LGL PUR PCH M 02.1 Lucy Electric Global Supplier Manual

Document Title Lucy Electric Global Supplier Manual
Document No. LGL-PUR-PCH-M-02

Reference Document
Issue No. 1 Date: 26/01/2022 Page 1 of 29
Document Control: Uploaded to LIMS on 28/01/2022
LUCY ELECTRIC
GLOBAL SUPPLIER MANUAL
Change History
Date Created Issue Reason for Change

26/01/2022 1 First version
Only for ease of readability, all defined terms (i.e. Supplier, Buyer, Products, etc.) are or may be printed in
throughout this manual in lowercase.
PREPARED BY: M. Pelado & S. Gledhill APPROVED BY: Subhash Nair DATE: 26/01/2022
Please ensure you are using the latest issue of this document by referring to the Documents Master List
Reference Document
Table of Contents
1.0 Terms & Definitions ..................................................................................................................................4
2.0 Doing Business with Us ............................................................................................................................6
2.1 Our Company .......................................................................................................................................6
2.2 Purpose.................................................................................................................................................6
2.3 Business Partner Code of Conduct ......................................................................................................6
2.4 Supplier Diversity ..................................................................................................................................6
3.0 General Supplier Requirements ...............................................................................................................7
3.1 Supplier Quality Management System .................................................................................................7
3.2 Supplier Manual ....................................................................................................................................7
3.3 Customer Communications ..................................................................................................................8
3.4 Document Control .................................................................................................................................8
3.5 Record Retention ..................................................................................................................................9
3.6 Confidentiality .......................................................................................................................................9
3.7 Risk Assessment & Contingency Planning.........................................................................................10
3.8 Environmental, Health & Safety Compliance ......................................................................................10
3.9 Sustainability .......................................................................................................................................10
3.10 Housekeeping .....................................................................................................................................12
3.11 Training ...............................................................................................................................................12
3.12 Customer Approved Sources..............................................................................................................12
3.13 Sub-Supplier Management .................................................................................................................12
3.13.1 Verification of Purchased Products & Services ..........................................................................12
3.13.2 Incoming Product Quality ............................................................................................................13
3.13.3 Sub-Supplier Monitoring .............................................................................................................13
4.0 Supplier Selection & Assessment ...........................................................................................................14
4.1 Supplier Assessment ..........................................................................................................................14
4.1.1 Generic Supplier Process Audit (GSPA) ........................................................................................14
4.1.2 Commodity Specific Process Audit (CSPA) ...................................................................................14
5.0 Advanced Quality Planning.....................................................................................................................16
5.1 Advanced Product Quality Planning (APQP)......................................................................................16
5.1.1 Planning ..........................................................................................................................................16
5.1.2 Product Design and Development (applicable to proprietary supply parts) ...................................16
5.1.3 Product and Process Validation......................................................................................................17
5.1.4 Production Launch ..........................................................................................................................17
5.2 Customer-designated Special Characteristics....................................................................................17
5.3 Measurement System Analysis ..........................................................................................................18
5.4 Calibration and Verification Records ..................................................................................................18
5.5 Product Approval Process ..................................................................................................................18
5.6 Laboratory Requirements ...................................................................................................................20
5.7 Production Monitoring .........................................................................................................................20
5.7.1 Layout Inspection ............................................................................................................................20
5.8 Change Control ...................................................................................................................................20
5.9 Preventive & Predictive Maintenance .................................................................................................21
5.10 Customer-owned Assets .....................................................................................................................21
5.11 Identification & Traceability .................................................................................................................22
5.12 Preservation of Material / Packaging ..................................................................................................22
5.13 Statutory & Regulatory Conformity .....................................................................................................23
6.0 Non-Conforming Product (suppliers processes).....................................................................................24
6.1 Control of Non-Conforming Product (suppliers processes) ................................................................24
6.2 Lucy Electric issued Non-Conformances (NCR) and Corrective Actions ...........................................25
6.2.1 Controlled Shipping ........................................................................................................................25
6.3 Problem Solving ..................................................................................................................................26
6.4 Cost of Poor Quality (COPQ) Recovery .............................................................................................26
6.5 Customer Waiver/Concession ............................................................................................................27
Reference Document
6.6 Continuous Improvement ....................................................................................................................27

7.0 Customer Satisfaction .............................................................................................................................28
8.0 Global Logistics ......................................................................................................................................28
8.1.1 Transport.........................................................................................................................................28
8.1.2 Standard Routing Instructions ........................................................................................................28
8.1.3 Returnable Packaging ....................................................................................................................28
8.1.4 Shipment of Hazardous Materials and Dangerous Goods .............................................................28
Reference Document
1.0 Terms & Definitions
Term Definition
Systematic, independent and documented process for obtaining and objectively
Audit evaluating evidence to determine the extent to which criteria are fulfilled.
Buyer Buyer shall mean the Lucy Electric legal entity identified as the Buyer in the applicable
contracting document (e.g., purchase order or supply agreement). The term “buyer” is
used interchangeably with the term "Lucy Electric" in the Global Supplier Manual. The
term "Lucy Electric" or "buyer", as defined above, may include one or more Strategic
Business Units (SBU)
Process The maximum amount of inherent variation in a process. A statistical study performed on
Capability a process to determine if it is capable of meeting the precision and/or accuracy according
to specifications (Cp, Cpk, Pp, Ppk and Sigma values)
Confidential 1) Information, knowledge or data disclosed by buyer to supplier, regardless of whether

Information disclosed in written, tangible, oral, visual or other form, including, without limitation,
sample products, equipment, software, or other objects or material, provided by buyer to
supplier, and 2) information, knowledge or data which was obtained from visits to buyer
facilities by supplier.
Control Plan Methodology to ensure all process outputs remain in a state of control. The plan is used
and maintained throughout the product life cycle and is responsive to changing
conditions via written descriptions of the actions required at each phase of the process
from receiving through shipping.
Safety / Product / Special Characteristics: Any product feature, component, material, assembly or complete
Process Special system which is selected for production and field traceability in order to satisfy safety
Characteristics reporting requirements, regulatory requirements, or to support reliability analysis of high
cost / high interest items.
Defect / Non- Non-fulfillment of a requirement related to an intended or specified use, including safety
Conformance considerations and regulatory requirements.
Deliverable See Product definition.
FMEA Failure Modes and Effects Analysis: A preventive analytical technique to methodically
study the cause and effects of potential failures in a product or a process. The product or
process is examined for all the ways in which a failure can occur. For each potential
failure, an assessment is made of its effect on the system and its seriousness, and a
review is made of the action being taken (or planned) to minimize the probability of
failure or to minimize the effects of the failure.
Transport The Incoterms rules are intended primarily to clearly communicate the tasks, costs, and
risks associated with the transportation and delivery of goods.
Reference Document
Term Definition
International Organization for Standardization: An international technical specification for
ISO-9001 quality management systems
Special event resulting from products or services that do not meet the agreed quality and
delivery specifications. Results in non-standard operations including: Quality Spills
Major Disruption (product out-of-spec, stop shipments, production interruption, etc.) and Stock Outs
(product not available).
New Business Hold: A control that prevents suppliers from quoting or receiving new
business until conditions are satisfied to address deficiencies identified by Lucy Electric.
NBH
The supplier may be removed from the approved supplier list.
Lucy Electric Product Development Process: Enterprise wide process to deploy world-
class standard product development processes; use systematic feedback for continuous
PDP improvement; implement a common approach to project and program management;
Invest in our employees’ capabilities.
Production Part Approval Process: Defines generic requirements for production part
approval, including production and bulk materials. The purpose of the PPAP is to
determine that customer engineering design record and specification requirements are
PPAP properly understood by the supplier. The supplier shall demonstrate that the
manufacturing processes have the potential to produce product consistently meeting
these requirements during an actual production run at the quoted production rate.
Parts Per Million: Reject rate determined by number of parts rejected divided by the
PPM number of parts provided times 1,000,000.
Action to eliminate the cause of a potential non-conformance or other undesirable

Preventive Action
situations.
The term “product” used in the Lucy Electric Global Supplier Manual refers to any kind of
product or service. This includes the physical “manufactured” product, a provided
service, engineering work such as drawings and specifications or any other internal
Product
product provided in a series of processes. The term "deliverable" is used
interchangeably with the term product in the Global Supplier Manual.
Part Submission Warrant: The warrant contains supplier, part information, required
documentation, the supplier application warrant and disposition. The submission
PSW
approval authorizes the supplier to start production based on PO requirements.
Quality Management System: A formalized system that documents the structure,

responsibilities and procedures required to achieve effective quality management. It is
QMS
based on the requirements detailed in ISO-9001:2008 with additional enhancements.
Non-Conformance Report: A formal request to take action to eliminate the cause(s) of an

NCR existing non-conformance or other undesirable situation in order to prevent recurrence.
Supplier: shall mean the legal entity identified as the supplier in the applicable
Supplier contracting document (e.g., purchase order or supply agreement).
Reference Document
2.0 Doing Business with Us
2.1 Our Company
Lucy Electric is a leader in secondary power distribution solutions and specialise in high-performance medium
voltage switchgear for utility, industrial and commercial applications. Our products are at the cutting edge of
medium voltage design and innovation, providing switching, protection and automation solutions with
reliability, safety and value built-in as standard.
With its headquarters in the UK, Lucy Electric have sales and manufacturing operations in Saudi Arabia,
United Arab Emirates, South Africa, India and South East Asia and through associations with industrial
partners and contractors, has an established international reputation for excellence in over 50 countries.
Suppliers should visit our website (www.lucyelectric.com)
2.2 Purpose
The Global Supplier Manual defines the expectations for all Lucy Electric suppliers. The supplier shall meet or
exceed the requirements and guidelines defined in this manual, as long as it provides products and/or
services to Lucy Electric and its customers.
Adhering to the guidelines established in this manual, the supplier should continually improve the processes
used to design, manufacture, and deliver products or services to Lucy Electric.
Throughout this manual, the word “shall” or “must” indicates a requirement. The word “should” indicates a
recommendation.
The English version of this manual is the official version. The English version has precedence in the event of
discrepancies with manuals translated into different languages.
2.3 Business Partner Code of Conduct
The supplier shall adopt and comply with the Lucy Electric Code of Conduct for suppliers (COC). The supplier
shall take all steps necessary to ensure that its sub-suppliers and subcontractors comply with the COC. At the
supplier’s request, the buyer will mail the supplier a hard copy. The COC may be amended by Lucy Electric
from time to time.
This requirement is covered through agreements with each supplier. The supplier will only be registered in
Lucy’s ERP system once all required documentation is submitted, reviewed and approved.
2.4 Supplier Diversity
Lucy Electric recognizes the value of diversity in its workforce and supply chain. Lucy Electric’s Supplier
Diversity Program includes minority, women, and veteran -owned businesses, both large and small. Each
procurement team has direct responsibility to search for and develop diverse-owned businesses.
Reference Document
3.0 General Supplier Requirements
The term supplier includes suppliers of products and services (together called "products" or "deliverables" in
this manual) and distributors that provide deliverables to Lucy Electric. The term supplier also includes
suppliers of both custom and commercially available products. The supplier shall:
▪ Satisfy the requirements established in this manual

▪ Maintain a working knowledge of all policies and procedures governing the relationship between the
supplier and Lucy Electric
▪ Obtain the latest version and be knowledgeable of all documents referenced in this manual. Ref
APQP/PPAP Guidelines
▪ Accept responsibility for the quality, on-time delivery, regulatory compliance, and technical
performance of all deliverables
▪ Meet Lucy Electric’s drawing requirements for Lucy designed parts
▪ Supplier’s production shall comply to the proprietary datasheets, drawings, Model type, specifications,
etc. which were agreed with Lucy Electric when approval was granted. In case of any change in
specific parameters within proprietary datasheets then it should be notified to Lucy and obtain
acceptance of change.
In the event of a conflict between the terms of this manual and any buyer purchase order or other contract
between the parties, unless the parties agree otherwise in writing, the various components of the agreements
shall be given the following precedence (in descending order of precedence): 1) the Supply Agreement, if any;
2) a purchase order; 3) an applicable country/region supplement to the buyer's terms and conditions of
purchase; 4) the buyer's terms and conditions of purchase and 5) the Global Supplier Manual. Subsequent
requirements may take precedence based upon:
▪ Customer, market, or site- specific operating conditions
The supplier shall be responsible for ensuring all sub-tier suppliers adhere to these requirements.
At Lucy Electric’s discretion, a waiver of certain manual requirements may be granted and approved for a
specific product or duration. All such waivers shall be effective only upon express written approval by Lucy
Electric.
3.1 Supplier Quality Management System
The supplier shall establish and maintain an effectively documented Quality Management System (QMS) that
satisfies the requirements defined in this manual. The QMS must communicate, identify, coordinate and
control all activities necessary to design, develop, produce and deliver a quality product or service to Lucy
Electric and/or its customers.
The supplier shall be compliant with one of the following international quality management standards:
ISO9001 or ISO/TS16949 latest revision. The supplier may be registered by a recognized, independently
certified third-party certification body. Lucy Electric may request a copy of the certificate when applicable. Lucy
Electric may conduct an audit of the supplier’s QMS. An audit shall be required to verify the supplier’s QMS if
the supplier has not achieved compliance or is not certified. The supplier shall notify Lucy Electric of any
significant changes in their QMS including loss of certification
3.2 Supplier Manual
The supplier shall maintain a Manual that includes:
▪ Supplier’s Management System

▪ Supplier’s Management System policy and objectives
▪ Documented procedures
▪ Record retention policy
Reference Document
The supplier’s management shall be engaged to ensure compliance and continuous improvement of the
requirements outlined in their Manual. The supplier shall provide a copy of their current Manual when
requested by Lucy Electric.
3.3 Customer Communications
The supplier shall communicate essential business information to Lucy Electric. Such information may pertain
to contractual issues including, but not limited to:
▪ Inquiries, orders, bids, amendments and invoices

▪ Product quality issues relating to design, specifications, changes and notifications
▪ Delivery delays and/or shortages
▪ Customer feedback and information
Other elements of essential information relating to changes in the supplier’s business environment must be
communicated immediately, such as:
▪ Acquisitions
▪ Partial Sale
▪ Change of control/executive management
▪ Pending litigation
▪ Restructuring
▪ Administration
▪ Bankruptcy
The effective transmission of such information requires that all suppliers identify and register key points of
contact with their Lucy Electric counterparts. The majority of the communication shall be handled through
electronic documents and systems. The supplier should adopt the necessary electronic systems to manage
these processes and improve communications with Lucy Electric. The supplier is responsible for the validity
and accuracy of the documents submitted electronically and must comply with all applicable legal
requirements regarding electronic signatures.
All communications, both electronic and otherwise, with Lucy Electric shall be in English. A specific Lucy
Electric facility may allow exceptions for direct communications meant for that facility only.
3.4 Document Control
The supplier shall establish and maintain procedures to ensure that applicable documents related to the QMS
are updated, approved for use, available at points of use and controlled in a consistent manner. The supplier’s
procedures shall include provisions for Lucy Electric design-owned documentation. A master list of documents
including the current revision level shall be maintained for all Lucy Electric parts to prevent use of invalid or
obsolete documents. When POs are received from Lucy Electric, each part listed in the PO has a revision
number which must be verified against the master list as a part of the PO acknowledgement process. Any
discrepancies shall be notified immediately to Lucy Electric and sought for revised drawings or agreement to
supply parts against earlier revision. The supplier shall maintain a record of each change implemented.
When the supplier has design responsibility, Lucy Electric may request any documentation including drawings,
engineering standards, and specifications. The supplier shall notify Lucy Electric of any changes by submitting
a Supplier Process and Design Change Request before implementing the changes as those may affect form,
fit and function within Lucy’s products. Refer to section 5.8 Change Control for additional information.
Obsolete documents shall be destroyed or appropriately identified as such.
Reference Document
3.5 Record Retention
The supplier shall establish and maintain records to provide evidence of regulatory compliance and Lucy
Electric requirements. Retention policies shall define requirements for paper and electronic records. The
records shall be:
▪ Legible
▪ Stored in an environment that prevents document deterioration
▪ Readily accessible upon request
The supplier’s employees, contractors, and agents who create, receive, use or manage these records are
required to comply with the policies and procedures in accordance with customer, warranty, legal and
regulatory requirements.
Lucy Electric requires the supplier to maintain all records relating to deliverables provided for the life of the
product plus one (1) calendar year and any applicable contractual requirements, including but not limited to
those for warranty and service for the purpose of this manual, unless otherwise specified. The life of the
product begins with product concept and extends until the end of active part production and service
requirements. Lucy Electric may notify the supplier when a product is no longer considered an active part. The
supplier shall provide records to Lucy Electric when requested.
The sections of this manual that require records shall conform to this retention policy.
3.6 Confidentiality
The supplier shall use Confidential Information solely for the purposes of supporting the current business
relationship with Lucy Electric. The supplier shall not disclose Confidential Information to any third party
without buyer’s express written consent, except that the supplier may disclose Confidential Information to its
contractors, sub-suppliers, consultants or agents who have a need to know and have executed confidentiality
agreements with the supplier, obligating them to treat such information in a manner consistent with these
Terms and Buyer’s Non-Disclosure Contract, if any, with supplier. The supplier shall not i) sell buyer parts or
components incorporating or containing Confidential Information to any third party, or ii) sell any deliverables
produced using Confidential Information to any third party.
Notwithstanding the foregoing, the foregoing shall not restrict or affect supplier’s rights to use or disclose
information: i) which is or may hereafter be in the public domain through no fault of supplier; or ii) which
supplier can show, as reflected by its written documents, was known to it prior to the disclosure by buyer; or
iii) which is disclosed to supplier by a third party, with the legal right to disclose, subsequent to buyer’s
disclosure; or iv) which supplier can show, as reflected by its documents, was independently developed by
supplier without the use of the Confidential Information.
The supplier acknowledges that a breach of this Section 2.6 would result in immediate and irreparable harm to
Lucy Electric, for which there is no adequate remedy at law. The buyer is entitled to equitable relief compelling
supplier to cease and desist all unauthorized use and disclosure of Confidential Information. The supplier shall
immediately notify buyer of any breach of confidentiality.
Throughout the period of production and service, the supplier shall prevent improper use, loss, or damage to
all Lucy Electric Confidential Information. At the conclusion of the defined retention period, the supplier shall
return or securely dispose of electronic and hard media copies of all such Lucy Electric documents. Refer to
section 2.5 Record Retention for additional information.
Reference Document
3.7 Risk Assessment & Contingency Planning
The supplier shall conduct a risk assessment of their operations that support Lucy Electric’s production
facilities, quality requirements, and delivery schedules. Each assessment should consider, at a minimum, the
impact arising from:
▪ Natural disasters
▪ Geo-political hazards
▪ Supply chain disruptions
▪ Facility or system issues
▪ Information loss
▪ Intellectual property claims
▪ Personnel concerns, including specialized skills
▪ Equipment problems
The supplier shall prepare contingency plans to ensure continued operations at Lucy Electric. The supplier
shall communicate any critical risk scenario without a contingency plan that may result in a Major Disruption.
The supplier shall provide the contingency plans to the buyer when requested. Refer to Section 5.8 Change
Control for additional information.
3.8 Environmental, Health & Safety Compliance
Lucy Electric is committed to sound Environmental, Health and Safety (EH&S) operating practices including:
▪ Decreased use of hazardous substances

▪ Reduced waste and emissions
▪ Improved energy and water conservation
▪ Greater reuse and recycling of materials
▪ Safe and healthy work environments that prevent accidents and injuries
▪ Continuous improvement in EH&S performance
Lucy Electric suppliers are encouraged to actively implement globally recognized Environmental, Health and
Safety management systems. A robust EH&S program reduces operational impact on human health and the
environment in a sustainable manner. Recommended programs include, but are not limited to:
▪ Occupational Safety and Health Administration (OSHA) VPP

▪ ISO 14001
▪ ISO 45001
The supplier shall work with Lucy Electric to reduce the impact of packaging waste through:
▪ Reduction or elimination of unnecessary over packaging

▪ Implementation of returnable packaging
▪ Substitution of current packaging materials for recyclable materials
The supplier shall comply with all applicable EH&S regulations. The supplier shall adhere to and comply with
the environmental policy found on our website at:
https://www.lucyelectric.com/about-us/quality-environment-and-health-and-safety-policy-statement/
3.9 Sustainability
Legal and Regulatory Compliance
Suppliers are to ensure their operations and the products and services supplied to Lucy Electric comply with
all local and other applicable laws and regulations.
Reference Document
Environmental Performance Improvement
Suppliers are to understand and reduce the environmental impacts of their operations and of the products and
services they provide to Lucy Electric. This will include programs that promote efficient and responsible use of
energy, water, and other resources; promote utilization of renewable energy; minimize the use of hazardous
materials; promote reuse and recycling, and reduce emissions to air, soil, and water, including greenhouse
gas (GHG) emissions, as well as, striving to achieve net-zero carbon. Lucy electric will work with their
suppliers to lead and support their journey towards net-zero carbon.
Conflict Minerals
Suppliers are expected to ensure that parts and products supplied to Lucy Electric are DRC conflict-free (do
not contain metals derived from “conflict minerals”; columbite tantalite (tantalum), cassiterite (tin), gold,
wolframite (tungsten), or their derivatives such that they do not directly or indirectly finance or benefit armed
groups through mining or mineral trading in the Democratic Republic of the Congo or an adjoining country.
Suppliers are to establish policies, due diligence frameworks, and management systems, consistent with the
OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-
Risk Areas, that are designed to accomplish this goal.
Cobalt
Battery-related direct suppliers to Lucy Electric are to establish policies, due diligence frameworks, and
management systems consistent with the OECD Due Diligence Guidance for Responsible Supply Chains of
Minerals from Conflict-Affected and High Risk Areas, designed to respond to and mitigate child labor risks
associated with cobalt mineral sourcing. Suppliers are expected to survey their supply chain and if applicable
report to Lucy Electric cobalt sourcing information relevant to Lucy Electric production.
Management Systems
Suppliers are to maintain effective management systems that integrate environmental, occupational health
and safety, human rights and labor, and ethics policies into their business and decision-making processes.
This includes establishing appropriate objectives and targets, regularly measuring and assessing
performance, and practicing continual improvement.
Transparency
Suppliers shall disclose to their point of contact at Lucy Electric within 48 hours of any such incident:
1. All supplier on-site incidents of worker fatality or accidents resulting in debilitating injury.
2. All known supplier off-site incidents of worker fatality or injury resulting from suicide or suicide attempt.
3. Any actual or alleged priority finding related to Lucy Electric Supplier Code of Conduct compliance
whether discovered by Supplier or by a third party including, but not limited to:
a. underage workers,
b. forced labor,
c. health and safety issues posing immediate danger to life or risk of serious injury,
d. significant excessive overtime as defined by local regulations, and/or
e. violation of environmental laws posing serious and immediate potential or actual harm to the
immediate or surrounding community.
In addition, suppliers are to provide clear, timely, accurate and appropriate reporting to Lucy Electric upon
request.
Substance of Initial Disclosure; Protecting Privacy: Suppliers shall in the first instance disclose to Lucy Electric
only that an incident (as described in 1-3 above) has occurred and provide basic information regarding the
incident. To protect the privacy of individuals involved, initial disclosures should be made without reference to
Personal Data. Should Lucy Electric require additional information, Suppliers shall comply with all applicable
data protection and privacy laws when transferring or sharing information with Lucy Electric.
Reference Document
"Personal Data" shall mean any information related to any identified or identifiable natural person, including
but not limited to employees and customers of the parties, and any other data deemed as personal data under
applicable personal data protection or privacy laws.
In selecting and retaining qualified suppliers, Lucy Electric will show preference to suppliers that meet the
above requirements and Lucy Electric’s Supplier Code of Conduct.
3.10 Housekeeping
The supplier shall adopt a cleanliness standard. The standard shall create a state of order consistent with the
requirements of the deliverables provided to Lucy Electric. The standard shall include a process for
establishing and maintaining a clean work environment. Lucy Electric recommends the 5/6S program to
establish the standard.
3.11 Training
The supplier shall provide appropriate training to ensure that employees are competent and qualified to
produce quality deliverables. The supplier shall review and document the required skills and competencies
necessary for the production, inspection, handling, and delivery of products to Lucy Electric and/or its
customers. The supplier shall provide appropriate training to ensure that employees follow applicable
procedures and instructions. The supplier shall maintain employee records of training, performance metrics,
and skills. Records of training should clearly identify training related with safety critical manufactured parts.
3.12 Customer Approved Sources
The supplier shall purchase products from Lucy Electric approved sources, when specified by the contract.
The use of Lucy Electric approved sources, including tooling and gauging suppliers, does not relieve the
supplier of the responsibility for ensuring the quality of purchased products. The supplier shall be responsible
for managing all aspects of the relationship with the approved source including:
▪ Quality of product or service

▪ Technical performance
▪ Source of materials
▪ On-time delivery
3.13 Sub-Supplier Management
The supplier shall define expectations for each sub-supplier including:
▪ Support of APQP and PPAP requirements (see guidelines)

▪ Identification of their role in the supplier’s and Lucy Electric’s products and processes
▪ Involvement in problem solving and corrective actions
The supplier shall work with sub-suppliers in order to meet the requirements provided in this manual. Areas of
emphasis include:
▪ Verification of purchased products

▪ Incoming product quality
▪ Sub-supplier monitoring
Any changes in sub-suppliers shall be notified to Lucy Electric and only after approval from Lucy, the new sub-
supplier can be used in production supply.
3.13.1 Verification of Purchased Products & Services
For each sub-supplier, the supplier shall establish and implement methods, processes, and systems to verify
that all deliverables comply with Lucy Electric requirements. The supplier shall complete this verification
Reference Document
process prior to use for all deliverables provided to Lucy Electric. Consistent methods used for verification
may include:
▪ Control plans
▪ Standard work instructions
▪ Regular inspection
▪ Functional testing
▪ Audits
To ensure on-going product quality, Lucy Electric may conduct an audit to verify product at the supplier or
sub-supplier facility. The scope of each audit will be at the sole discretion of Lucy Electric. Lucy Electric shall
notify the supplier of the planned date of the audit. The supplier must notify the sub-supplier of this
requirement. Any verification performed by Lucy Electric does not relieve the supplier of the responsibility to
provide quality products.
3.13.2 Incoming Product Quality
The supplier shall implement a process to ensure the quality of incoming deliverables meets Lucy Electric’s
requirements. The process should incorporate standard methods including:
▪ Statistical data evaluation from the sub-supplier

▪ Performance-based receiving inspection
▪ Testing based on approved sampling plans
▪ Supplier audits or assessments coupled with records of acceptable delivered product quality
▪ Part evaluation by an approved laboratory
▪ Other methods approved by Lucy Electric
All non-conforming material resulting from this process shall be identified and quarantined. The supplier and
sub-supplier shall have a process to disposition non-conforming product.
3.13.3 Sub-Supplier Monitoring
The supplier should collect objective data on the performance of its sub-suppliers. This data should be used to
generate a performance ranking or scorecard. Performance metrics may include:
▪ Delivered product quality – Nonconforming Parts Per Million (PPM)

▪ Delivery schedule performance with incidents of premium freight
▪ Lead-time improvement
▪ Major Disruptions
▪ Special status notifications from sub-supplier pertaining to quality or delivery issues
Continuous improvement activities should be driven by a sub-supplier’s performance against such metrics.
In some cases, sub-supplier performance monitoring may not be conducted due to the business, product or
other quality considerations. The supplier may be required to notify Lucy Electric of such exceptions.
Reference Document
4.0 Supplier Selection & Assessment
Lucy Electric expects the supplier to:
▪ Abide by our Code of Conduct

▪ Provide high quality products that meet or exceed expectations
▪ Provide products at a competitive price
▪ Deliver products on-time
▪ Maintain financial strength to support current business and promote growth
Lucy Electric shall verify compliance during the selection and assessment process.
4.1 Supplier Assessment
Lucy Electric may conduct an On-Site Assessment (OSA) of the supplier’s QMS, documentation and
manufacturing facilities based upon criteria established in Lucy Electric’s Supplier Self-Assessment Form. The
OSA is generally conducted for potential new suppliers or an existing supplier’s new facility. An OSA may be
conducted if a supplier has not had an Audit / Visit by Lucy Electric Quality in the last two (2) years. The OSA
shall be conducted in person at the supplier’s manufacturing facility. A Technical Assessment (TA) of the
supplier may be required in addition to the OSA for new suppliers. The TA evaluates the supplier’s capability
to manufacture the potential product.
Lucy Electric shall share the results of the OSA with the supplier and provide a status of:
▪ Approved – the supplier may be awarded new business and will be added to the approved supplier list
▪ Conditionally approved – the supplier may be awarded new business, pending acceptable corrective
actions are implemented, and may be added to the approved supplier list
▪ Not approved – the supplier fails to meet the requirements and Lucy Electric shall not award new
business or may be removed from the approved supplier list
The OSA and TA status is manufacturing site specific. Lucy Electric reserves the right to conduct more
frequent audits and to enter the supplier’s facilities to perform an audit. Lucy Electric shall notify the supplier of
the planned date of the audit. If the supplier plans to transfer Lucy parts’ manufacturing to a different new or
existing location, the Supplier must notify Lucy and seek approval before starting production parts/assemblies
from the new manufacturing location. This is typically done through a new PPAP submission. More details on
the OSA can be found through the following Lucy Electric procedures:
New suppliers application process and approval – Ref LGL-PUR-PCH-P-03

Procedure for selection of approval methodology for parts and assemblies – Ref LGL-PUR-PCH-P-03
Control of externally provided processes, products and services – LGL-PUR-PCH-P-04 / LGL-PUR-PCH-P-05
4.1.1 Generic Supplier Process Audit (GSPA)
Lucy Electric may conduct an on-site Generic Supplier Process Audit (GSPA) at the supplier and/or its sub-
suppliers. The GSPA ensures the process meets Lucy Electric’s requirements for capability and error
detection and prevention. All processes will be reviewed based on:
▪ Continuous improvement
▪ New or changed processes
▪ Support for global procurement strategy
4.1.2 Commodity Specific Process Audit (CSPA)
Certain manufacturing processes cannot be verified using normal monitoring and measurement techniques.
The deficiencies are only apparent after the product is in use or by utilizing destructive verification methods.
These processes include heat treatment, welding, brazing, plating, painting, coating, etc. The supplier must
Reference Document
demonstrate the ability to control the elements of these processes to achieve the defined results. The supplier
shall establish verification methods for these processes, as applicable:
▪ Defined criteria for review and approval of the processes

▪ Approval of equipment and documented capability assessments
▪ Documentation of training, previous experience and qualification of personnel
▪ Use of specific methods and procedures
▪ Requirements for records
▪ Revalidation of the processes
After the start of production, the audit is a method for identifying continuous improvement ideas and helping
with problem solving.
Reference Document
5.0 Advanced Quality Planning
The identified suppliers shall develop the processes required for the quality planning of product. In the
planning of product, the supplier shall work with Lucy Electric to:
▪ Develop quality objectives and requirements for the product

▪ Establish processes, documents, and provide resources
▪ Determine required verification, validation, monitoring, inspection and test activities and the criteria for
acceptance
▪ Define records required to provide evidence of product conformity
5.1 Advanced Product Quality Planning (APQP)
Identified suppliers shall implement a framework that ensures robust product and process development
capabilities. Advanced Product Quality Planning (APQP) provides a proven and disciplined approach that
meets Lucy Electric’s deliverable requirements. The process should be implemented from initial product
concept and continue through the production launch phase of the project.
The supplier shall establish periodic internal reviews during the design and development process and the
production launch. The supplier shall evaluate quality risks, costs, lead-times, critical paths and other items as
appropriate throughout the entire APQP process. The reviews shall:
▪ Monitor progress of the design and development of deliverables

▪ Evaluate the results compared to the product requirements
▪ Identify potential problems and develop corrective actions
▪ Analyze the product and/or process utilizing FMEA methodology
▪ Provide input for management reviews
Lucy Electric may request the results of reviews based upon potential risk that a product has to Lucy Electric’s
business or products.
It is in Lucy Electric’s discretion to require the supplier to seek formal training in the APQP methodology such
as the APQP4Wind Specialist training available from the APQP4Wind organization.
5.1.1 Planning
The supplier shall develop a project plan with:
▪ Project tasks, target dates and assigned responsibilities

▪ Time allocated for completing initial designs, supplier selection, product development, testing, tool
design, manufacturing, supplier production try-outs and Production Part Approval Process (PPAP)
▪ Sample requirements, PPAP quantities, and delivery dates
▪ Lucy Electric Product Development Process (PDP) alignment when applicable
5.1.2 Product Design and Development (applicable to proprietary supply parts)
When design responsible, the supplier shall complete the initial product design and maintain a record of all
changes for each product. Lucy Electric shall be notified of all changes impacting product form, fit function or
potential influence on user experience. All changes shall be reviewed, verified and validated, prior to the
implementation and acceptance by Lucy Electric. The review of design changes shall include an evaluation of:
▪ Product and mating parts in the assembly

▪ Manufacturing and downstream processes
▪ Purchasing costs
The supplier shall verify that the product meets the requirements established during the planning activities.
Design verification shall be conducted independent of the responsible design team. The verification results
Reference Document
shall be reviewed periodically with management. The supplier may be required to participate in design reviews
with the Lucy Electric project team.
5.1.3 Product and Process Validation
The supplier should begin the Product and Process Validation phase of APQP when the tooling, capital
equipment and/or gauging is delivered. The supplier shall test and verify that their process outcomes satisfy
the designs and/or specifications derived in the Product Design and Development phase. The process
capacity shall meet the contracted production rate prior to acceptance.
Lucy Electric may specify the validation plan when it has design responsibility. When the supplier has design
responsibility, Lucy Electric reserves the right to approve the validation plan. The supplier shall perform the
validation testing. The testing shall ensure the resulting product satisfies the requirements for the application
and its intended use. The supplier’s engineering function shall define and finalize specific test procedures to
validate the design. The supplier is responsible for any outsourced services used in the validation process.
Refer to section 4.13 Statutory & Regulatory Conformity for additional requirements.
Production intent materials, tooling, processes and sub-suppliers should be used to produce products for
validation testing. Lucy Electric may require product for testing requirements.
Lucy Electric shall approve parts via the PPAP submission. The supplier shall not ship any production parts
until signed approval is received from Lucy Electric per agreed method or documentation (i.e. Part Submission
Warrant). Refer to section 5.5 Product Approval Process.
5.1.4 Production Launch
The supplier begins the Production Launch phase of the APQP when PPAP approval or interim approval is
provided by Lucy Electric. The supplier shall utilize the Early Launch Containment methodology to reduce risk
and improve quality prior to product delivery.
Once the production process has stabilized, Lessons Learned and Best Practices can be documented and
reviewed.
5.2 Customer-designated Special Characteristics
Lucy Electric drawings and specifications may designate product features as Special Characteristics, Critical-
to-Quality or other designations. These features may be designated by various symbols depending on Lucy
Electric site. Typically, these characteristics influence:
▪ Product form, fit or function

▪ Compliance to regulations
▪ Safety requirements
▪ Customer satisfaction
The supplier shall demonstrate process capability through statistical controls for all designated special
characteristics and maintain control for all measurement methods used. The target process capability for
special characteristics shall be (Cp, Cpk, Pp, Ppk):
▪ Short-term: greater than or equal to 1.67

▪ Long-term: greater than or equal to 1.33
The Lucy Electric site may define the exact process capability requirements for each special characteristic. If
no special characteristics are defined, the supplier shall determine which product and/or process characteristic
should be used to evaluate capability. Lucy Electric reserves the right to approve the characteristics selected
for evaluation. Lucy Electric shall define the requirements in the PPAP request letter when the volume does
not support conducting a process capability study.
Reference Document
For any deviation of process capability, the supplier shall initiate an internal corrective action plan, including
100% inspection, when process capability is not met. The supplier shall maintain records of all corrective
actions.
5.3 Measurement System Analysis
The purpose of the Measurement System Analysis (MSA) is to assess the accuracy, repeatability, and
reproducibility of each measuring device used in the manufacture of products supplied to Lucy Electric. The
supplier shall implement a procedure to evaluate each type of measurement system. An MSA shall be
conducted on all new or modified measurement systems. Analytical methods and acceptance criteria shall
conform to Lucy Electric requirements. The supplier shall develop a corrective action for any measurement
system found that does not meet the requirements, including:
▪ Containment of suspect and non-conforming products

▪ Notification to Lucy Electric of affected products
▪ Potential last good inspection/calibration/MSA date
▪ Interim corrective action
▪ Repair, replacement and/or recovery plans
▪ Certification by outside source
Lucy Electric may request MSA results and/or sample parts from the supplier to perform comparative
correlation studies with the supplier’s measurement results.
5.4 Calibration and Verification Records
The supplier shall implement a calibration and verification system or procedure to ensure all gauges, jigs,
fixtures, poka-yoke devices, measuring and testing equipment are qualified at defined frequencies. All
measuring and test equipment must be:
▪ Identified with unique traceability and qualification status

▪ Calibrated and/or verified at a specified frequency to approved standards
▪ Adjusted or re-adjusted, as required
▪ Prevented from improper adjustment
▪ Protected from damage during use, handling and storage
Records shall be maintained for all gauges, measuring and testing equipment including:
▪ Equipment identification and calibration standard

▪ Revisions for engineering changes
▪ Any out-of-specification readings
▪ Impact assessment for out-of-specification condition
▪ Statements of conformity after calibration or verification
The supplier shall notify Lucy Electric of potential suspect product when an out-of-calibration condition is
detected after production launch. The supplier shall take appropriate actions to prevent further use of
discrepant product at Lucy Electric. All suspect products at the supplier must be identified and quarantined.
Refer to section 6.0 Non-Conforming Product for additional information.
Computer software and its application shall be verified and documented on a regular basis when used for
monitoring or measuring product conformity.
The supplier should reference ISO 17025 as a guideline for compliance.
5.5 Product Approval Process
Lucy Electric utilizes the PPAP requirements for product approval. All suppliers shall comply with these
requirements for all new products and any approved changes to production parts. Lucy Electric shall
Reference Document
determine the PPAP level required. The Lucy Electric PPAP owner shall work with the supplier to define the
PPAP submission supporting data via the Part Submission Warrant (PSW) and the PPAP production run
quantity. The PPAP run parts and the supporting data should be conducted utilizing production intent process.
Reference the PPAP chart for submission requirements:
High Risk Highest level of risk and most demanding on

documentation required from supplier. Level of
documentation is discussed and agreed at Kick-off
meeting. See example below.
Medium Risk Medium level of risk and documentation required from
supplier. Level of documentation is discussed and
agreed at Kick-off meeting. See example below.
Low Risk Lowest level of risk and documentation required from
supplier. Level of documentation is discussed and
agreed at Kick-off meeting. See example below.
PPAP documentation matrix High Risk Medium Risk Low Risk

Doc. Submit Doc. Submit Doc. Submit
Retain Retain Retain
1 Product Quality Plan M S M S TBA TBA
2 Team Feasibility Commitment, TFC M S M S TBA TBA
3 Design Failure Mode & Effect Analysis, M S M TBA TBA TBA
DFMEA 3)
4 Part History M S M S M R
5 Customer Engineering Approval M S M S M R
6 Process Flow Chart M S M S TBA TBA
7 Factory Floor Plan M S M TBA TBA TBA
8 Process Failure Mode & Effect Analysis, M S M S TBA TBA
PFMEA
9 Control Plan M S M S TBA TBA
10 Process Capability Studies M S M TBA TBA TBA
11 Performance Test Report M S M TBA M R
12 Material Test Report M S M S M R
13 Dimension Test Report M S M S M R
14 Appearance Approval Report M S TBA TBA TBA TBA
15 Measurement System Analysis M S M TBA TBA TBA
16 Packaging Test Report M S M TBA M R
17 Product and Master Sample M TBA M TBA TBA TBA
18 Part Submission Warrant, PSW M S M S M S
19 Part Submission Warrant, Deviation Sheet M S M S M S
20 Safety Data Sheet M S M S M S
21 Form, Fit and Function M S M TBA M S
22 Qualified Laboratory Documentation M TBA TBA TBA TBA TBA
23 List of Checking Aids M TBA M TBA TBA TBA
24 Sub Supplier Source Details M TBA M TBA M R
The supplier shall refer to the PPAP workbook provided by Lucy Electric.
Lucy Electric will provide a status of:
▪ Product and Process Approved as Submitted – the product or service meets all requirements and the
supplier is authorized to deliver production quantities.
Reference Document
▪ Conditionally Approved – the product or service may be delivered for a specific time or quantity while
the supplier implements the required corrective actions. The supplier must re-submit the PPAP to
Lucy Electric for approval.
▪ Not Approved – the product or service fails to meet the requirements and the Supplier is not
authorized to deliver the product or service. After implementing the corrective actions identified, the
supplier must re-submit the PPAP to Lucy Electric for approval.
Lucy Electric shall notify the supplier of the concerns and/or issues that result in a product status of Interim
Approval or Rejected.
5.6 Laboratory Requirements
The supplier should establish and maintain internal laboratory capability for frequently used services, such as
gauge calibration. Laboratory services provided by the supplier, either internal or external, shall be qualified to
perform the required inspection, test or calibration services. The laboratory scope shall be defined, and
technical requirements reviewed for:
▪ Adequate laboratory procedures

▪ Competent laboratory personnel
▪ Testing procedures
▪ Capability of performing test and traceability to standards
▪ Related documents
External laboratories may require accreditation to ISO/IEC 17025 or equivalent national standard.
At any time, Lucy Electric may request production samples to perform analysis and testing.
5.7 Production Monitoring
The supplier’s control plan shall identify all Lucy Electric requirements and the method of inspection and when
applicable functional verification to be performed. Lucy Electric may specify certain criteria for inspection
methods and functional verification. The control plan establishes the method and frequency of monitoring and
measuring the product and processes to ensure conformity to Lucy Electric requirements. The supplier shall
establish procedures to control non-conforming product or service. The non-conforming product shall not be
released or delivered unless approved by the supplier’s authorized representative and, when applicable, Lucy
Electric. Refer to section 5.5 Customer Waiver for additional information.
5.7.1 Layout Inspection
Lucy Electric strongly recommends suppliers to submit an annual layout inspection report for all pasrt and
assemblies. If a non-conformance is found, the supplier shall notify Lucy Electric. Lucy Electric may issue an
NCR (Non-Conform) for supplier identified non-conformances with the products. Refer to section 6.2
Reference Document
Lucy Electric issued Non-Conformances (NCR) and Corrective Actions.
5.8 Change Control
After product approval, the supplier shall control all changes to Lucy Electric deliverables. The supplier’s QMS
shall include procedures to manage all changes to engineering documents, manufacturing equipment and
tooling, test and measurement equipment and all materials used in the process.
Any changes to engineering drawings, specifications, materials, manufacturing processes or other documents
require PRIOR APPROVAL by the authorized Lucy Electric representative. The Supplier Process and Design
Change Request form shall be used by the supplier to notify Lucy Electric prior to any changes.
Some examples requiring notification and when applicable PPAP re-submission:
▪ Drawing or specification change

▪ Material change or new material supplier
▪ Special process change including heat treatment, plating, coating, etc.
▪ New or modified production tooling
▪ Re-locating equipment within a site
▪ Manufacturing location change
▪ New sub-supplier or sub-supplier process change
▪ New or modified testing and/or measuring equipment
▪ Packaging and/or labeling change
▪ Shipping to new Lucy Electric facility
Lucy Electric shall be notified of planned changes prior to starting the project. The implementation date shall
be determined by Lucy Electric and the supplier.
Various new process and product capability studies and approvals may be required as a result of the planned
changes. The acceptance criteria for a planned change shall be agreed upon by Lucy Electric and the supplier
prior to implementation. The process for accepting a change may require substantial time to complete all tasks
identified. Refer to section 4.5 Product Approval Process for additional information.
In the event of an unauthorized change, the supplier must notify Lucy Electric within 24 hours of detecting the
change. The supplier may be placed on New Business Hold (NBH) if the proper notifications and processes
are not followed.
The supplier shall request approval from each Lucy Electric site affected by a change and refer to the
applicable procedures and forms.
5.9 Preventive & Predictive Maintenance
The supplier shall plan and operate a comprehensive maintenance system for the production equipment used
to support products. The maintenance system, at a minimum, shall cover:
▪ Planned maintenance activities

▪ Packaging and preservation of equipment, tooling and gauging
▪ Availability of replacement parts for key manufacturing equipment
▪ Documenting, evaluating and improving maintenance objectives and performance
▪ Predictive methods to reduce and/or eliminate unscheduled interruptions
5.10 Customer-owned Assets
Custom products may require Lucy Electric-owned assets to be consigned to the supplier. The assets shall be
used exclusively for the development, production, and testing of Lucy Electric products. Such assets may
include, but are not limited to:
Reference Document
▪ Production tooling and fixtures

▪ Gauges
▪ Testing and measuring equipment
▪ Dedicated processing equipment
▪ Prototype or production components
▪ Licensed software and hardware
The purchase order shall identify all required assets, applicable specifications, maintenance requirements and
expected life of the asset. The supplier shall adhere to the terms and conditions established by the Agreement
with Lucy Electric. The supplier must attach an approved Lucy Electric asset tag or utilize another approved
method of marking. The supplier must maintain a log of all Lucy Electric-owned assets. Lucy Electric may
request the asset log and/or conduct an audit of the assets.
The supplier shall record and maintain a log of operational data for each asset including, but not limited to:
▪ Maintenance history
▪ Usage
▪ Capability information and capacity records
▪ Tool changes for perishable tooling or wear components
▪ Tool modifications and engineering changes
▪ Updated pictures of each asset
The supplier shall immediately notify Lucy Electric if any asset is found to be defective or unsuitable for
production. All tool modifications and design changes shall be recorded and maintained. Records of all repair
or replacements actions must be submitted to Lucy Electric.
The supplier shall not transfer, or consign to another party, any Lucy Electric-owned assets without prior
written approval from Lucy Electric. Any asset transfer may require a new PPAP approval before production
resumes. Refer to section 4.5 Product Approval Process for additional information.
The supplier shall not disposition any Lucy Electric-owned tooling without prior written approval from Lucy
Electric.
5.11 Identification & Traceability
The supplier shall properly identify product throughout the realization process and establish a system that:
▪ Identifies the production status

▪ Verifies product acceptance with regards to inspection and testing
▪ Properly controls product disposition
The supplier shall create a traceability method for unique identification of each part or material lot, unless
otherwise agreed upon by Lucy Electric. The supplier shall work with Lucy Electric to develop and approve an
acceptable method, location and content for marking the product. The supplier shall maintain all records
necessary to ensure product quality.
5.12 Preservation of Material / Packaging
The supplier shall develop a plan for proper identification, handling, packaging, storage, protection and
preservation of all Lucy Electric products and materials. The preservation plan shall apply to all internal and
external supplier processes. The plan shall apply to the storage and delivery of all products prior to assembly
at Lucy Electric or its customer facilities. As required, material handling, packaging and storage shall be
designed to:
▪ Prevent contamination
▪ Prevent part-to-part contact (except bulk material)
▪ Reduce environmental effects on product
Reference Document
▪ Prevent degradation of product

▪ Prevent loss or damage in transport
▪ Properly manage shelf life of perishable products
The supplier should utilize an inventory management system to optimize inventory, reduce risk of obsolete
product, and ensure stock rotation.
The supplier must contact Lucy Electric for any requirements related with product packaging requirements and
procedures.
Reference Document
5.13 Statutory & Regulatory Conformity
The supplier’s product shall be certified to applicable standards as required (e.g. Underwriters Laboratory
(UL), European Union/UK (CE/UKCA mark, AMSE, RoHS WEEE, REACH etc.). The supplier shall ensure
that certification is maintained. Evidence shall be submitted along with PPAP documentation, when required.
The supplier’s product or service shall meet all statutory and regulatory requirements for the locations where it
is manufactured and used. These requirements shall be properly documented, and records maintained.
The supplier shall comply with all buyer requests for information and other reasonable buyer requirements
regarding Conflict Minerals. For more information see the Conflict Minerals section.
The supplier shall provide samples, testing, environmental and Material Safety Data Sheet (MSDS)
information when requested. The MSDS is required for but not limited to:
▪ Rust prohibitive
▪ Lubricating oil and grease
▪ Acids and caustics
▪ Cleaners
▪ Other chemical material that is used while producing or assembling the product
Reference Document
6.0 Non-Conforming Product (suppliers processes)
When a non-conformance occurs, the supplier shall:
▪ Identify the non-conformance

▪ Minimize its impact through proper containment
▪ Determine the true root cause
▪ Implement corrective action
▪ Establish controls to prevent the non-conformance from recurring
In the process of resolving the non-conformance, corrective actions, lessons learned and best practices are
documented and shared, when appropriate.
6.1 Control of Non-Conforming Product (suppliers processes)
The supplier shall identify and control in a quarantined location any non-conforming product when:
▪ Product requirements are not met

▪ Packaging is incorrect
▪ Labeling or marking misidentifies the product
▪ Product status is unknown or suspect
The supplier shall implement a procedure to define the controls, related responsibilities and authority to
manage non-conforming product. The non-conforming product must be controlled until the supplier can:
▪ Determine and eliminate root cause of non-conformance through process improvements

▪ Eliminate the detected non-conformance by Lucy Electric-approved rework and/or repair
▪ Obtain approval to “Use-As-Is” from Lucy Electric. Refer to section 6.5 Customer Waiver/Concession.
▪ Scrap or reject product to prevent unintended use
▪ Re-allocate product to a different Lucy Electric-approved application (known as re-grade)
The supplier shall create process work instructions to define and control rework and repair processes. Any
rework or repair process, not identified within the approved PPAP documents, must be approved by Lucy
Electric prior to beginning. Customer approval does not relieve the supplier of any liability regarding product
quality. All corrected non-conforming product must be re-verified to demonstrate conformity to the
requirements. The supplier must properly identify each product or package as repaired or reworked.
The supplier shall immediately notify Lucy Electric of any defective products found at their facility that may
have been delivered to Lucy Electric and/or its customers. When potential non-conforming products have
been shipped, the supplier must implement appropriate containment procedures and actions. The actions
should include:
▪ Containment of product at the supplier’s or sub-suppliers’ facility, in transit and at Lucy Electric and/or
its customer
▪ Notification to the Lucy Electric plant of conforming product availability and shipment dates
▪ Product sorting at Lucy Electric and/or its customer
▪ Approved third party sorting provisions when supplier is unable to send representatives
The supplier shall maintain records of the non-conformance and subsequent actions taken. Lucy Electric
reserves the right to audit any non-conformances. Lucy Electric may issue a Non-Conformance Report (NCR)
for supplier identified non-conformances with the product(s).
Reference Document
6.2 Lucy Electric issued Non-Conformances (NCR) and Corrective Actions
Lucy Electric issues a NCR in the identification and resolution of non-conformance detected at Lucy Electric’s
facilities and by our customers. The NCR may be issued based upon incoming inspections, in-process rejects,
customer rejects, field failures, packaging or labeling issues.
The supplier is expected to respond to all NCRs issued in the format received.
Initial Response within 24 hours:
▪ Acknowledge receipt of an NCR upon notification

▪ Identify all suspect product at supplier’s premises or in transit
▪ Agree with Lucy for taking back NCR parts and/or any rework plan through third party arrangements
▪ Notification of quantity of suspect material in route to Lucy Electric and/or its customers
▪ Immediate containment action taken, such as, verification/rework of stock, in-process parts etc.
▪ Interim plan for supporting Lucy Electric production with certified product
Corrective Action Plan within 14 days:
▪ Use problem solving techniques to determine the root cause of the non-conformance. Refer to section
6.3 Problem Solving for additional information
▪ Detailed plan for implementing corrective actions to control and prevent recurrence
▪ Disposition of suspect products. If Lucy Electric will have to dispose of non-conforming parts, then
cost of disposal to be agreed with Lucy commercial teams.
Final Report within 30 days:
▪ Implemented corrective actions with supporting data

▪ Verify effectiveness of corrective actions
If the supplier fails to respond appropriately, the supplier may be placed on New Business Hold and may be
removed from the approved supplier list.
Lucy expects Supplier to display the monthly NCRs status and improvement actions on their notice board, so
all the information is available to their employees. Similarly, as a best practice supplier shall display all KPIs
on their notice board.
6.2.1 Controlled Shipping
If escalation of a non-conformance is necessary, Lucy Electric may place a supplier in Controlled Shipping
(CS). Controlled Shipping ensures a rigorous inspection process to protect Lucy Electric and its customers
from receiving non-conforming product. The supplier shall utilize a separate and distinct area for redundant
inspection of the product. Lucy Electric will determine when a supplier shall be placed into Controlled Shipping
Level 1 (CS1) and/or Controlled Shipping Level 2 (CS2). Lucy Electric may place a supplier immediately into
CS2, bypassing CS1.
For CS1, the supplier must provide certified product to Lucy Electric. The supplier shall provide the CS1
inspection results at the specified frequency determined by Lucy Electric. The supplier shall continue its
problem-solving activities and corrective action implementation.
In the event that CS2 is required, a meeting will be scheduled between key stakeholders within Lucy Electric
and the supplier. An approved third-party provider must be utilized to certify the supplier’s product prior to use.
Lucy Electric shall determine the location where the third-party provider must perform the inspections. The
results of the third-party inspections shall be provided to Lucy Electric at the specified frequency. The supplier
shall continue its problem-solving activities and corrective action implementation. If a CS1 inspection has been
established, the CS1 requirement remains in effect even with the addition of a CS2 inspection requirement.
Reference Document
The supplier is responsible for all costs associated with CS. The supplier shall remain in CS1 and/or CS2 until
the Exit Criteria have been met. When placing a supplier in CS, Lucy Electric may consider:
▪ Severity or duration of a non-conformance

▪ Repeat NCRs
▪ Supplier’s process is not capable
▪ Warranty issues
▪ Current containment activity is inadequate
▪ Production Launch first pass yield results inadequate
Additional details necessary for each occurrence shall be defined when the CS process is initiated. Lucy
Electric shall provide the Exit Criteria for CS1 and/or CS2 when the process is initiated.
6.3 Problem Solving
The supplier should adopt the “Zero Defects” mindset to reduce and eliminate non-conformances. When a
non-conformance occurs, the goal is to quickly and effectively identify the problem, minimize its impact,
determine the root cause, implement corrective actions and prevent recurrence. A robust problem-solving
methodology leads to effective root cause identification and elimination. Lucy Electric recommends the 8D
Problem Solving method. The supplier should adopt this method, or another industry recognized disciplined
approach that covers, at a minimum:
▪ Establish the problem-solving team and key contact person – include key stakeholders, experts, and
direct involved personnel
▪ Define the problem scope – state the problem using quantitative terms identifying who, what, where,
why, when and how
▪ Develop an interim containment plan – immediate actions to contain product at all locations
▪ Identify all potential root causes – analyze and verify source of the problem including what process
failed, why failure was not detected and what systems failed to prevent the
▪ non-conformance (3 root cause approach)
▪ Develop corrective actions to prevent recurrence – verify actions resolve the problem and do not
create unintended effects
▪ Implement corrective actions – update required process documentation and validate effectiveness
▪ Implement preventive actions – take steps to prevent similar problems from occurring in other
products or processes and document Lessons Learned and Best Practices
▪ Review and recognize the team – review and approve completion with management
The supplier shall evaluate the effectiveness of its problem-solving process through feedback of internal
audits, process audits, performance data and review of repeat NCRs.
Error-proofing methods are effective corrective actions to eliminate recurrence of a root cause when properly
implemented. The supplier shall use error-proofing methods to identify potential design and/or process
improvements and implement when applicable.
Refer to the Lucy Electric Global 8D Guidelines. LGL-GEN-CPA-P-02
6.4 Cost of Poor Quality (COPQ) Recovery
The supplier shall be responsible for all costs incurred by Lucy Electric and its customers in conjunction with
an NCR or any failure of the supplier’s deliverables. Lucy Electric may take immediate actions to satisfy
customer requirements while notification of the issue is provided to the supplier. A Cost Recovery Notice shall
be provided with details regarding costs incurred. The supplier shall respond to a Cost Recovery Notice when
received within 10 days.
Potential costs incurred include, but are not limited to:
Reference Document
▪ Incoming inspections
▪ Necessary sorting activities
▪ Return shipments or shipments to third party locations
▪ Customer management for warranty and field inspections
▪ Analysis of warranty and field returns
▪ Rework, repair or scrap of product at Lucy Electric and/or its customer’s facilities
▪ Premium freight charges
▪ Production downtime
▪ Additional labor costs including overtime and extra manpower
▪ Process changes for accommodating product
▪ Additional inspections or process controls
▪ Costs to manage actions taken
Lucy Electric may place a supplier on New Business Hold as a result of COPQ, NCRs, or other concerns. The
supplier may be removed from the approved supplier list.
6.5 Customer Waiver/Concession
The supplier must obtain approval from Lucy Electric for temporary changes to existing product and processes
prior to releasing product for shipment or authorizing production to proceed. The supplier shall utilize a
concession for these basic steps:
▪ Initiate a concession for deviation with detailed information with respective Lucy Electric site Logistics
/ Purchasing team who will initiate internal dialogue with Lucy design and Quality teams
▪ Review deviation with Lucy Electric representative
▪ Notify Lucy Electric of delivery date
▪ Mark affected product accordingly
▪ Manage concession quantity or time
▪ Monitor completion of corrective actions
The supplier and Lucy Electric shall evaluate the concession request to reduce adverse impact on the
customer, operations, safety, and environment. Product engineering may be required to perform analysis to
validate any adverse effects the deviation may have on the design integrity for form, fit or function. The
supplier shall provide samples, when requested, of the deviation to evaluate impact of the change in both the
design and in use at the Lucy Electric facility. Any costs associated with testing, evaluating or accommodating
deviated product are the supplier’s responsibility. Lucy Electric will approve or reject the concession request.
Excessive use of deviation requests/concessions are an indication that the supplier’s QMS may not be
performing as expected.
6.6 Continuous Improvement
The supplier shall strive to continually improve its products, processes and systems. The supplier shall
conduct regular reviews of:
▪ Quality policy and objectives

▪ Audit results
▪ Data analysis
▪ Corrective and preventive actions
The process of continuous improvement must be included in the goals and objectives of the entire supplier
organization. Continuous improvement can reduce potential risks and prevent possible non-conformances.
Refer to section 5.8 Change Control for additional information.
Reference Document
7.0 Customer Satisfaction
Customer satisfaction provides an important feedback to the supplier on their performance. The supplier shall
establish a method to evaluate feedback from Lucy Electric in these areas:
▪ Part quality performance

▪ Warranty and field returns
▪ Delivery schedule performance
▪ Lucy Electric issued NCRs
The supplier shall monitor the performance of their manufacturing processes to demonstrate compliance with
Lucy Electric requirements for product quality and efficiency of the process. The supplier should use
subjective information to receive additional feedback.
Lucy Electric monitors its suppliers for these items and may place a supplier on New Business Hold as a
result.
8.0 Global Logistics
The supplier shall comply with the requirements established by Lucy Electric Global Logistics and any specific
regional requirements.
The supplier shall use existing Lucy Electric-specified systems for receiving forecast requirements and
communicating shipping information.
8.1.1 Transport
The supplier shall adhere to the applicable shipping requirements contained in the Lucy Electric Terms &
Conditions, unless otherwise specified. Exceptions shall be granted and approved by Lucy Electric Global
Logistics.
8.1.2 Standard Routing Instructions
The supplier shall interface with Lucy Electric and/or third-party managed portals for standard routing
instructions. These routing instructions shall apply for inbound shipments where Lucy Electric is responsible
for freight payment. Lucy Electric shall provide detailed information for system usage during the supplier
onboarding process.
8.1.3 Returnable Packaging
The supplier shall interface with Lucy Electric and/or third-party managed portals for securing, managing, and
controlling returnable packaging when this is used. Lucy Electric shall provide detailed information for system
usage during the supplier onboarding process.
Packaging shall be of suitable recyclable packaging material. The supplier shall endeavor to minimize or
eliminate the use of plastics, and any other non-recyclable material to achieve sustainable packaging.
8.1.4 Shipment of Hazardous Materials and Dangerous Goods
The supplier shall comply with all applicable domestic and international transport regulations when shipping
hazardous materials and/or dangerous goods to Lucy Electric, its subsidiaries, or customers.

LGL PUR PCH M 02.1 Lucy Electric Global Supplier Manual

Uploaded by

Copyright:

Available Formats

LGL PUR PCH M 02.1 Lucy Electric Global Supplier Manual

Uploaded by

Document Information

Original Title

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

LGL PUR PCH M 02.1 Lucy Electric Global Supplier Manual

Uploaded by

Copyright:

Available Formats

Document Title Lucy Electric Global Supplier Manual

Document No. LGL-PUR-PCH-M-02

Date Created Issue Reason for Change

6.6 Continuous Improvement ....................................................................................................................27

1.0 Terms & Definitions

Confidential 1) Information, knowledge or data disclosed by buyer to supplier, regardless of whether

Deliverable See Product definition.

Action to eliminate the cause of a potential non-conformance or other undesirable

Quality Management System: A formalized system that documents the structure,

Non-Conformance Report: A formal request to take action to eliminate the cause(s) of an

2.0 Doing Business with Us

2.1 Our Company

Suppliers should visit our website (www.lucyelectric.com)

2.3 Business Partner Code of Conduct

2.4 Supplier Diversity

3.0 General Supplier Requirements

▪ Satisfy the requirements established in this manual

▪ Customer, market, or site- specific operating conditions

3.1 Supplier Quality Management System

3.2 Supplier Manual

The supplier shall maintain a Manual that includes:

▪ Supplier’s Management System

3.3 Customer Communications

▪ Inquiries, orders, bids, amendments and invoices

3.4 Document Control

3.5 Record Retention

3.7 Risk Assessment & Contingency Planning

3.8 Environmental, Health & Safety Compliance

▪ Decreased use of hazardous substances

▪ Occupational Safety and Health Administration (OSHA) VPP

▪ Reduction or elimination of unnecessary over packaging

Legal and Regulatory Compliance

Environmental Performance Improvement

3.12 Customer Approved Sources

▪ Quality of product or service

3.13 Sub-Supplier Management

The supplier shall define expectations for each sub-supplier including:

▪ Support of APQP and PPAP requirements (see guidelines)

▪ Verification of purchased products

3.13.1 Verification of Purchased Products & Services

3.13.2 Incoming Product Quality

▪ Statistical data evaluation from the sub-supplier

3.13.3 Sub-Supplier Monitoring

▪ Delivered product quality – Nonconforming Parts Per Million (PPM)

4.0 Supplier Selection & Assessment

Lucy Electric expects the supplier to:

▪ Abide by our Code of Conduct

4.1 Supplier Assessment

New suppliers application process and approval – Ref LGL-PUR-PCH-P-03

4.1.1 Generic Supplier Process Audit (GSPA)

4.1.2 Commodity Specific Process Audit (CSPA)

▪ Defined criteria for review and approval of the processes

5.0 Advanced Quality Planning

▪ Develop quality objectives and requirements for the product

5.1 Advanced Product Quality Planning (APQP)

▪ Monitor progress of the design and development of deliverables

The supplier shall develop a project plan with:

▪ Project tasks, target dates and assigned responsibilities

5.1.2 Product Design and Development (applicable to proprietary supply parts)