Counterfeit, Fraudulent and Suspect Items (CFSI)
Policy Statement

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The purpose of this Policy is to ensure that Offshore Stainless Supplies takes appropriate measures to prevent the introduction, procurement and distribution of counterfeit, fraudulent or suspect products. This policy is established to maintain the integrity, safety and compliance of our supply chain, ensuring our customers receive only authentic and quality materials.

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This policy applies to all stainless steel, duplex, super duplex and nickel alloy products sourced, manufactured or supplied by Offshore Stainless Supplies and covers the identification, reporting, handling and prevention of CFSI throughout the procurement, manufacturing and distribution processes. Our definitions are:

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Counterfeit Item: A product that is intentionally manufactured, altered or configured to resemble a legitimate product but does not meet legal, technical or quality standards.
Fraudulent Item: A product that is intentionally misrepresented with false documentation, certification, age, use, composition or origin, with the intention to deceive.
Suspect Item: A product that, through visual inspection or testing, does not appear to conform to specifications or quality standards, or raises doubts about its authenticity or integrity.

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Offshore Stainless Supplies is a reputable manufacturer and stockholder of cold drawn stainless steel and nickel alloy bars, as well as being the World’s largest stockholder of 1.4003 stainless steel. All the Company’s suppliers must undergo a rigorous qualification process to ensure they meet standards for quality, authenticity and integrity. Suppliers are also required to declare the origin of the materials, including any third-party sourcing, to prevent fraud or misrepresentation.

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All products must be accompanied by complete and verifiable documentation, including mill certificates, test reports and evidence of compliance with applicable industry standards (such as ASTM, ISO or equivalent). Offshore Stainless Supplies will maintain detailed records of all purchased materials to ensure traceability throughout the supply chain.

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Offshore Stainless Supplies conduct thorough inspections of all incoming material and products, including documentation review, physical testing and verification of certifications. Any product that raises suspicion of being counterfeit, fraudulent or suspect will be quarantined and subjected to further investigation and testing. If the item is confirmed to be counterfeit, fraudulent or non-compliant, it will be rejected and returned to the supplier. A non-conformance report will then be issued to the supplier.

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The Company will provide regular training to all employees involved in procurement, quality assurance and manufacturing processes on how to detect and handle counterfeit, fraudulent or suspect items. Suppliers are also made aware of the Company's CFSI policy and will be required to adhere to it through contractual agreements.

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This policy demonstrates Offshore Stainless Supplies commitment to the prevention of counterfeit, fraudulent and suspect items and ensures adherence to quality standards that protect our business and customers.

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Overall responsibility for CFSI at Offshore Stainless Supplies rests with:

Ian Griffiths

Chief Executive Officer
Offshore Stainless Supplies
September 2024