schedule Agreement ...................................................................................................... 10

A 3.2.1 Information on a Schedule Agreement .................................................................. 10 A 4.0 Invoicing / Packing Slip ............................................................................................... 10 A 4.1 Commercial Invoice Requirements .............................................................................. 10

A 4.1.1 Benteler Automotive Canada Corporation and U.S. ............................................. 11 A 4.1.2 Benteler de Mexico, SA de CV ............................................................................... 11

A 4.2 Data Required on a Packing Slip / Delivery Note...................................................... 11 A 4.3 Data Required on a Payment Invoice .......................................................................... 11

A 4.3.1 How to get an invoice to Benteler Accounts Payable........................................... 11 A 4.3.2 Invoice Returned to a Supplier .............................................................................. 12

A 4.4 Banking Instructions ..................................................................................................... 12 A 5.0 Change Management.................................................................................................... 12 A 5.1 Engineering Change Request ...................................................................................... 12 A 5.2 Manufacturing Location Change.................................................................................. 12 A 5.3 Shipping Location Change............................................................................................ 13 A 5.4 Sub-supplier Change...................................................................................................... 13 A 5.5 New or Modified Tooling.............................................................................................. 13 A 6.0 Rejected Material ........................................................................................................... 13 A 6.1 Rejection Notice/Return Material Number Notification – MRO ............................. 13

Section B - Supplier Quality ....................................................................................................... 18

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B 1.0 Advance Quality Planning and Production Part Approval Process ........................... 18 B 1.1 Advance Quality Planning ............................................................................................. 18

B 1.2 Samples for Customer Functional Trial Run and Prototype Components............ 18 B 1.3 Run @ Rate / Capacity Verification......................................................................... 18 B 1.4.1 Supplier IMDS Submission .................................................................................... 19 B 1.4.2 Supplier Deviation Request .................................................................................... 19

B 2.0 Ongoing Production Quality ........................................................................................ 20 B 4.0 Part Re-qualification...................................................................................................... 20 B 5.0 Supplier Process Audit................................................................................................... 20 B 6.0 Change Management .................................................................................................... 20 B 7.0 Rejected Material ........................................................................................................... 20 B 7.1 Quality Incident Management ...................................................................................... 21 B 7.2 Problem Solving Methodology...................................................................................... 21 B 7.3 Incident Financial Report ............................................................................................. 21 B 7.4 Request Suspect Production component Return ........................................................ 21 B 7.5 Incident Dispute Process .............................................................................................. 21 B 8.0 Supplier Performance KPI............................................................................................. 21

Section C - Logistics.................................................................................................................... 27 C 1.0 Logistics Agreement ...................................................................................................... 27 C 1.1 System Requirements..................................................................................................... 27

C 1.1.1 EDI Requirements................................................................................................... 27 C 1.1.2 Barcode Label .......................................................................................................... 27

C 1.2 Packaging Specifications............................................................................................... 27 C 1.2.1 Packaging Instructions / Logistic Data Form...................................................... 27 C 1.2.2 Packaging Design / Development ........................................................................ 27 C 1.2.3 Material Handling ................................................................................................... 28 C 1.2.4 Container Bar Code Labeling and Supplier Identification .................................. 29 C 1.2.5 Shipping Container Classification ......................................................................... 29 C 1.2.6 Packaging Approval Process .................................................................................. 31 C 1.2.7 Packaging Shipment Process ................................................................................. 31 C 1.2.8 Commercial Invoice Requirements ....................................................................... 31 C 1.2.9 Data Required on a Packing Slip / Delivery Note ............................................... 31

C 1.3 Customs Clearance......................................................................................................... 32 C 1.3.1 Shipping to Benteler in Canada.............................................................................. 32 C 1.3.2 Shipping to Benteler de Mexico S.A. de C.V......................................................... 32 C 1.3.3 Shipping to Benteler in the United States ............................................................. 33 C 1.3.4 Shipping FROM Mexico to Benteler US or Canada ............................................ 34 C 1.3.5 Security..................................................................................................................... 34 C 1.3.6 Foreign Trade Zones (FTZ)................................................................................... 34

C 1.4 Trade Data Requirements ............................................................................................. 34 C 1.4.1 North American Free Trade Agreement (NAFTA) .............................................. 35 C 1.4.2 Manufacturer’s Affidavit (MA) ............................................................................... 35 C 1.4.3 Traced Value............................................................................................................ 35

C 1.5 Transportation ................................................................................................................ 35 C 1.5.1 Ground Transportation ........................................................................................... 35 C 1.5.2 Air/Ocean ................................................................................................................ 35

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C 1.5.3 Direct Shipment to Customer................................................................................. 35 C 1.5.4 Expedite ................................................................................................................... 35

C 2.0 Change Management .................................................................................................... 36 C 2.1 Engineering Change Request ....................................................................................... 36

C 2.1.1 Supplier Responsible Packaging ............................................................................ 36 C 2.1.2 Benteler Responsible Packaging ........................................................................... 36

C 2.2 Manufacturing Location Change.................................................................................. 36 C 2.3 Shipping Location Change............................................................................................ 36 C 3.0 Supplier Performance KPI............................................................................................. 37 C 3.1 Supplier Performance Expectations ............................................................................. 37 C 3.2 Logistics.......................................................................................................................... 37

Section D - Appendix Listing ..................................................................................................... 42 Section E - Glossary .................................................................................................................... 43

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Section A - Purchasing A 1.0 Requirements to be a Benteler Supplier A 1.1 New Supplier Assessment In order to complete the Benteler Sourcing Process, new suppliers must complete the Supplier Self-Assessment form (Appendix 01). Each supplier must complete a team evaluation of its business system and production process using this form. Once the assessment is completed, the report should be sent to the designated Benteler buyer for review prior to customer onsite audit. A Benteler SQE will complete an onsite assessment to evaluate new suppliers’ processes for sections contained on the Supplier Self-assessment form. The rating from the supplier submitted version will be revised as required per the audit results. If a supplier’s rating is equal to or higher than 90%, may be considered as an addition to the pool of Benteler Approved Suppliers and listed as such. The supplier is responsible for 100% of the travel cost; however with a rating of 90% or higher 50% of the travel costs will be refunded. A 1.1.1. Supplier Assessment Package This package of documents is used to determine if a serial supplier has established and maintained the necessary financial, manufacturing, quality control, logistic and security capabilities to assure a defect-free product and continuous supply. This package and the internal approval process have been put into place to ensure that the corporate goals and strategies are met through our supplier partnerships. The documents included in this package are: • Appendix 01 Supplier_Self_Assessment Form • Appendix 02 Traceability Compliance Letter • Appendix 03 Quality Assurance Directive • Appendix 04 C-TPAT Security Questionnaire • Appendix 05 EDISurvey • Appendix 06 Trade Data Requirements • Appendix 07 Product Liability and Recall Cost Insurance Obligation • Appendix 08 EDI and Barcode Specifications A 1.1.2 MRO, Capital & Tooling Suppliers These suppliers are requested to complete the first three tabs of the Supplier Self Assessment Form (Appendix 01) and provide documentation of financial stability. A 1.1.3 Supplier Financial Assessment This will be conducted by the Commodity Buyer by means of a D&B Report or other acceptable process. The key figures to be used from the D&B Report will be the Risk Indicator and the 12-Month D&B PAYDEX. A 1.1.4 Quality Certification Check Benteler is requiring production-related suppliers to be ISO/TS16949 certified; however, all suppliers must be certified according to ISO9001, at a minimum. A 1.1.5 Product Liability and Recall Cost Insurance Requirement for Serial Suppliers Due to the ever increasing quality demands and security requirements placed on Benteler by our customers, it has become necessary to request that all Serial Production Component Suppliers obtain and provide proof of appropriate liability insurance with coverage’s of at least 12 MM USD per incident for extended product risks and recall costs.. As an alternative this risk can be covered by the supplier joining the Benteler Insurance Pool. Details regarding this Pool and the rate to be charged to the supplier can be obtained from your Benteler buyer. Being firmly anchored in our framework contract, meeting this requirement is obligatory for all suppliers who wish to do business with Benteler. New suppliers won't be approved without such coverage; already approved suppliers won't receive new business if they fail to obtain coverage.

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A 1.2 Technical Review Suppliers being considered for sourcing of new business will be required to complete a Technical Review Checklist (Appendix 09) which includes the basic agenda to be followed. During this review Benteler will evaluate a supplier’s proposal to meet customer requirements related to quote under consideration. It is recommended suppliers to prepare a presentation with details of the proposal addressing items on Technical Review Checklist. The designated Benteler buyer will inform supplier of the specifics of technical review to be conducted – meeting place, date, time, and participants required. A list of open points will be created from technical review discussion using the PDCA format that is included within the Technical Review Checklist document. All open points from the onsite assessment and technical review need to be addressed to proceed with final sourcing. Any changes to the proposal presented during technical review in terms of capital equipment, production location, timing, tool shop selection, process flow and tool/gage plan must be communicated and agreed to by Benteler Purchasing in writing. A 1.3 Feasibility Sign-Off Supplier’s team will be required to review feasibility of their proposal to meet customer requirements, using the Feasibility Commitment Letter (Appendix 10). Supplier team members including the Quality Manager, Plant Manager and Program Manager needs to sign-off on the feasibility form and return to Benteler to qualify for the Sourcing Process. If the results of the feasibility analysis conclude that the production process is not feasible, sourcing will not proceed. The Benteler Program Team (SQE, Buyer, Product Engineer, Tooling Engineer, and Program Manager) will review and approve the feasibility document. However an approval does not release the supplier from any of its contractual obligation and cannot be considered a waiver by Benteler in regard to any of its rights under the respective contracts. A 1.4 Step-down PPM targets identified at new sourcing award. PPM and incident targets will be given at the award of new business as well as an annual reduction targets for these KPI’s. Please review this data with your Benteler Buyer and SQE. A 2.0 Benteler eSourcing Portal The Benteler eSourcing Portal is a keystone for a globally harmonized, efficient communication with our suppliers. The portal is operated by the service provider Newtron AG (www.newtron.net). There are no special technical requirements for this process other than a computer with a secure internet browser. The portal itself is available in 11 languages and all users can refer to a multilingual hotline-service for support. • Europe: +49 (0)351 43958-538 • North America: + 1 (0)313 91806-12 • South America: +55 (0)353 65411-79 • Asia: +86 (0)21 613238-67 The Benteler eSourcing Portal is offering benefits to many parties involved in the supply chain: • More transparency, less administration and faster response time is achieved through the global standardization of our

purchasing processes. • Less media breaks in the supply chain communication are ensuring clear, flawless and lean information flows. • Secure data transfer is guaranteed through certified data transmission. Benteler cares about the intellectual property

protection of our business partners. • Electronic collaboration saves resources & costs and also helps to protect our environment. A 2.1 eRFQ: Online inquiries The Benteler buyer issues all inquiries online via the eSourcing Portal. Every invited supplier receives an informational e-mail to the address maintained in the account. New suppliers will be trained in how to maintain the supplier account. Suppliers enter the proposed prices into a structured template and transmit the offer online. The Benteler buyer is able to review and compare the offers in the eSourcing Portal. Responses to these RFQ’s are expected to be completed within 14 days. A 2.2 eAuction: Reverse auctions The purchasing tool 'eAuction' is the final step in our sourcing process. This tool is part of the eSourcing Portal and suppliers can obtain information and training from Newtron AG. The auction is based on a previous RFQ and can be seen as final negotiation. The benefits for suppliers are less travel time & costs and a transparent assessment of their competitiveness. A 2.3 eAuction: Data Exchange File sizes up to 100MB can be transmitted quickly and securely.

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A 2.4 Risk Score Finance Benteler requests that our suppliers provide financial data on a quarterly basis within the secure Benteler eSourcing Portal. All data is entered into a structured template. Once data is initially entered, it is only necessary to update changes in data. This will reduce the efforts of the suppliers drastically. The tool helps Benteler to monitor the financial status of the supplier base. A 2.5 Benteler APQP The Advanced Product Quality Planning Process is supported by an easy-to-use online application. Benteler asks standardized questions to the supplier online in order to ensure all necessary information is provided. Attachments like forms, pictures or reports can easily be uploaded. The Benteler Supplier Quality Engineer (SQE) ensures that all of the required data will be provided. The joint target between Benteler and the supplier is Launch Readiness to meet the customers’ requirements. Refer to A 2.0 Benteler eSourcing Portal for additional information. A 3.0 Purchase Documents Within Benteler, purchasing personnel acting in line with internal signature policies are the only individuals who are authorized to commit company funds for the acquisition of a product or service. This acquisition is done through the use of Purchase Orders for MRO, Capital, and Tooling purchases. Serial production component acquisitions are done through the use of a Schedule Agreement and Material Release Requirements. These requirements are sent by the Material Planners located at the Benteler facilities. Additional contractual documents may be used as needed. A 3.1 Purchase Orders Purchase Orders are issued for the purchase of specific items, at a specific quantity, price, and delivery date. The buyer sends the purchase order to the supplier, along with the confirmation page for signature. The supplier, by signing the confirmation page and returning it to the buyer, commits to supplying the items listed in accordance with the conditions stipulated in the order and, as referenced, Benteler’s Standard Terms and Conditions. Purchase Orders are used for, including, but not limited to, the following: • MRO requirements • Services • Capital Equipment • Prototype requirements • Tooling A 3.1.1 Information on a Purchase Order Refer to Appendix 22 for this information.

A 3.2 Schedule Agreement Schedule Agreements define the specific production components being purchased from a specific supplier at a specific price and time frame. This Schedule Agreement also indicates the specific contract that has been agreed to between Benteler and the Supplier. The buyer sends the schedule agreement to Supplier, along with the confirmation page for signature. The Supplier, by signing the confirmation page and returning it to the buyer, commits to supplying the items listed in accordance with the conditions stipulated in the order. Delivery dates and current requirements are not included in this Schedule Agreement. This data is provided to the supplier on a weekly basis by means of EDI as a separate Planning Schedule (830/DELFOR) and/or Daily Ship Schedule (862/DELJIT) (Appendix 11, 12, and 13). A 3.2.1 Information on a Schedule Agreement Refer to Appendix 23 for this information. A 4.0 Invoicing / Packing Slip A 4.1 Commercial Invoice Requirements The commercial invoice is required for entry into another country and is used to report information to the government. It is important that the commercial invoice includes the items detailed in Appendix 06 Trade Data Requirements. Reference the information in A 4.1.1 and A 4.1.2 to complete the listed fields on the commercial invoice.

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A 4.1.1 Benteler Automotive Canada Corporation and U.S. Purchaser/Sold To: Benteler Automotive Corporation 2650 N. Opdyke Road, Bldg. B Auburn Hills, MI 48326 Consignee/Ship To: Benteler Automotive Corporation specific to the production facility you are shipping A 4.1.2 Benteler de Mexico, SA de CV Purchaser/Sold To: Benteler de Mexico, SA de CV

Prolongación Diagonal Defensores de la República No. 999 Zona Industrial Norte C.P. 72260

Consignee/Ship To: Benteler Automotive Corporation specific to the production facility you are shipping A 4.2 Data Required on a Packing Slip / Delivery Note

Suppliers delivering product or services to a Benteler facility within the US and Canada are required to issue their packing slips in English. Packing slips must contain the information listed below. Suppliers that deliver to Benteler facilities in Mexico may issue packing slips in English or Spanish, though they must still include the following information:

• Supplier Company Name, Address & Phone number of shipping location • Benteler facility name and location receiving the production components • Benteler Purchasing Document Number & Position Number issued for this shipment • Benteler Production Component Number and description as issued from the Purchasing Document • Quantity of each item shipped • Date of shipment • Number of packages (containers) per line item • Total number of packages (containers) for the entire shipment • Supplier Packing Slip Number / Delivery Note that is unique to this shipment • Carrier transporting the goods to the Benteler Facility

A 4.3 Data Required on a Payment Invoice

Suppliers sending invoices to a Benteler facility within the US and Canada are required to issue them in English. Invoices must also contain the information listed below. Suppliers that deliver invoices to Benteler facilities in Mexico may issue them in English or Spanish, though they must still include the following information:

• Supplier Company Name, Address & Phone number • Supplier Remit To Name, Address, & Phone • Supplier VAT Tax (as required) • Currency of Invoice • Complete name & address of Benteler facility that received the product or service • Complete name & address of Benteler facility that has been billed for the product or service • Date Invoice was issued • Unique invoice number (can be the same as the packing slip/delivery note) • Packing Slip / Delivery Note, if not the same as the invoice • Benteler Purchasing Document Number & Position Number as issued for shipment • Benteler Production Component Number and description as issued from the Purchasing Document • Quantity of each item shipped • Unit of Measure Pricing

A 4.3.1 How to get an invoice to Benteler Accounts Payable For each respective entity, all invoices, referencing the Benteler Purchasing document, should be mailed to the entity’s

address as listed below: US Facilities Canadian Facilities Mexican Facilities Benteler Automotive NAO Benteler Automotive Benteler de Mexico, SA de CV 2650 N. Opdyke Road, Bldg. B Canadian Corporation Prolongación Diagonal Defensores de la República Auburn Hill, MI 48326 2650 N. Opdyke Road, Bldg. B No. 999 Zona Industrial Norte C.P. 72260 Auburn Hills, MI 48326

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The following e-mail address can also be used for US & Canadian facilities ONLY : [email protected] The following e-mail address can also be used for Mexico facilities ONLY: [email protected] A 4.3.2 Invoice Returned to a Supplier It is Benteler’s policy that all purchases must have a Benteler Purchasing Document with a unique number assigned to them. This unique number must be on all documents received from the supplier as it is related to that order. If an invoice is received from a supplier without the information listed in 4.3 above this invoice will be returned to the supplier. A 4.4 Banking Instructions For payment of your invoices, please notify BAC Accounts Payable of your banking instructions immediately following receipt of our initial purchase order. The following information must be on your company letterhead and signed by an officer of your company. Please make sure that their name is clearly written below their signature. Please be sure that it is understood that the Supplier signature authorizes Benteler to make Electronic Fund Transfers into the bank account listed. Benteler will pay the amounts owed to the supplier by Electronic Funds Transfer in accordance with the terms of the Purchase Order issued by Benteler to the supplier, plus three calendar days. If the payment date is a non-banking day, the electronic funds transfer will occur the following day on which both Benteler’s originating bank and Supplier’s Depository Institution are available to transmit and receive electronic funds transfers.

• Company Name on the bank account • Bank account number • All sort codes/routing codes that apply to your bank (i.e.: ABA, SWIFT, BLZ, IBAN, etc….) • Name and address of the bank • Your supplier number which is located on the BAC Purchasing Document • Your Company Name and complete address • ACH Classification: International or Domestic

Suppliers sending product to a US or Canadian facility, please send the above information as a .PDF document to the e-mail address of [email protected] Suppliers sending product to a Mexican facility, please send the above information as a .PDF document to the e-mail address of [email protected] Payments to supplier are contingent on providing the above mentioned information to Benteler. A 5.0 Change Management Supplier shall follow Customer Notification and Submission Requirement as defined by APQP, PPAP 4th edition manual (www.aiag.org) and specific OEM requirements as required when reporting any product or process change to Benteler. A 5.1 Engineering Change Request The Engineering Change Request (ECR) (Appendix 24) documents engineering changes that have been made to a production component. The ECR process is initiated by the Benteler Engineering Department and then forwarded to the Benteler Purchasing Department. The designated Benteler ECR Coordinator will send to the supplier an Engineering Change Request to complete the Supplier Feedback form (FSB) (Appendix 14) with critical information to assess the feasibility. Expected response time for each ECR is an Engineering Estimate within 5 business days and an Official Quote within 10 business days. Once the component supplier returns the ECR form to designated Benteler ECR Coordinator, Benteler will review change and, if acceptable, release for production. A copy of the released ECR, purchasing document and updated drawing will be sent to supplier authorizing the change. Normal changes in production component designs and packaging materials require constant attention to assure the consumption process needs are met as economically as possible. The supplier must submit new forms detailing changes, and also communicate packaging changes in advance for proper preparation. A 5.2 Manufacturing Location Change All possible changes to the location of where a Benteler production component is produced should be communicated with the Benteler Buyer as early as possible and must have Benteler’s signed approval prior to the change. These changes may affect many documents and departments in the Benteler organization; including PPAP. (See Section B) When a previously NAFTA qualified component or assembly changes the country it is manufactured in, the NAFTA qualification process must be performed again by the supplier. This is necessary because depending on the new

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manufacturing location, the goods may no longer qualify and an updated NAFTA Certificate of Origin or Manufacturer’s Affidavit (Appendix 06) must be emailed to: [email protected]. A 5.3 Shipping Location Change Changing the shipping location could affect transportation and packaging availability. As soon as it is known that the shipping location may change, Benteler Logistics must be notified. When a previously NAFTA qualified component or assembly changes the shipping location, the NAFTA certificate needs to be reviewed. This is necessary because the address shown on the document may no longer be valid, and an updated NAFTA Certificate of Origin or Manufacturer’s Affidavit (Appendix 06) must be emailed to: [email protected]. A 5.4 Sub-supplier Change When a previously NAFTA qualified component or assembly changes sourcing, the NAFTA qualification process must be performed again by the supplier. This is necessary because depending on the new manufacturing location, the goods may no longer qualify and an updated NAFTA Certificate of Origin or Manufacturer’s Affidavit (Appendix 06) must be emailed to: [email protected]. This change must also meet the standard AIAG requirements; such as PPAP. A 5.5 New or Modified Tooling The Benteler Buyer shall be notified immediately of any need for a new tool to produce a Benteler production component or any modifications needed to a current tool that is producing a Benteler production component. In most cases the supplier will be required to re-PPAP and the supplier should notify the Benteler SQE in advance and follow the standard AIAG requirements and any specific OEM requirements. New, modified or refurbished tooling could be considered an assist or indirect payment according to Customs Regulations. Refer to Appendix 06 Trade Data Requirements explanation to understand the reporting requirements. Benteler travel costs associated with new or modified tooling driven by the supplier will be at the expense of the supplier. Travel associated with OEM or Benteler new or modified tooling are at Benteler’s expense. A 6.0 Rejected Material In the event of a quality disruption with purchased production components, the affected Benteler production facility will notify supplier via phone and/or email. Supplier’s immediate assistance to minimize the impact of a quality problem is required by containing non-conforming / suspect material at all locations of supply chain within 24 hours. Supplier is also expected to assume responsibility of disruption cost associated with the quality problem; See Section B7.3 A 6.1 Rejection Notice/Return Material Number Notification – MRO The Benteler buyer will contact the supplier within a commercially reasonable amount of time after it is determined that an item received does not meet the requirements of the purchase order. A Return Material Number (RMA or RGA) will be requested in conjunction with shipping instructions. It is the responsibility of the supplier to issue the authorization and to have their Finance Department issue the credit memo associated with the return. This credit must be sent to Benteler’s Accounts Payable Department.

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Section B - Supplier Quality B 1.0 Advance Quality Planning and Production Part Approval Process B 1.1 Advance Quality Planning The Advanced Product Quality Planning Process (APQP) is supported by an easy-to-use online application thru Benteler Supplier Portal, supported by Newtron AG (www.newtron.net). Benteler asks standardized questions to the supplier in order to ensure that all necessary information is provided. Attachment like forms, pictures or reports can be easily uploaded. The Benteler Supplier Quality Engineer (SQE) ensures that all of the required data will be provided. The joint target between Benteler and the supplier is Launch Readiness to meet the customer’s requirements. Benteler requires suppliers to support the development phase of the APQP program using the following milestone timing guidelines:

• Milestone A - Sourcing and Kickoff o Start Date: Supplier Notification o End Date: Supplier Notification + 2 Weeks

• Milestone B - Prototype Readiness o Start Date: 2 weeks before supplier shipment of Prototypes o End Date: Delivery date required by program/plant

• Milestone C - Design Release o Start Date: 2 – 4 weeks before supplier’s design freeze date o End Date: Supplier’s design freeze date

• Milestone D - Production Preparation o Start Date: 8 (or more) weeks before Run @ Rate o End Date: 4 weeks before Run @ Rate

• Milestone E - Production Release o Start Date: 4 weeks before Run @ Rate o End Date: 1 week after Run@ Rate

• Milestone F - PPAP Approval o Start Date: PPAP Submission o End Date: PPAP Approval

Any and all travel associated with APQP is at the expense of the respective company. The supplier is required to inform Benteler in a timely and appropriate manner of any risks to the program timing or launch success. Refer to A 2.0. Benteler eSourcing Portal for additional information. B 1.2 Samples for Customer Functional Trial Run and Prototype Components The supplier must have a complete prototype plan that is acceptable to the Benteler SQE. Prototype documentation relative to control plan, gage methodology, dimensional studies, initial process studies, material specification, and functional requirements must be discussed and agreed to with the Benteler SQE. Functional samples, prototype samples and containers shipped to Benteler must be individually labeled in order to prevent the possibility of material mix. Labels at each shipping container must be clearly visible. Refer to Appendix 15 Trial Run and Prototype Parts Label. B 1.3 Run @ Rate / Capacity Verification As part of the Production Part Approval Process, Benteler reserves the right to carry out an extensive process acceptance run (Run @ Rate), on site at the supplier. Unless otherwise agreed to by the Benteler SQE, the supplier should expect the Run @ Rate duration to last two successive shifts under full production conditions. It is expected that the supplier will select parts from this run in support of the initial sample submission. Failure of a Run @ Rate / capacity verification requires the supplier to be responsible for all follow-up travel costs until full PPAP is achieved.

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B 1.4 PPAP Submissions The objective of the Production Part Approval Process (PPAP) is to confirm that the supplier has complied with all customer design requirements and assures the production process is capable of consistently producing conforming product at the required production rate. Suppliers are required to obtain PPAP approval from the Benteler SQE whenever a new or modified part is introduced to production, or the manufacturing process is changed. The production part approval documents and sample production parts must be submitted in accordance with AIAG Production Parts Approval Process - 4th edition (www.aiag.org), OEM specific requirement and/or as directed by Benteler SQE. Unless alternative agreements are made with the Benteler SQE, supplier should apply AIAG PPAP Submission Level 3 for production part approval process. The supplier shall obtain PPAP approval prior to shipping the first production batch. If the initial submission is rejected for any reason, a full corrected PPAP must be submitted by the supplier. Original PPAP samples must be retained at the supplier per AIAG requirements. Late or rejected supplier PPAPs may be subject to Benteler standard administrative fees, including any associated travel costs. B 1.4.1 Supplier IMDS Submission The logging of material data in the IMDS is a requirement for the production part approval process. Submissions must be in accordance with the most recent version of the published IMDS manual for supplier. Acceptance of IMDS submission is a requirement for PSW/PPAP approval. B 1.4.2 Supplier Deviation Request If supplier’s production part or process does not meet customer requirements as defined per the PPAP process, the supplier must submit a deviation request to the Benteler Plant Quality Department and the Benteler SQE. Refer to Appendix 16 for the Benteler Supplier Deviation Request form. A thorough explanation of the background shall be included in the deviation request along with the requestor contact information, the affected production part number(s), a corrective action plan and the period of time or quantity authorization is required. The Benteler Plant Quality Department and the Benteler SQE will evaluate the deviation request with the appropriate functional groups and if agreed, the deviation will be authorized. PPAP submission to Benteler shall include a copy of the approved deviation to proceed with interim PPAP approval. Benteler travel expenses associated with closing PPAP to full approval will be at the expense of the supplier when the supplier is at fault for not meeting the initial PPAP submission. B 1.5 Early Production Containment The early production containment is required for all pre-production, production parts and services that require PPAP, as well as carry over parts with significant risk to Benteler and/or mandated by Benteler’s customer. A pre-launch control plan is required for Early Production Containment to ensure the enhancement to the supplier's production control plan and raises the confidence level to ensure that all parts shipped will meet Benteler and/ or OEM requirements. The supplier must reach an agreement with the Benteler SQE on this subject prior to launch (at Benteler APQP Milestone D).

Expectations of Early Production Containment at each process stage are as follows:

1. Create the Pre- Launch Control Plan: Supplier shall generate a pre- launch control plan that is significant enhancement to the production control plan. The pre-launch control plan should take into consideration all known critical conditions of the part as identified on the PFMEA as well as potential areas of concern identified during the APQP process.

2. Validation: Supplier shall establish a validation process to monitor the effectiveness of the pre- launch control plan. Facilities and containment process will be validated by the Benteler SQE.

3. Documentation: The pre-launch control plan shall be documented in the AIAG control plan format. Early production containment activities must be documented and results available on request. All actions taken to contain nonconformities must be documented.

4. Exit Criteria/ Duration: The supplier will be eligible to exit containment after validating the effectiveness of the process control plan and had shipped product without customer disruptions for the specified period or number of pieces required as agreed with Benteler and/or the OEM. If the supplier is unable to meet the exit criteria, the early containment plan must continue until the quality concerns are resolved to the satisfaction of both the supplier and the customer, and the supplier’s production control plan is validated.

5. Consequences of shipping nonconforming material: Shipment of non-conforming material or failure to execute containment will result in Controlled Shipping Level 2 and other possible consequences including supplier’s placement on Focus Supplier Program and New Business Hold in addition to all legal rights given under the contracts and Benteler’s Standard Terms and Conditions. See B7.3 for expected costs.

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B 2.0 Ongoing Production Quality It is expected that the supplier verify and improve product and process quality through regularly-scheduled internal system, process and product audits. Additionally, it is expected that the supplier pursue continued quality improvements through the tracking and evaluation of internal process indicators (e.g. downtime, scrap, rework, etc.). The supplier shall employ suitable procedures (e.g. statistical process control or manual control chart methods) across the entire production period in order to prove the process capability for any and all function-relevant characteristics. If the required process capability is not achieved, quality shall be ensured via suitable 100% tests until the supplier can optimize the production process in order to meet the required capability. 100% tests must be supported by documented standardized work that is supported by training records on all associated shifts. B 3.0 Part/Batch Traceability It is the responsibility of the supplier to ensure that Benteler is aware of and accepts the level of traceability the supplier can ensure prior to product launch. The supplier is responsible and liable for the clear traceability and proper marking of the product during all phases of production and delivery (including sub-contractors & external processes). The supplier shall ensure full traceability of items supplied to Benteler through the implementation of appropriate technical and organizational measures. The possibility of establishing the origin of primary material and the supplier’s production data must be guaranteed at any time. The traceability information of a supplied part shall be available, upon Benteler’s demand, at any time. B 4.0 Part Re-qualification Yearly re-qualification is required for all Benteler purchased parts. Production part re-qualification process should include at a minimum: - Full dimensional analysis on at least three finished production parts (per cavity if applicable). - Material certification. - Performance and functional test results. - Capability analysis for critical dimensions as defined at customer drawing or by the Benteler plant. - Other re-qualification requirements will be applicable depending on OEM program. If re-qualification results do not meet customer drawing requirements or capability acceptance criteria per AIAG PPAP 4th edition manual (www.aiag.org), the supplier must immediately initiate required countermeasures and notify the Benteler SQE. The supplier must retain records of yearly re-qualification onsite. Requalification records shall be supplied to Benteler within 24 hours after customers’ request. B 5.0 Supplier Process Audit Benteler uses the process audit as a tool to assess the supplier’s system and practices against standard automotive industry norms in an effort to continuously improve our supply base and minimize risk associated with supplied parts. The Benteler SQE will conduct periodic onsite audits to assess supplier’s production processes. The supplier will be notified in advance by the Benteler SQE to coordinate an audit date and agenda. A Corrective Action Report will be generated with the findings and a corrective action plan. The supplier is required to address any open points coming out of the process audit in a timely and thorough manner. Refer to Appendix 25 Process Audit Form for additional information. Travel expense is the responsibility of Benteler for the audit and one follow-up visit. Additional visits will be at the expense of the supplier. B 6.0 Change Management The supplier shall follow customer notification and submission requirements as defined by APQP, PPAP 4th edition manual (www.aiag.org) and specific OEM requirements as required when reporting any design engineering change, manufacturing or shipping location change, sub-supplier change or new/modified tooling changes to Benteler. Refer to section B1.0 Production Part Approval Process for applicable PPAP submission requirements. B 7.0 Rejected Material In the event of a quality disruption with purchased production part(s), the affected Benteler production facility will notify supplier via phone and/or email. Supplier’s immediate assistance to minimize the impact of a quality incident is required by containing non-conforming / suspect material at all locations of the supply chain within 24 hours. The supplier is also expected to assume responsibility of the disruption cost associated with a confirmed supplier quality problem. See Section B7.3

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B 7.1 Quality Incident Management The illustration in Appendix 17 explains Benteler’s requirements for supplier quality incident management. Incomplete or late supplier problem solving reports may be subject to Benteler administrative fees. B 7.2 Problem Solving Methodology Benteler requests that suppliers adopt a cooperative, proactive problem-solving philosophy which emphasizes the following:

- Data-driven analysis - Team approach to the problem solving activity - Development of possible root causes through the use of the fishbone / Ishikawa Diagram - Root cause analysis through the use of the 3 x 5 Why Methodology - Implementation of corrective action(s) which address prevention, detection and quality system improvement - Verification of corrective action(s) through data analysis - Implementation of corrective action(s) into similar products and processes as a preventative measure and continuous improvement activity

B 7.3 Incident Financial Report An Incident Financial Report will be completed by the Benteler production facility and sent to supplier with charges of disruption costs. [The disruption cost will include, but is not limited to, the cost of non-conforming product, cost of third party inspections, cost of finished product repair or scrap at Benteler, line downtime caused by disruption, cost of material handling suspect product, charges from OEM or Benteler’s customer (if pass-thru issue), travel costs, and other cost of extraordinary activities initiated by Benteler to minimize impact of the disruption. Benteler will charge a standard administrative fee for every disruption caused by a defective purchase part. ] B 7.4 Request Suspect Production component Return The supplier has the right to request return of defective and suspect material contained at the affected Benteler production facility. A Return Material Authorization (RMA or RGA) needs to be provided by the supplier in order to return suspect material. If necessary, the supplier can also provide the Benteler production facility with their account number of an Expedite Delivery Company to return suspect samples for prompt root cause evaluation. The supplier should contact the designated quality representative at the Benteler production facility to coordinate return of suspect material. If a suspect part is found after assembled, at a minimum supplier will receive a picture showing the suspect condition. Supplier has the option to review suspect material at the Benteler plant. B 7.5 Incident Dispute Process Benteler requires suppliers to submit incident disputes via 8D report with a thorough explanation of supplier position. The dispute should be documented with complete test reports and visual illustrations that clearly explain supplier’s conclusion. Disputes need to be submitted to the Benteler SQE and the Production Plant Quality representative within five business days after suspect part is received or analyzed by supplier. If suspect part analysis takes longer than five days, the Benteler Quality Manager and the Benteler SQE will consider an extension of the five day limit to submit the dispute. Once dispute is reviewed at Benteler, the designated Benteler SQE will notify supplier with results. B 8.0 Supplier Performance KPI Benteler expects the supplier to support our organizational targets for the following Key Performance Indicators: Pass-through customer incidents: 0 PPAP: 100% on-time full approval 8D closure within: 21 working days Process Audit Score: >90 % Deliveries: 100 % on-time Each year the supplier will receive a letter notifying them of their annual PPM and incident targets. Suppliers will also receive at a minimum a quarterly scorecard showing their actual performance to these targets.

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B 8.1 Benteler Focus Supplier Program. If the supplier’s performance does not meet Benteler expectations, the supplier could enter into the Benteler Focus Supplier Program. Within this program, cooperative problem solving activities will be entered into by Benteler and Supplier’s Management Team. Once a supplier is selected for the Focus Supplier Program, the supplier is expected to actively support all program activities including travel costs (air & hotel) of Benteler SQE. If the supplier’s performance does not improve within the first three months from the inclusion date, long-term containment measures could be instituted and/or punitive steps could be taken by Benteler Purchasing Management. Likewise, Supplier may be found to be in material breach of the terms of the purchase order or related long-term agreement. This may be grounds for termination of the contract between Supplier and Benteler. The criteria for supplier selection to the Benteler’s Focus Suppler Program is based on, but not limited to, the following guidelines:

Performance of supplier based off PPM and/or number of incidents – Suppliers that have three quality non-conformities within each quarter – Supplier has repeat non-conformities – Supplier non-conformity impacts customer with line shut down – Supplier non-conformity with an impact to the OEM – Supplier actual PPM is higher that PPM target communicated in supplier’s scorecard

Continual Short/Missed shipments per EDI releases

– Suppliers that have three non-conformities within each quarter – Supplier shuts customer down due to missed shipment

Responsiveness to Quality concerns

– Supplier refuses to initiate containment within 24 hours of notification – Supplier containment is ineffective – Supplier fails to submit an effective 8D within the required timing. Refer to B 2.1 Quality Incident

Notification

ECR Management – Supplier fails to meet customer ECR deadlines, including late PPAP

B 9.0 General Supplier Communication & Support Benteler expects the supplier to act as an extension of our business and support our plants with open and accurate communication. Further, Benteler expects the supplier to be available (at our facility or elsewhere) for technical support when required. If the supplier is requested to support activities with a Benteler customer, communication between the supplier and the Benteler customer may only occur with Benteler’s prior written consent. B 10.0 Contingency Plans The Supplier must have an executable contingency plan to ensure supply of product to Benteler. This plan should generally address natural disasters, power outages, labor work stoppages, etc. The plan should also specifically address the facility and equipment used to produce the Benteler products and details regarding alternative means to continue the supply of product to Benteler.

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Section C - Logistics C 1.0 Logistics Agreement C 1.1 System Requirements C 1.1.1 EDI Requirements

• Available formats: X12, EDIFACT, VDA • Required EDI Transactions: See Appendix 11, 12, and 13 for details of the list below. Planning schedule (830/DELFOR) Advanced Ship Notification (856/DESADV) Functional Acknowledgment (997/CONTRL) Daily Ship Schedule (862/DELJIT) • The Benteler EDI contact is monitors [email protected]. The users monitoring this address will be able

to conduct testing and approve compliance. Please return the EDI Survey to this address to begin testing. See Appendix 05 EDISurvey.

• All suppliers are required to send an Advanced Shipping Notification (ASN) immediately upon shipment conveyance.

• All dates contained within EDI call-offs are SHIP dates. This is the date that our carrier will pick up the product at your facility.

C 1.1.2 Barcode Label

• Containers must be labeled according with Benteler’s documented specifications, based on Appendix 08 EDI and Barcode Specifications. o If you ship multiple containers on a pallet, a Master Label is required. o Do not ship mixed loads. o Please use only the supplier code issued by Benteler.

• Certification process will be conducted prior to implementation of barcode receiving. Bar codes are scanned against supplier ASN upon receipt for receiving verification.

• Suppliers which do not meet these requirements will be subject to administrative charges and MCN process. • Labels are to be submitted for pre-approval as instructed prior to Start of Production to:

o Attn. Corporate IT o Scan E-mail to: [email protected] o Fax to: (248) 364-7160 o Mail to: 2650 N. Opdyke Road, Bldg. B, Auburn Hills, MI 48326

C 1.2 Packaging Specifications C 1.2.1 Packaging Instructions / Logistic Data Form Depending on the production component, either the Benteler or Supplier Logistics department will issue an initial packaging specification (Appendix 18 Logistics Agreement) that will detail the initial plan for production component packaging. C 1.2.2 Packaging Design / Development C 1.2.2.1 Returnable Packaging Development

The supplier is responsible for supporting the design, testing, and approval of the packaging. Both Benteler and the supplier are required to provide a final approval. Final approvals must take place 90 days prior to start-of-production.

C 1.2.2.2 Expendable Packaging Development The supplier is responsible for designing, developing and testing the packaging. Benteler and the supplier are required to provide final approval.

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C 1.2.2.3 Packaging Priorities When developing production component packaging, the following priorities are to be respected:

• Employee ergonomics will be taken into account on all shipping containers • Maximize the use of returnable and collapsible packaging • Minimize the amount of expendable waste used as internal packaging • Ensure that the quality of the production components are maintained at all times • Packaging must conform to all governmental and transportation rules and regulations. • The package design must deliver the production component to the point of use, in a production ready

and damage-free condition. • Packaging design and production components count (pieces per container) for a single production

component shall not vary from one container to another and containers are to always be shipped to agreed upon container production component counts except when a release is marked „Final release“ or „Balance out“.

C 1.2.2.4 Packaging Material Types

• Whenever possible, reusable materials should be used, such as returnable containers and thermoform plastics, etc. All returnable and expendable packaging materials must be clearly stated on the packaging specification form. The supplier is responsible for procuring and supplying all expendable packaging.

• All expendable plastic materials must have the material recycling logo clearly identified on all pieces shipped to Benteler for proper recycling.

• All suppliers shipping into the United States must conform to United States APHIS requirements on Solid Wood Packing Material treatment. Refer to Section Solid Wood Packaging Materials – Heat or Chemical Treatment Requirements of this packaging guideline for further details. Benteler will not be held responsible for any shut-downs, fines, etc. related to non-conforming solid wood packing materials.

• Expendable Containers o In some cases, expendable packaging containers may be utilized instead of the normally preferred

returnable containers. Approval for the supplier to utilize expendable containers for regular production use must be approved in writing by Benteler logistics prior to launch.

o In the event that expendable packaging is determined to be the best solution, unit loads must cube out the pallet footprint. The container(s) are never to extend beyond the edges of the pallet. Paperboard edge protectors may be necessary to prevent carton damage when supplying cartons on pallet.

o Stretch wrapping may be utilized with prior written approval from Benteler Logistics. A minimum of two complete passes of stretch wrapping must be used along with edge protectors utilized on all four vertical corners.

C 1.2.2.5 Unique Packaging Requirements

• Identifying unique packaging requirements to protect the production component (i.e. rust prevention, fragility, electrostatic discharge protection or visual characteristics, etc.) is the responsibility of the supplier and must be approved by the Benteler Logistics and Quality departments.

• The supplier is responsible for procuring any and all expendable packaging materials used on a regular production basis or for secondary back-up packaging (i.e. VCI coated paper or plastic, general plastic bags, desiccant, banding, expendable cartons and or dunnage, etc.).

C 1.2.3 Material Handling C 1.2.3.1 General Requirements

• The supplier must notify Benteler Logistics or Purchasing, in writing, during the concept development phase of any special material handling requirements due, but not limited to, manufacturing/assembly line limitations, special material handling equipment, or operator ergonomics. Any undocumented issues that later cause a financial impact to correct will be turned over to Benteler Purchasing for cost recovery resolution with the supplier.

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• Intercontinental suppliers shipping in expendable cartons, returnable KLT or other modular pallet unit loads will be required to use a minimum of four plastic bands per unit load. Two across each vertical unit load face. Plastic banding is not to exceed a 12.7mm (½ inch) width unless approved in advance and must have a minimum of 317 (kilograms 700 pounds) average breaking strength. The supplier is responsible for procuring the plastic banding that meets the above mentioned requirements. Use of stretch wrapping must be approved in advance by Benteler.

• North American suppliers shipping in expendable cartons, returnable totes, or other modular pallet unit loads will be required to use a minimum of two plastic bands. Plastic banding is not to exceed a ½ inch width unless approved in advance and must have a minimum of 700 pounds (317 kilograms) average breaking strength. The production supplier is responsible for procuring the plastic banding that meets the above mentioned requirements. Stretch wrapping must be approved in advance by Benteler.

• The standard maximum acceptable weight of production unit loads handled via mechanical equipment (fork lifts, pallet jacks, etc.) will not exceed a gross weight of 817 kg (1,800 pounds). Any unit loads that exceed this gross weight guideline must be specially reviewed to assure that the proper container and material handling equipment is capable of handling the higher weight.

• The maximum acceptable weight of individual hand carried returnable totes (KLT) or expendable cartons must not exceed a gross weight of 15.8 kg (35 pounds). Gross weight consists of the combination of the TARE weight of the returnable tote (KLT) or expendable carton and production components.

C 1.2.3.2 Production packaging shipping requirements

• All production shipments are to be made in approved primary packaging unit loads detailed on the packaging specification except when a deviation has been provided in advance and in writing by the Benteler production facility Logistics Department.

• The supplier’s failure to conform to this requirement will result in the issuance of a Receiving Discrepancy Report and an applicable fee from the Benteler production facility to said supplier.

• Benteler will return empty supplier returnable packaging on prescheduled return shipments via the standard Benteler transportation network.

C 1.2.4 Container Bar Code Labeling and Supplier Identification Reference the section on bar code labeling provided under Appendix 19 Supply Chain Management - Supplier Requirements. Benteler provided returnable shipping containers and any respective internal, removable dunnage will be identified with supplier name (or abbreviation) to assure that the specific packaging materials are properly returned to the production component supplier.

C 1.2.5 Shipping Container Classification In some instances unique production component characteristics or production facility limitations will require unit load sizes which vary from the standard container types and/or dimensions indicated below. These unique situations will be clarified during the container concept development phase of the packaging development between Benteler and the production component supplier. If there are any special requirements on the suppliers’ behalf, these must be provided to Benteler during the concept phase. C 1.2.5.1 Returnable containers

Due to environmental, ergonomic, cost, and quality considerations, Benteler encourages the use of returnable packaging for all of its incoming production components. Benteler will negotiate with the supplier if returnable packaging does not meet the suppliers manufacturing or processing requirements.

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C 1.2.5.2 Returnable Standard Containers Many production components can be shipped in standard containers which are already designed and require little or no modification. Intercontinental suppliers shipping to North America:

The preferred pallet box container types are: Plastic pallet box 4039 (1200 x 1006 x 1000 mm) Plastic pallet box 5748 (1448 x 1219 x 864 mm) Plastic pallet box 6448 (1638 x 1219 x 864 mm) Steel collapsible rack (1135 x 935 x 1075 mm) Steel collapsible rack (1500 x 1100 x 1100 mm)

The preferred KLT (tote) unit load container:

KLT (tote) unit load footprints of 800 x 1000 mm or 1200 x 1000 mm The KLT unit load height can not exceed 1100 mm

North American suppliers shipping within North America:

The preferred pallet box container types are: Plastic pallet box 3234 (864 x 813 x 864 mm) Plastic pallet box 4534 (1200 x 1143 x 864 mm) Plastic pallet box 5748 (1448 x 1219 x 864 mm) Plastic pallet box 6448 (1638 x 1219 x 864 mm) Steel collapsible rack

The preferred tote (KLT) unit load container: Tote (KLT) unit load footprint dimensions of 1219 x 1143 mm The Tote (KLT) unit load height can not exceed 1143 mm

For both Intercontinental and North American suppliers shipping production components in KLT’s/Totes.

The sizes of the individual KLT/tote will be dictated by production component dimensions, weight, fragility, ergonomics, electro-static discharge protection, and meeting maximum gross weight of individual totes stipulated under section 2.3 Material Handling. The supplier must always ship full layers of KLT’s/Totes. The supplier’s failure to conform to this requirement will result in the issuance of a Receiving Discrepancy Report and an applicable administrative fee from the Benteler facility to said supplier.

C 1.2.5.3 Economics

Benteler tries to receive packaged production components utilizing the most economical method possible, while at the same time maintaining production component quality, line space efficiency, employee ergonomics, tooling, container repair and recycling, and maximizing transportation utilization.

C 1.2.5.4 Maintenance The supplier is responsible for keeping any and all packaging materials clean and maintained in a useable/functional condition. This includes but is not limited to removing old bar co

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C 1.2.5.6 Solid Wood Packaging Materials – Heat or Chemical Treatment Requirements As of September 16, 2005 all solid wood packaging materials imported into the United States must conform to the United States Department of Agriculture, Animal and Plant Health Inspection Service (APHIS herewith) Title 7 Code of Federal Regulations Part 319. This United States Federal Regulation requires that all solid wood packaging materials must be either heat treated or fumigated with methyl bromide to prevent the introductions of exotic plant pests into the United States. - “APHIS has set standards for Wood Packaging Material imported into the USA through 7 CFR 319.40 - Importation of Wood Packaging Material, as published on September 16, 2004. This rule states that all regulated wood packaging material shall be appropriately treated and marked under an official program developed and overseen by the National Plant Protection Organization (NPPO) in the country of export.” - Refer to the following USDA APHIS web site for full detailed requirements about this new guideline: http://www.aphis.usda.gov/ppq/swp/import.html

C 1.2.6 Packaging Approval Process Once the correct packaging has been selected and agreed upon by Benteler Logistics, the Supplier and the Customer (when applicipable) then the information should be communicated to the Logistics department. It is expected that the supplier approves the packaging for maintaining the components/function and quality when shipped and stored. A scanned electronic copy (preferred file type is Adobe Acrobat PDF) of the currently approved packaging specification should be provided back to the respective Benteler representative with the supplier representative name, signature, position, and date included. C 1.2.7 Packaging Shipment Process Suppliers are responsible for conforming to the packaging specification to prevent production component damage. Non-conformances will generate RDR’s (Receiving Discrepancy Reports) and will impact supplier delivery performance. C 1.2.8 Commercial Invoice Requirements The commercial invoice is required for entry into another country and is used to report information to the government. It is important that the commercial invoice includes the items detailed in Appendix 06 Trade Data Requirements. Reference the information in C 1.2.8.1 and C 1.2.8.2 to complete the listed fields on the commercial invoice. C 1.2.8.1 Benteler Automotive Corporation Canada and U.S. Purchaser/Sold To: Benteler Automotive Corporation 2650 N. Opdyke Road, Bldg. B Auburn Hills, MI 48326 Consignee/Ship To: Benteler Automotive Corporation specific to the production facility you are shipping C 1.2.8.2 Benteler de Mexico, SA de CV Purchaser/Sold To: Benteler de Mexico, SA de CV

Prolongación Diagonal Defensores de la República No. 999 Zona Industrial Norte C.P. 72260

Consignee/Ship To: Benteler Automotive Corporation specific to the production facility you are shipping C 1.2.9 Data Required on a Packing Slip / Delivery Note

Suppliers delivering product or services to a Benteler facility within the US and Canada are required to issue their packing slips in English. Packing slips must contain the information listed below. Suppliers that deliver to Benteler facilities in Mexico may issue packing slips in English or Spanish, though they must still include the following information:

• Supplier Company Name, Address & Phone number of shipping location • Benteler facility name and location receiving the production components • Benteler Purchasing Document Number & Position Number issued for this shipment • Benteler Production Component Number and description as issued from the Purchasing Document • Quantity of each item shipped • Date of shipment • Number of packages (containers) per line item • Total number of packages (containers) for the entire shipment • Supplier Packing Slip Number / Delivery Note that is unique to this shipment • Carrier transporting the goods to the Benteler Facility

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C 1.3 Customs Clearance When product moves across an international border, details regarding the shipment must be reported to the customs agency of that country. In some cases, both the exporting and importing countries require this reporting before the government will release the goods. This release is called Customs Clearance and the detailed requirements are different for each country. C 1.3.1 Shipping to Benteler in Canada C 1.3.1.1 Paperwork Requirements

Every shipment must include a packing slip, bill of lading and customs invoice. Present this paperwork to the driver at the time of shipment. Data for the Part Number, Part Description and Value fields must be taken from the Benteler Purchase Agreement. Packing Slip: - All shipments must be accompanied by a packing slip which is to be adhered to one of the unit loads.

Customs Invoice: - All shipments must have three (3) copies of the Customs Invoice - The Customs Invoice must have the quantity shipped, the product and description shipped and the value of each individual line item.

C 1.3.1.2 Broker Information DHL Global Forwarding 6200 Edwards Blvd. Mississauga, Ont. L5T 2V7 289.562.6500 C 1.3.2 Shipping to Benteler de Mexico S.A. de C.V. C 1.3.2.1 Paperwork Requirements

Every shipment must include a certificate of origin, packing slip, bill of lading and customs invoice. Present this paperwork to the driver at the time of shipment. Data for the Part Number, Part Description and Value fields must be taken from the Benteler Purchase Agreement. Certificate of Origin: - This may be in the form of a NAFTA for North American Free Trade Agreement eligible goods. - This may also be in the form of a EUR1 for European goods. With permission from the European

government, you may add a statement similar to the one below to your customs invoice. If a signed original invoice with this statement is provided, the EUR1 will not be needed.

Packing Slip: - All shipments must be accompanied by a packing slip which is to be adhered to one of the unit loads.

Customs Invoice: - All shipments must have three (3) copies of the Customs Invoice - The Customs Invoice must have the quantity shipped, the product and description shipped and the value of each individual line item.

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C 1.3.2.2 Broker Information Broker Agency Customs Address Phone Number Plant

Moz Agencias Aduanales Veracruz Calle Benito Juarez No 357

Centro, 91700 Veracruz, Veracruz

01 (229) 9896609 Puebla Assembly

Moz Agencias Aduanales Manzanillo Boulevard Costero Miguel de La Madrid No 4190 Col Del

Pacifico Manzanillo, Col. 01 (314) 33 101 50 Puebla Assembly

Moz Agencias Aduanales Altamira Cella 2A.201 Col Lomas de

Chairel 89360 Tampico Tamaulipas

01 (833) 2 30 22 05 Puebla Assembly

Moz Agencias Aduanales Lazaro Cardenas

Andador Cerezos 20-Altos, Segundo Sector de

Fideicomiso, 60950, Lazaro Cardenas, Mich

01 (4453) 537-44 31 Puebla Assembly

Ryder Laredo 8410 W. Bob Bullock, Laredo, TX 78045 001 (956) 707-3041 Puebla Assembly

Cargoquin Laredo 5803 East Drive, P.O. Box 1128, Laredo TX 78041 01 (956) 722 99 78 Puebla Assembly

Corporativo Aduanal Especializado

Aeropuerto De Mexico

Boelvard Valsequillo 707-A, Col Prados Agua Azul, CP

72430 01 (222) 285 15 07 Stamping &

Assembly Plants

Grupo Logistica Internacional Veracruz

Andador Cerezos 20-Altos Segundo Sector De

Fideicomiso, 60950, Lazaro 01 (229) 939 66 01 Puebla Stamping

Gonzalez De Castilla Laredo 11929 Sara Drive, El Portal

Industrial Park, P.O. Box 1391 Laredo Texas 78045

01 (956) 712 65 42 Puebla Stamping

Dicex Toluca

Boulervard Miguel Aleman No 5 Edificio de la Aduana 2Do Piso Col. Sam Pedro

Totoltepec, Toluca Estado de Mex CP. 50200

01 (722) 65 89 00 Stamping & Assembly Plants

C 1.3.3 Shipping to Benteler in the United States C 1.3.3.1 Paperwork Requirements

Every shipment must include a packing slip, bill of lading and customs invoice. Present this paperwork to the driver at the time of shipment. Data for the Part Number, Part Description and Value fields must be taken from the Benteler Purchase Agreement. Packing Slip: - All shipments must be accompanied by a packing slip which is to be adhered to one of the unit loads.

Customs Invoice: - All shipments must have three (3) copies of the Customs Invoice - The Customs Invoice must have the quantity shipped, the product and description shipped and the value of each individual line item.

C 1.3.3.2 Broker Information DHL Global Forwarding - Northern Border (Canada) 2660 20th Street Port Huron, MI 48060 810.987.8966 - Southern Border (Mexico) 302 Grand Central Blvd. Laredo, TX 78045 956.725.0791 - Atlanta, GA (Ocean/Air) 2500-A Sullivan Road College Park, GA 30337-6204 404.942.0600

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C 1.3.4 Shipping FROM Mexico to Benteler US or Canada C 1.3.4.1 Paperwork Requirements

The packing slip, bill of lading and customs invoice must be scanned and e-mailed to Benteler’s custom broker within 30 minutes of departure. Failure to do so will result in delays in customs clearance and/or unnecessary storage/demurrage costs which may be invoiced back to Supplier by Benteler.

C 1.3.4.2 Broker Information DHL Global Forwarding 302 Grand Central Blvd. Laredo, TX 78045 956.725.0791 C 1.3.5 Security For the safety of our employees as well as the nations in which we employ, Benteler requires cooperation from our suppliers to help secure our supply chain. Currently our focus is on the two initiatives explained below. C 1.3.5.1 Importer Security Filing

ISF went into effect on January 26, 2009 as an additional filing required for cargo arriving to the U.S. via ocean carrier. As this is a U.S. law, failure to submit the information will lead to monetary penalties, increased inspections and delay of cargo. The purpose of this law is to improve U.S. Customs and Border Protection’s (CBP) ability to identify high-risk shipments, prevent smuggling and ensure cargo safety and security. To support this law, Benteler is requiring suppliers to submit advance information to our freight forwarder DHL Global Forwarding for each shipment to the U.S. via ocean carrier. This form and explanation can be found in Appendix 06 Trade Data Requirements.

C 1.3.5.2 Customs Trade Partnership Against Terrorism C-TPAT is a voluntary program between the U.S. Government and businesses. The goal of this program is to work together to build a more secure supply chain. Benteler supports this initiative and has gained certification for the Duncan, South Carolina and Puebla Mexico assembly facilities. New Suppliers to Benteler: -When becoming a new supplier to Benteler, we ask that you complete the C-TPAT questionnaire (Appendix 04 C-TPAT Questionnaire). This questionnaire is designed to gain an understanding of your company’s current level of security. Suppliers to Benteler Duncan, South Carolina: -As a supplier to our Duncan, South Carolina facility we require the questionnaire be completed on an annual basis and sent to [email protected]. Suppliers to Benteler’s Puebla Assembly Plant: -As a supplier to our Puebla Assembly facility we require the questionnaire be completed on an annual basis and sent to [email protected]

C 1.3.6 Foreign Trade Zones (FTZ) A Foreign-trade zone (FTZ) is a restricted access site in or adjacent to a Customs port of entry and is treated for purposes of the tariff laws and Customs entry procedures as being outside of the Customs territory of the United States. Under zone procedures, foreign and domestic merchandise may be admitted into the zone for operations such as storage, exhibition, manipulation, destruction, assembly, manufacture and processing, without being subject to formal Customs entry procedures and payment of duties until it enters the Customs territory for domestic consumption. The Duncan, SC facility is a designated FTZ and the movement of merchandise into this facility must occur via a bonded carrier who requests an “In Transit” (IT) bond from the port of entry to travel to the FTZ. The bonded carrier requires certification under the C-TPAT program and upon arrival, the security seal is removed and all merchandise is accounted for and admitted into the FTZ for use in the manufacturing of chassis systems. C 1.4 Trade Data Requirements This document was designed to provide further guidelines to the suppliers for shipping as well as trade relevant information. Refer to Appendix 06 Trade Data Requirements to view requirements for shipping as well as paperwork completion.

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C 1.4.1 North American Free Trade Agreement (NAFTA) The North American Free Trade Agreement (NAFTA) enables items of US, Canadian or Mexican origin to qualify for reduced duty rates. The solicitation of the NAFTA Certificate of Origin is a requirement for production components supplied to Benteler, as we utilize this data to certify our end items for our customers. If you are not the manufacturer of production components sold to Benteler, then it is your responsibility to obtain the NAFTA information from the original manufacturer and complete the Certificate of Origin. The NAFTA Rules of Origin located in General Note 12 of the Harmonized Tariff Schedule (www.cbp.gov) and the NAFTA Trace List (Appendix 21) are utilized to determine whether a good qualifies under this agreement. The annual process to solicit NAFTA Certificates occurs in the fall to avoid duty payments the first of the following year. This form and instructions can be found in Appendix 06 Trade Data Requirements. C 1.4.2 Manufacturer’s Affidavit (MA) The Manufacturer’s Affidavit is utilized to provide origin and content information for non-NAFTA qualified components and assemblies. If you are not the manufacturer of production components sold to Benteler, then it is your responsibility to obtain the origin and content information from the original manufacturer and complete the Manufacturer’s Affidavit. This form and instructions can be found in Appendix 06 Trade Data Requirements. C 1.4.3 Traced Value Traced Value is the amount of foreign content in a component or assembly and is reported on the NAFTA Certificate of Origin or Manufacturer’s Affidavit. These forms and instructions can be found in Appendix 06 Trade Data Requirements. C 1.5 Transportation Responsibility for transportation arrangement and costs can be found on your Purchase Agreement under Delivery Terms. Listed will be an Incoterm with a location. Incoterms represent a set of international rules for the interpretation of commonly used trade terms. It is important that you follow the delivery terms on your purchase agreement to avoid delays in the supply chain. Examples are shown below. Example A: Supplier is located in Paderborn, Germany and has sold product to Benteler Automotive Canada Corporation. FCA Paderborn, Germany - Benteler Automotive Canada Corporation is responsible to arrange and pay for transportation and customs clearance costs. - The supplier is responsible to complete any necessary export and load the freight on the truck. Example B: Supplier is located in Toronto, Canada and has sold product to Benteler de Mexico S.A. de C.V. EXW Toronto, Canada - Benteler de Mexico S.A. de C.V. is responsible to arrange and pay for transportation and customs clearance costs. - The supplier is responsible to load the freight on the truck provided by Benteler de Mexico S.A. de C.V. If Benteler is responsible for arranging the transportation, your location will be contacted with details of the arrangement. Wherever possible, regular routes will be established for production components. Irregular shipments may require notification of order readiness be sent to Benteler for initiation of transportation arrangement. C 1.5.1 Ground Transportation Ryder Integrated Logistics is our provider for all Land Transport for Benteler in Canada and the United States. Benteler de Mexico S.A. de C.V. uses Ryder as well as other local carriers. C 1.5.2 Air/Ocean DHL Global Forwarding is our provider for all Air and Ocean shipments for Benteler Automotive Canada Corporation and United States. Benteler de Mexico S.A. de C.V. uses Hellmann Worldwide Logistics as well as other carriers. C 1.5.3 Direct Shipment to Customer Any shipment to Benteler’s customer from our supplier must have a signed bill of lading sent back to the responsible Benteler facility. C 1.5.4 Expedite In the event that an expedited shipment is needed, Benteler will work with our established carriers to arrange the most efficient shipment. If the need for this extra freight is caused by the supplier, the cost will be deducted from an upcoming payment. Explanation of this charge back will be sent at the time of shipment scheduling.

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C 2.0 Change Management Supplier shall follow Customer Notification and Submission Requirement as defined by APQP, PPAP 4th edition manual (www.aiag.org) and specific OEM requirements as required when reporting any product or process change to Benteler. C 2.1 Engineering Change Request The Engineering Change Request (ECR) documents engineering changes that have been made to a production component. The ECR process is initiated by Benteler Engineering Department and then forwarded to the Benteler Purchasing Department. The designated Benteler buyer will send to supplier an Engineering Change Request with request to complete the Supplier Feedback form (SFB) with critical information to assess feasibility of change. Expected response time to each ECR is an Engineering Estimate within 5 business days and an Official Quote within 10 business days. Once the component supplier returns the ECR form to designated Benteler buyer, Benteler will review change and if acceptable release for production. A copy of the released ECR, purchasing document and updated drawing will be sent to supplier authorizing the change. Normal changes in production component designs and packaging materials require constant attention to assure the consumption process needs are met as economically as possible. The supplier must submit new forms detailing changes, and also communicate packaging changes in advance for proper preparation. C 2.1.1 Supplier Responsible Packaging Any change in production component design that affects logistics (packaging or freight) needs to be communicated to the Benteler Logistics team immediately by submitting a completed Packaging Specification Form found in Appendix 18 Logistics Agreement. This form must be mutually agreed upon and signed by Benteler & Supplier, before the change is applied. Benteler requires test results and a test pack evaluation for supplier responsible packaging. Production components that require rust inhibiting dunnage will be provided by the supplier, and paid for via piece price negotiation with Benteler Logistics and Benteler Purchasing. C 2.1.2 Benteler Responsible Packaging Any change in production component design that affects logistics (packaging or freight) will be communicated to the supplier immediately. The Benteler Logistics Team will send the Packaging Specification Form found in Appendix 18 completed with the new packaging design that fits in the new production component. The supplier will be given time to evaluate this internally to check any other potential impacts and the form needs to be mutually agreed to and signed by Benteler & Supplier, before the change is applied. Any reduction in unit load densities that affect the existing fleet size in packaging will be discussed with the supplier, and any additional fleet size required will be provided to the supplier. Any impact in freight due to packaging design changes will be studied by Benteler and will be communicated to the Supplier as to what the impact will be in scheduling, truck load quantities and delivery frequencies from Supplier to Benteler and vice versa. All the above changes will be agreed to and signed by Benteler and the Supplier, before the change is applied. C 2.2 Manufacturing Location Change All possible changes to the location of where a Benteler production component is produced should be communicated with the Benteler Buyer as early as possible and must have Benteler’s signed approval prior to the change. These changes may affect many documents and departments in the Benteler organization; including PPAP – See Section B. When a previously NAFTA qualified production component or assembly changes the country it is manufactured in, the NAFTA qualification process must be performed again by the supplier. This is necessary because depending on the new manufacturing location, the good may no longer qualify and an updated NAFTA Certificate of Origin or Manufacturer’s Affidavit must be emailed to: [email protected]. C 2.3 Shipping Location Change Changing the shipping location could affect transportation and packaging availability. As soon as it is known that the shipping location may change, Benteler Logistics must be notified. When a previously NAFTA qualified component or assembly changes the shipping location, the NAFTA certificate needs to be reviewed. This is necessary because address shown on the document may no longer be valid, and an updated NAFTA Certificate of Origin or Manufacturer’s Affidavit must be emailed to: [email protected].

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C 2.4 Sub-supplier Change When a previously NAFTA qualified component or assembly changes sourcing, the NAFTA qualification process must be performed again by the supplier. This is necessary because depending on the new manufacturing location, the goods may no longer qualify and an updated NAFTA Certificate of Origin or Manufacturer’s Affidavit (Appendix 06) must be emailed to: [email protected]. This change must also meet the standard AIAG requirements; such as PPAP. C 2.5 New or Modified Tooling The Benteler Buyer shall be notified immediately of any need for a new tool to produce a Benteler production component or any modifications needed to a current tool that is producing a Benteler production component. In most cases the supplier will be required to re-PPAP and the supplier should notify the Benteler SQE in advance and follow the standard AIAG requirements and any specific OEM requirements. New, modified or refurbished tooling could be considered an assist or indirect payment according to Customs Regulations. Refer to Appendix 06 Trade Data Requirements explanation to understand the reporting requirements. Benteler travel costs associated with new or modified tooling driven by the supplier will be at the expense of the supplier. Travel associated with OEM or Benteler new or modified tooling are at Benteler’s expense. C 3.0 Supplier Performance KPI C 3.1 Supplier Performance Expectations Timely delivery of conforming and goods of acceptable quality is a precondition for payment to Supplier. In the event that nonconforming goods are not cured, or a quality issue materially disrupts or deprives the customer of their order, the contract between Supplier and Benteler may be terminated as set forth under the respective contracts or Benteler’s General Terms and Conditions. C 3.2 Logistics KPI Scorecard is in development and will be released to suppliers when complete.

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Section D - Appendix Listing Number Name File Name

01 Supplier Self-Assessment Form

Appendix 01 Supplier Self-Assessment Form

02 Traceability Compliance Letter

Appendix 02 Traceability Compliance Letter

03 Quality Assurance Directive Appendix 03 EK_25_Revision_05_14.5.2009_GB 04 C-TPAT Questionnaire Appendix 04 CTPAT Questionnaire 05 EDI Survey Appendix 05 EDI.Survey.US.2010 06 Trade Data Requirements Appendix 06 Trade_Data_Requirements 07 Product Liability & Recall

Cost Insurance Obligation Appendix 07 Benteler Product Liability & Vehicle Recall Insurance

08 EDI & Barcode Specifications

Appendix 08 BentelerAutomotiveBarcodeLabelSpecs V3.4

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Section E - Glossary Term Description 8D 8-Disciplines Problem Solving Report ACH Automated Clearing House AIAG Automotive Industry Action Group APHIS Agriculture, Animal and Plant Health Inspection APQP Advanced Product Quality Planning ASN Advanced Shipping Notice Call-Off Release, delivery requirements or orders for production components CBP U.S. Customs and Border Protection D&B Duns and Bradstreet is a financial reporting company ECR Engineering Change Request EDI Electronic Data Interchange is a method used to electronically

transfer data eRFQ Electronic request for quote FSB Supplier Feedback form FTZ Foreign Trade Zone IMDS International Material Data System ISO/TS16949 Quality certification program ISO9001 Quality certification program KLT Packaging tote KPI Key Performance Indicator are metrics used to monitor performance MA Manufacturer’s Affidavit MB Mega byte is a unit used to describe the size of an electronic file Mio or MM Million MRO Non-production orders NAFTA North American Free Trade Agreement NAO North American Operations OEM Original Equipment Manufacture Paydex Calculation performed within a D&B financial report PDCA Plan Do Check Act is a process used in problem solving Portal Internet website shared between two or more parties FMEA Failure Mode & Effects Analysis PPAP Production Part Approval Procedure PPM Parts Per Million is a metric used to quantify defects PSW Part Submission Warrant Production Component Components included in the manufacture of our end product RFQ Request for Quotation RGA Return Goods Authorization RMA Return Material Authorization Serial Part Component used during the production phase of a program SQE Supplier Quality Engineer Supplier Base Group of all Benteler suppliers US United State of America USD United States Dollar VAT Value Added Tax VDA Electronic Data Interchange format VDA Verband der Automobilindustrie is a German Automotive Task Force

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