pewag group managementhandbuch 2013 revision e e

Integrated Management Manual November 2013, Revision E 2009 / 2010

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Information & Contact Klaus Huber Chief Quality Officer (CQO) pewag International GmbH A-8041 Graz, Gaslaternenweg 4 Phone: +43 316 6070-139 Fax: +43 316 607080-139 hu@pewag.com www.pewag.com 2

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Contents 1 Foreword

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2 Scope

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3 Declarations of Commitment and Enactment

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4 Management Responsibilities

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4.1 Mission Statement 4.2 Principles of pewag group 4.3 Code of Conduct 4.4 Our Quality Policy 4.5 Our Energy and Environmental Policies 4.6 Evaluation of Management System by Management 4.7 Responsibilities

5 Safety and Risk Management 5.1 Safety 5.2 Risk Protection

6 Integrated Management System 6.1 Set-up of IM-Systems 6.2 Document Control 6.3 Quality and Environmental Reporting

7 Measuring, Analysis and Improvements 7.1 7.2 7.3 7.4

Customer Satisfaction Internal Audit Handling of Nonconforming Products Corrective and Preventive Actions

8 Energy and Environmental Report

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1 Foreword The development of our Integrated Management System (IMS) follows system elements that adhere to the following norms according to the current issues: • Quality Management System EN ISO 9001 • Environmental Management System EN ISO 14001 • Energy Management System EN ISO 50001 • Quality requirements for fusion welding of metallic materials EN ISO 3834-2 • Occupational Health and Safety Assessment OHSAS 18001 • Risk Management EN ISO 31000 • Information technology – safety engineering EN ISO 27001 Certification of the above mentioned norms is not mandatory. All our production locations are certified under EN ISO 9001 and/or EN ISO 14001. The energy management system certification EN ISO 50001 has been implemented in all production locations during the course of 2013, with the aim of receiving the certification by November 2014. The current certification status can be found on our homepage http://www.pewag.com/News---Press/Print-und-Videos.aspx as well as on the individual country websites, e.g. http://pewag.at/News---Press/Print-und-Videos.aspx By using the documentation within the company organisation’s integrated management system, we can show our customers that we are able to satisfy their needs, requirements and expectations fully.

As well as producing products that meet the customer’s needs, we strive to offer our customers expert advisory services and efficient support in overcoming specialised problem areas. The goal of all our activities is to undergo continuous improvement so that we can offer our customers optimum quality by dealing thoughtfully with our natural resources.

Graz, November 2013

Representative of Management: Klaus Huber Chief Quality Officer (CQO)

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2 Scope The documented provisions within this manual are valid for every employee of the pewag group. This does not mean, however, that they replace the individual responsibility of the employee in terms of their performance quality, as well as the responsibility towards the environment and health and safety compliance with in the workplace.

Supplier

Supplier

Supplier

Supplier

Management Board Segment Z

Segment ...

Segment B

Segment A

pewag International US market:

pewag inc.

...

French market:

Customer

Austrian market: pewag austria Vertriebsgesellschaft mbH

Branch

German market: pewag Deutschland GmbH

pewag France SAS

pewag group Structural organisational plan of the pewag group

World Map: 31 Subsidiaries (red) - 11 Plants (blue) Integrated Management Manual

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3 Declarations of Commitment and Enactment As the CEO, I confirm that the management system that has been described in this manual fulfils the requirements and will be put into practice. Furthermore, I confirm that all regulations explained herein are to be seen as a binding commitment by each employee.

Klagenfurt, November 2013

Ă„gyd Pengg CEO

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4 Management Responsibilities 4.1 Mission Statement

The mission statement is a basic principle shared by and throughout the whole company and is therefore always in the forefront of every decision and action undertaken.

With our joy for innovation, we ensure that all products of the pewag group are the best in the respective markets, both now and in the future. The high quality of our products and services as well as our employees‘ passionate dedication are the foundation to our pursuit of outstanding services and complete customer satisfaction.

4.2 Principles of pewag group Leading in Quality The values of our premium product brands are demonstrated by our first class quality and innovations and are communicated consistently and coherently.

We anticipate market demands and changes in the environment and adapt our strategies, organizations and actions accordingly to satisfy our customers’ needs through providing the best value for the money; timely delivery; efficient and obliging service.

in Quality

in Technology Leading to Excellence

in Responsibility

in Economics

Leading in Responsibility We commit ourselves to careful treatment of the environment, by reducing the use of energy and raw materials, ensuring the longevity of our products and making them recyclable.

We value an open, honest and team-oriented work style, which is based on transparent communication honouring ideas, opinions and experience of our employees as valuable inputs for our decision making process. We strive for stable and fair partnerships with our employees, customers, suppliers and other business partners and take social aspects into consideration when making business decisions.

Leading in Technology We secure our technological leadership through highest product quality, constant improvements and innovations of products, as well as manufacturing processes.

We are dedicated to keep on top of product technology. This ensures that our customers always have the best solutions available and that we expand and protect our market position.

Leading in Economics In all our processes we use due diligent business practices and efficiency and strive to improve these continuously.

In the long-term, we will continuously increase our economic performance to raise corporate value, achieve sustained growth and thus secure a successful future of the organization.

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4.3 Code of Conduct For the pewag group, combining entrepreneurial action with ethical principles is one of the essential factors in long-term success and is a tradition.

In this Code of Conduct, minimum standards are laid down which define the minimum level of compliance, we expect from our staff, customers, suppliers and other contract partners.

These include: • Observance of the statutory provisions of each item of applicable legislation • Avoidance of conflicts of interest • Active and effective combatting of every form of corruption and bribery • Prohibition of forced and child labour • Respect for human rights • Fair working conditions • Acceptance of responsibility for the health and safety of employees • Respect for environmental protection • Confidentiality Our Code of Conduct can be found by all customers, suppliers and other contractual partners on the individual country websites, e.g. http://pewag.at/News---Press/Print-undVideos.aspx, as a PDF to download.

4.4 Our Quality Policy Our main goal is customer satisfaction. In this instance, quality means that only those products and services are developed, manufactured and delivered which completely and without compromise satisfy the customer. The pewag group’s quality policy, is underlined by the following basic principle: “we supply high-end products and services to our customers that conform to the technical standards and requirements”, can be summarised in the subsequent four points.

Market-oriented Quality In order to maintain and to widen the competitive position of the pewag group, the quality of finished goods and services must be consistent with the specifications of the customer and also with their expectations of a technological leader. No product should ever pose a danger to people or the environment.

Economic Quality As a profit-oriented company, quality is achieved by taking into consideration the material, personnel and financial resources; this means that we establish an appropriate best price/ performance ratio for the customer within the acknowledged framework.

Quality Responsibility Stringent demands are placed on all employees to ensure high standards of quality. No matter what hierarchical level, all managers are in charge of managing quality. Every employee within the pewag group should be educated, motivated and instructed by the management team. It is important for promoting high quality awareness that the education and training of employees is at the forefront, as each employee is responsible for the quality of his/her own work.

For each of our employees, the statement “QUALITY STARTS WITH ME” must be true!

Process-oriented Quality Clearly defined processes, operations and responsibilities within each separate organisation – and within the group as a whole – have been established in order to foster the close working relationship between sales, development, manufacturing and customer service departments. Constant improvement of technology and our processes should ensure, that the effectiveness of our work and quality is consistently improved.

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4.5 Our Energy- and Environmental Policy Our company’s manufacturing location in Kapfenberg, Austria, has been used for iron and steel production for over 270 years. A second facility located in Brueckl, Austria, was first documented in records dating back to 1479. Based on this long manufacturing tradition, we take serious responsibility for our products, employees and the environment at all our international locations. Hence, one of our major concerns is to improve energy efficiency and, in doing so, to minimise energy consumption over a long period of time with the development of new production technologies. An important goal is to increase energy efficiency and consequently lower energy demand. Consequently, we develop our products to achieve longer product life-cycles and lower weight but simultaneously, increasing their working load capacities and the safety for our customers.

We are committed to upholding all relevant energy and environmental regulations by setting clearly defined goals and continually improving our performance. To achieve this goal, we use modern manufacturing technologies. An important step is to provide the necessary resources and to include our employees in the process. We are convinced that well-informed and motivated employees can actively participate in environmental conservation.

Wherever we are unable to avoid an environmental impact, we have set ourselves the goal to continually reduce our energy consumption, waste and environmentally harmful emissions. When purchasing new equipment, we strive to find the best and most efficient technical solution possible. It is important for us to promote the purchase of energy efficient products and services.

Our process-oriented management system regulates the documentation concerning all environmental relevant procedures. It also encompasses preventative measures for possible failures, as well as behavioural instructions for regular and/or extraordinary operational procedures. By systematically monitoring and assessing our environmental activities, we are quickly able to resolve deviances and to take corrective action. This process extends throughout the whole organisation to optimise all business processes.

We strive to engage in an open dialogue with our customers, neighbours and authorities to inform them of our energy and environmental engagements.

Through specific communication we want to inform our customers about the environmental aspects of our products – specifically inform them about the longevity of our products. Through meaningful communication, we strive to motivate our suppliers and customers to think – in turn – about their environmental footprint and to put into practice similar environmental standards in their businesses.

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4.6 Evaluation of Management System by Management The managing director and/or the segment leader of the pewag group are responsible for ensuring the proper use of the management manual and the implementation of the IMS measures.

The managers of the individual organisations in charge of quality and environmental tasks should constantly question the effectiveness of the management measures and improve them if need be.

The managing director and/or the segment leader evaluate and review the situation and the effectiveness of the management system at least once a year on the basis of the results of internal audits and other information sources. The management’s evaluation is documented and retained.

4.7 Responsibilities Responsibilities and competencies can be found in the job descriptions and instructions including those of the representative. Furthermore, the documents highlight the reporting system, the goals and the requirements profile for the tasks to be carried out.

Tasks and activities can be delegated, but not the responsibility!

Management activities concerning integrated management. The CEO is responsible for establishing and maintaining the quality, energy and environment policies within the whole of the pewag group and is also responsible for the management system.

The representative from top management (CQO) is responsible for the management system and its total evaluation; he directly answers to the CEO. The managing director/segment leader of the pewag group is responsible for the establishment and upkeep of the quality, energy and environmental policies as well as the integrated management system and evaluation within their own division.

The quality managers within the company/segment are responsible for the adherence and evaluation of the integrated management system as well as the disclosure of documents.

5 Safety and Risk Management 5.1 Safety Our employees’ health sits at the top of our list.

In the field of health and work safety, we take preventative measures and set up appropriate procedures.

We support our employees in assuring strict observance of and complete compliance with the preventative safety measures to guarantee safety in the workplace. We ensure that the employees receive proper training in the area of safety in the workplace and call on individuals to see if the measures are being put into practice.

5.2 Risk Protection In terms of our customers and suppliers we value long-standing relationships and strive towards efficient organisation with clearly defined responsibilities and procedures, as well as a well-working internal communication and information flow. Clear documentation and a functioning (written) reporting system create transparency which assists us in making business and employee decisions more successfully.

The economic goals of profitability, liquidity and growth must be balanced so that we are able to sufficiently meet our payment obligations at any time; provide a performancebased remuneration to our employees; and provide and maintain a healthy capital base for our company. Recognisable risks are either to be avoided, insured against or taken on deliberately.

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6 Integrated Management System 6.1 Set-up of IM-Systems

Management Manual Mission Statement Principles Policies

Core Processes

Process Instructions Work Instructions Inspection Instructions Miscellaneous Documents Forms

The IMS follows a strict document hierarchy.

The core processes which are valid at all locations, and the 3rd level documents within the pyramid, are confidential and not allowed to be passed on to third parties without the permission of the managing director and/or other representatives of the management board.

Management Manual The management manual contains a superordinate presentation of the integrated management measures. A general description of the overall processes and the organisation is depicted which allows our customers, inspecting authorities, public authorities and our employees to gain a better insight into how the company meets customer requirements, national and international regulations.

The core processes were identified as: Management Processes (GMP) Resource Processes (GRP) Production Processes (GPP) Measuring, Analysing and Improving (GAP)

Third level documents Documents used to implement quality and environmental management guidelines (can be set out differently depending on the individual company) are as follows: Process Instructions Work Instructions Inspection Instructions Miscellaneous Documents Forms Technical Delivery Conditions

The allocation of quality and environmental relevant documents contained within this management manual is guaranteed via the central document registry.

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6.2 Document Control All documents in their current version can be accessed by all employees in their national language through our IT-system. The procedure of creating, verifying, releasing, distributing, changing, retracting and archiving of QM-documents is explained, in detail, in the process descriptions and procedural guidelines. In those areas where the employees are unable to access a computer, it is the responsibility of the department manager to inform all employees of changes or new information.

Management Manual The CQO of the pewag group is responsible for the content, the distribution and the retraction of the manual. Due to constant scrutiny of the effectiveness of quality-relevant activities, the methods and organisational structure within the company are continuously updated to reflect the latest findings and requirements.

Foreign language versions Translations of the manual into a foreign language must be carried out by suitable translators. To avoid generalisations and differences in interpretations, the original version in German will be valid. A current version is available on the homepage www.pewag-group.com as a downloadable pdf.

Core processes A process leader will be appointed who will, along with his team, create and oversee the running of core processes making sure that these are up-to-date and who are responsible for the creation and updating of standardised training documentation. Permission needs to be granted by the CEO and/or CQO in order for changes or alterations to be made.

Documents at the third level Each individual department is responsible for publication.

Chapter classification Based on the ISO 9001 supplemented in the chapters on the previous Norms discussed in the foreword.

04 Quality management system 05 Management responsibilities 06 Resource Management 07 Product realisation 07.01 Planning of product realisation 07.02 Customer-oriented Processes 07.03 Development 07.04 Procurement 07.05 Production und Service provision 07.06 Control of systems of monitoring and measurement 08 Measuring, analysing and improving 08.01 General Information 08.02 Monitoring and measurement 08.03 Handling of nonconforming products 08.04 Data analysis 08.05 Improvements 09 Safety measurements 09.01 General Information 09.02 Fire prevention 09.03 Work place evaluation 09.04 IT-Security 09.05 IKS (Internal Control System) 10 Environment 10.01 General Information 10.02 Waste management concept 10.03 Legal compliance

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6.3 Quality and Environmental Recordings System, job-related and overall recordings are gathered in documents wherein the method of information storage, the storage location and length of storage are noted.

All employees are responsible for the careful handling and storing of documents for as long as such information is in the custody of the department. While using and/or storing, the recordings need to be protected against damage, loss or environmental degradation.

EDP-data will be saved at specified intervals und stored. This is applicable for the mainframe computer as well as for individual EDP work areas. The backups will be stored separately.

7 Measuring, Analysis and Improvment Our processes and products are regularly examined and improved. We orientate ourselves using Deming’s PDCA-cycle.

7.1 Customer Satisfaction The sales department, using the Business Trip Report and questionnaires, can gage and evaluate the customer‘s satisfaction. The Business Trip Report is set up in the EDP Database; issues imperative when filling in the dataset are (for the automatic evaluation): • Quality • Price • Customer Service • Supplier Performance

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7.2 Internal Audits Regular internal audits help in maintaining surveillance, compliance and effectiveness of the defined requirements and a shared realisation of the improvement potential. The qualifications of the auditors are governed by the procedures laid down in a cross-site IT database which should improve transparency.

Audit plan creation Once a year, the CQO distributes a base audit plan for all organisations for the ITdatabase and sends this for approval to the CEO. This plan outlines the areas to be audited, elements and/or processes as well as the names of the auditors. The base audit plan can be changed by the quality managers and approved by the responsible managing director at each individual location.

The approved audit plan is distributed via the IT-database. Additional audits can be called for by the responsible managing director, segment leader and/or quality manager.

The internal audit’s implementation supervision behooves the responsibility of the quality manager. The objectivity of the audit is guaranteed in that a minimum of one auditor is not an employee of the company/the profit centre/departement being audited. When compiling the auditing team, auditors are nominated on the basis that they possess specialized knowledge in the audited area. There are, for example, numerous locations within the pewag group that have electroplating. The department heads are familiar with the process, with handling and disposing of hazardous substances, with waste products etc. Due to this specialised knowledge, a more in-depth analysis can take place and the audit is more efficient. Additionally, the auditor is able to broaden his skill-set and knowledge-base through the auditing process and in turn, bring improvements to his own department. Through this, the management system compliance is guaranteed; as well as the processes and improvement potential can be audited.

Execution of internal audits • System/Process audit The execution of internal audits is carried out using checklists and old audit reports.

Deviations from the QM-System requirements are noted in writing within the audit report and distributed to the relevant departments. The processing of the deviations need to be agreed upon at the audit dates. The allocation of the audit reports as well as the automatic reminders take place via the database. • Product audit This is initiated through process changes, quality issues, complaints etc.

7.3 Handling of Nonconforming Products The process descriptions, which are binding, contain the procedures and responsibilities for handling mistakes during the execution of orders, as well as how to handle customer complaints.

Mistakes should be openly discussed, analysed and troubleshooting procedures implemented in order to avoid the same mistakes from occurring again in the future.

The results from self-monitoring help in this process.

The faults and notification of problems reports and complaints of the pewag group are collected in a cross-site EDP-database, processed and evaluated; so that major improvements in transparency are created.

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7.4 Corrective and Preventive Actions Corrective and preventive actions serve in eliminating causes from actual or alleged mistakes and/or defects; thereby avoiding the same mistakes from occurring in the future.

The triggers for introducing corrective and preventive actions are as follows: • faults and notification of problems reports and complaints • results of supplier assessment • reports from internal and external audits • service and business trip reports, etc.

• evaluation of the QM-System through the management board or PC-leader • internal suggestion scheme • environmental aspects • environment programme The faults and notification of problems reports and complaints of the pewag group and their validity are collected in a cross-site EDP-database, processed and evaluated; so that major improvements in transparency are created.

8 Energy and Environmental Report Our ISO 14001 and ISO 50001 certified companies create a yearly energy and environmental report which is available to download from our website www.pewag-group.com.

Based on our ecological operating report, this report contains our strategies and our facts. Our environmental indicators, our energy efficiency development and our accident statistics are also portrayed herein. Of course we would also like to present our plans for environmental protection for the future.

This integrated management manual is the intellectual property of Metallwaren Beteiligungsgesellschaft mbH and is available for download by all those interested from our homepage www.pewag-group.com and is not subject to revision.

Please consider your environmental responsibility before printing this manual.

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pewag International GmbH A-9020 Klagenfurt, Schleppe-Platz 8, Phone: +43 463 4880-0, Fax: +43 463 4880-400 office-mwb@pewag-group.com, www.pewag-group.com