Supplier Quality Manual

1.0 Overview

1.1 Introduction

Argus Group is a leading New Zealand-based manufacturing partner specialising in high-quality products and solutions, including electronics assembly, heating design and manufacture. Argus Group is a key supplier into a range of sectors, including aerospace and defence, medical devices, marine, appliance, automotive, and heating products industries.

Argus Group has a firm belief in doing business responsibly, fairly, and sustainably. We have a strong commitment to doing the right thing and creating a positive lasting impact that goes beyond our dedication to our direct customers, but also to our supply chain. The way we do business is anchored by our approach to social responsibility and sustainability.

This Supplier Quality Manual reflects our values and our expectations for all third parties, including suppliers, contractors, service providers and their affiliates who work with us, including upstream supply chain. It represents our values of trust, mutual respect and common values, and the Argus principles, which are based on the ‘3-P principles’ of People, Product and Process. This code supports compliance with quality, environment, health & safety, sustainability, social, and business ethics, as well as all relevant laws and regulations.

This code applies to all Argus Group partners as a total supply chain initiative. We view our suppliers as partners and ask them to align with our core values and help maintain the standards set forth in this manual. We encourage our partners to require the same standards of conduct from their suppliers.

Within our upstream supply chain, we apply active risk mitigation through continuous monitoring and partnering with socially responsible organisations that mirror our values. We dual source directly from manufacturers, service providers and third parties globally.

Argus will use this code of conduct as part of its supplier selection and evaluation procedures. Argus reserves the right to end its business relationship with Argus partners if they do not adhere to the principles defined in this Code of Conduct.

By supplying goods or services to Argus Group, partners agree to meet these standards and encourage their own suppliers to do the same.

1.2 Purpose

Argus partners with suppliers who share our commitment to quality, innovation, and reliability. This manual defines Argus’ expectations for suppliers, and provides guidance for the supply of goods and services to Argus. The purpose is to assist suppliers to consistently supply to Argus’ standards. This manual sits alongside the Argus Supplier Code of Conduct to support the on-going relationship with suppliers.

1.3 Scope

This document covers all suppliers of Argus Group (‘Argus’), including subsidiaries Argus ManuTech, Argus CableTech, and Argus Heating. These requirements apply to all Argus suppliers globally and to all products, processes and services that impact Argus deliverables.

1.4 Responsibility

The Supply Chain Manager is responsible for process changes and updates to this document.

1.5 Definitions

Approved Supplier: A supplier approved by Argus, of an item or service that has a direct effect upon, or association with, Argus’ product or service. An approved supplier is internally approved by Argus and should be considered a trusted source that will reliably provide authentic and conforming material.

Critical Item: Those items (e.g., functions, parts, software, characteristics, processes) having significant effect on the provision and use of the products and services; including safety, performance, form, fit, function, producibility,

service life, etc.; that require specific actions to ensure they are adequately managed. Examples of critical items include safety critical items, fracture critical items, mission critical items, key characteristics, etc.

Counterfeit Part: An unauthorized copy, imitation, substitute, or modified part (e.g., material, part, component), which is knowingly misrepresented as a specified genuine part of an original or authorized manufacturer

Delivery In Full On Time (DIFOT): A key performance indicator to measure how reliably a business delivers products or services to customers according to their agreed requirements. It measures the percentages of customer orders that contain all items and quantities ordered by the agreed delivery date.

Flow Down: Communication, to external providers (suppliers or subcontractors), of specific management system requirements, to ensure that everyone in the supply chain adheres to the required standards for quality and compliance

FMEA: Failure Modes and Effects Analysis (FMEA) is a structured risk assessment methodology used to proactively identify potential failures in a design, product, process or service. It is designed to analyse potential causes and consequences, and to prioritize actions to prevent or mitigate these.

High Risk Industries: High Risk Industries, in the context of Argus’ products and services are considered to be Aerospace, Defence and Medical Devices, including supplier products used in, and supplier services to Argus that have a direct effect upon, or association with, Argus’ product or service into these industries.

Special Requirements: Those requirements identified by a customer, or determined by Argus, which have high risks of not being met, or requiring additional risk management processes. Factors used in the determination of special

requirements include product or process complexity, historical experience, and product or process maturity. Examples of special requirements include performance requirements imposed by the customer that are at the limit of the industry’s capability, or requirements determined by the organization to be at the limit of its technical or process capabilities.

1.6 Communications

The official business language for Argus for all documents and communications is English. Other languages may only be used as agreed.

2.0 General Supplier Requirements

2.1 Management System

Argus partners with suppliers who take pride in strong, well-managed systems. Your quality management system should ensure that every process supports consistent delivery of reliable, compliant, and high-quality outcomes — reflecting the same standards Argus applies to its own operations. Suppliers are expected to have knowledge of their own operations relevant to Argus, including identifying key stakeholders including customers, regulators, certification bodies and end users. Suppliers should notify Argus where these requirements affect product conformity.

Partners are expected to have a management system in place, covering all manufacturing sites. The management system, at a minimum, should consist of a Quality Management System (QMS). Suppliers should have a commitment to quality product or service, and take a risk-based approach to product quality and business operations.

2.2 Process Capability

Argus engages with suppliers who demonstrate technical capability to provide product or service while maintaining a disciplined process, and adhere to Argus product, service and regulatory requirements. Argus evaluates suppliers based on quality, delivery (DIFOT), responsiveness, environmental commitment and social aspects. Results are reported through supplier review. Argus supports supplier development and may partner with suppliers to improve quality, delivery or process robustness where mutually beneficial.

2.3 Management of Materials

Suppliers are responsible for maintaining effective shelf-life management systems for all materials used in manufacture of Argus products. No material may be used beyond its manufacturer’s expiry date without written approval from Argus.

2.4 Procedures and Records

Suppliers are required to maintain appropriate procedures and records for all activities performed for Argus. At a minimum, this will include processes relating to production, inspection, training and competence, document and record control, control of non-conforming product, and corrective and preventative action.

2.5 Competence and Awareness

Ensure staff are adequately trained and appropriately qualified for the provision of services or manufacture of product for Argus.

2.6 Rework

If rework or repair is required for non-conforming product produced for Argus, prior approval for the rework in writing is required before proceeding. When rework or repair is initiated due to non-conforming components returned by Argus, rework and repair procedures should include a method to verify and remedy the reported failure, unless prior approval is obtained from Argus.

2.7 Sub-suppliers

Notify Argus if a sub-supplier will be involved in the production of Argus materials or product. The supplier is responsible for qualifying all sub-suppliers in alignment with Argus requirements, including confidentiality and intellectual property rights.

2.8 Document and Record Control

Documents should be controlled for any changes. All documents and records associated with the manufacture of product for Argus should be retained for a minimum of 7 years from date of manufacture and be made available to Argus in a timely manner.

2.9 Management of Changes

Requests or communications for changes to product should be made in writing directly to Argus, and approved before the implementation of the change.

2.10 Issue Management

Have a process in place to contact Argus, in writing, if they suspect quality or potential quality issues will impact on manufactured components, product performance, regulatory non-compliance, or cause product to be non-conforming. This includes if non-conforming products have been shipped. When requested, suppliers will immediately stop production and shipping of Argus materials, and provide technical support to contain and investigate the root cause.

2.11 Control of Argus Owned Equipment

Suppliers are expected to maintain the security and confidentiality of, and prevent any damage or loss to all Argus equipment. They will ensure all Argus owned equipment is identifiable and integrated with the supplier’s asset database and quality system. Prompt communication is required if damage occurs to any Argus owned equipment. Equipment should be maintained in a safe and proper condition for the intended purpose, and kept in calibrated and maintained range. Any instance of non-conformance must be reported to Argus.

3.0 Quality Requirements for Critical Items and High Risk Industries

3.1 Quality Management System

Argus values suppliers who take a proactive and disciplined approach to quality. Suppliers shall maintain a quality management system to ensure the organization’s processes, procedures and responsibilities are formalized and support the organization in meeting or exceeding internal, customer and regulatory requirements. We encourage certification to ISO 9001, ISO 13485, or AS9100, to the latest revision, through an accredited third-party registrar, as relevant to your products and markets.

Regular reviews and audits help demonstrate control and continuous improvement of your management system. Suppliers are expected to perform internal audits, management reviews and risk-based assessments to evaluate the performance of their quality management system. Argus may review or audit your quality management system to confirm it continues to meet expectations.

The supplier will be required to supply copies of their current certifications to Argus. The supplier shall notify the Argus within five business days via email of any suspension or disapproval of the supplier’s Quality Management System by their certification body. Any work conducted or delivered to Argus during the period of any suspension or disapproval of shall also be notified to Argus without delay.

3.2 Competence, Training, Awareness

Every person in partnership with Argus plays a role in upholding commitment to excellence — from ensuring product and service conformity to maintaining the highest standards of safety and integrity. Suppliers are expected to support this through effective training, ongoing competency development, and by keeping accurate records that demonstrate compliance. Suppliers must ensure that all team members involved in processing orders or carrying out work that impacts product quality are appropriately trained and understand the importance of their work in relation to meeting Argus’ requirements. The training and awareness shall include the supplier's contribution to product or service conformity, their contribution to product safety and the importance of ethical behavior.

3.3 Requirements Implementation and Flow Downs

Suppliers are accountable for meeting all Argus requirements and for ensuring the same standards are upheld throughout their supply chain. When sub-tier suppliers are used, all relevant technical, quality, and regulatory requirements must be communicated clearly and followed. Sub-tier suppliers involved in critical product or service delivery must be approved by Argus and demonstrate the capability to meet all specified performance and compliance expectations.

3.4 Supplier Access Rights & Audits

Argus works closely with our suppliers to maintain the highest levels of quality and compliance. We may, at times, along with our customers or relevant authorities, conduct audits or assessments at supplier or sub-tier facilities where production, maintenance or service activities take place to confirm compliance with product, process, and regulatory requirements.

These assessments provide assurance that production, documentation, and control systems are effective and aligned with Argus standards. After each audit, Argus issues a written report outlining findings and opportunities for improvement. Suppliers must address any nonconformities by submitting a corrective action plan within two weeks and providing evidence of completion and effectiveness once resolved. Upon completion of the action plan, the supplier shall submit evidence to validate implementation and effectiveness of each corrective action to Argus.

3.5 Supplier Risk and Opportunity Management

Suppliers are expected to build resilience into their production, service, and supply chain, and be prepared to respond to disruptions. Disruptions can occur for many reasons, including weather conditions, material shortages, geo-political factors, climate change, manufacturing site issues, and material end of life.

Suppliers working with high-risk or safety-critical products, including those for aerospace, defence, or medical device applications, must maintain a strong understanding of risks and have well-defined plans for crisis management, disaster recovery, and business continuity. Evidence of business continuity plans shall be made available to Argus upon request. Suppliers are expected to have conducted risk assessments appropriate to the context of their organization, and mitigation for critical items, including those that are safety-critical to either Argus, downstream customers, or the end user.

Risk assessments for parts, assemblies or materials identified as safety-critical (impacting airworthiness, patient safety or electrical hazard potential) are encouraged to follow a Failure Modes and Effects Analysis (FMEA) model. Risk assessments should be completed on all safety-critical manufacturing and inspection processes.

3.6 Identification and Traceability

Suppliers and their sub-tier partners must maintain complete traceability for all materials and components — from raw material through to finished product. This includes traceability by manufacturer’s part number, lot number, and date code for all electrical and electronic components, raw materials, machined parts, assemblies, subassemblies, special processes, and acceptance tests.

Serialization and part marking must align with the purchase order, design data, drawing, or any other contractually agreed specification or standard. Traceability is required from the highest assembly level down to individual component level, ensuring every product can be traced back through the supply chain.

Upon request, suppliers must be able to provide full traceability documentation throughout their supply chain. Commercial off-the-shelf (COTS) items only require traceability to the original manufacturer unless otherwise specified on the purchase order. When requested, suppliers must provide certification that is traceable to the original lot, batch, block, or heat number from the manufacturer, mill, or producer. These certificates must confirm material conformity and be signed by an authorised quality representative, including their name and title.

3.7 Control of Equipment, Tools, and Software

Argus expects suppliers to maintain full confidence in the tools, equipment, and software used throughout production. Equipment, tools, and software programs used to automate, control, monitor or measure production processes shall be validated prior to release for production and shall be maintained. Software used for production, inspection or testing shall be validated prior to use and maintained under configuration control, including software lifecycle controls, backup protocols, patch management and cybersecurity controls.

The supplier shall be responsible for maintaining traceability whether items are calibrated internally or externally. Calibrations should be performed traceable to a national or international standard and documented in calibration records or calibration certificates. Storage requirements shall be defined for production equipment or tooling in storage including any necessary periodic preservation or condition checks.

3.8 Process Control

Suppliers must maintain a clear and controlled process — such as a traveller, router, or process flow sheet — that defines the required procedures for managing quality and configuration at every stage of production.

When Argus issues a design change, including updates to part numbers or revision levels, and work is already in progress, if necessary, suppliers are required to prepare rework instructions and submit them in writing for Argus Engineering approval before any rework begins.

Only products that fully meet the approved specifications are to be shipped to Argus. Any deviations must be formally reviewed and approved through a Supplier Concession Request prior to dispatch.

3.9 Packaging

The supplier shall adequately plan for packaging design and shipment to prevent product contamination, deterioration, damage, or loss. Argus encourages suppliers to select eco-friendly materials and sustainable/reusable packaging that reduces environmental impact.

Suppliers shall include a packing sheet with each shipment and, at a minimum, include:

• Packing sheet number,

• Shipment date,

• Argus PO number,

• All Argus PO line and item numbers, exactly as referenced on the Argus PO, being delivered (this includes intangible items such as software),

• PO item quantity being shipped.

Suppliers shall ensure that the packaging and preservation is adequate to protect the products during transportation, handling, and storage. Packaging shall be appropriate for the size, weight, and fragility of the products being packed, and shall ensure there is no metal-to-metal or part to part contact of finished features. Suppliers shall use part separation/dividers or unitized packing to prevent part-to-part contact or packaging damage. Where possible, individual box weight is not to exceed 15 kg.

Suppliers shall clearly state the shelf life/expiration date on the packaging and the shipping paperwork for material with shelf-life requirements. All chemicals are to be accompanied by a relevant Safety Data Sheet (SDS) or a link to digital copy with each shipment. Goods and products containing items with finite shelf life shall have the expiry date identified on the product and the delivery documentation with the information regarding the recommended storage conditions. The remaining shelf life shall be a minimum of 80% of the total shelf life for the material at time of delivery unless otherwise specified. This applies to items such as, but not limited to, adhesives, compounds, and elastomers.

3.10 Packaging - ESD Sensitive Parts

All electrostatic discharge (ESD) sensitive devices must be clearly identified with an ESD warning label on each product carton and comply with the relevant electrostatic protection standards. Packaging containing ESD-sensitive products shall display an external warning label in accordance with ANSI/EOS/ESD S-8.1.

Products must be packaged to prevent physical damage and to preserve the condition of leads, terminals, and assemblies during handling, storage, and transportation. Unless otherwise specified on the purchase order or subcontract, ESD-sensitive items shall be individually packaged to prevent component-to-component contact; bulk packaging is not permitted.

Suppliers shall use appropriate ESD-protective materials — such as ESD bags, boxes, foam, or bubble wrap — to ensure the safe transport of printed circuit boards (PCBs) and printed circuit board assemblies (PCBAs).

For suppliers shipping cable assemblies or harnesses, packaging must ensure that all connectors are protected and that materials and methods used do not compromise the minimum allowable bend radius of the assembly.

3.11 Foreign Object & Contamination Control

Argus expects suppliers to take a proactive approach to preventing contamination and Foreign Object Damage (FOD) in every stage of production. Suppliers are expected to implement and maintain a Foreign Object Damage (FOD) and contamination control program in accordance with the requirements of AS9146 and ISO13485/ISO14971 as applicable.

FOD and contamination control should be integrated throughout the manufacturing process — from design and assembly to testing and final packaging. Work areas and equipment must be kept clean, and inspections carried out before closing any inaccessible assemblies. FOD and contamination risks should be assessed and documented with applicable mitigation actions.

All FOD or contamination incidents, actual or potential, must be promptly reported and investigated. Argus may request immediate containment or verification actions to protect product integrity. Suppliers shall flow down FOD prevention and contamination control requirements to its sub-tier suppliers.

3.12 Counterfeit Product Prevention

Argus expects suppliers to maintain strong controls that safeguard against counterfeit or suspect counterfeit parts entering the supply chain. Every component, material, and assembly provided to Argus must be sourced directly from the Original Component Manufacturer (OCM), Original Equipment Manufacturer (OEM), or their authorised distributors.

Suppliers must immediately notify Argus if they identify, or have reason to suspect, that counterfeit parts have been supplied. Upon notification, suppliers are expected to isolate the affected material and cooperate fully with Argus in containment, investigation, and corrective actions.

These counterfeit prevention and reporting requirements must be communicated to all sub-tier suppliers and subcontractors to ensure full supply chain integrity and product authenticity.

3.13 New Product Introduction

Suppliers are expected to ensure that all Argus requirements are fully understood and met for every new product introduction. This includes completion of all relevant commercial and legal agreements, clear communication of deliverables and schedules, assessment of supply chain capability, and identification of any critical elements.

For initial production runs or new product launches, Argus may require the submission of a First Article Inspection (FAI) report or a Golden Sample to demonstrate compliance with regulatory, industry, and Argus-specific requirements.

3.14 First Article Inspection

When specified in the Argus contract or purchase order, suppliers shall complete a First Article Inspection (FAI) on a representative part from the first production run. Each FAI unit must be clearly identified and accompanied by a completed First Article Inspection Report (FAIR) for the part or assembly being supplied. Where applicable, the FAIR shall comply with the requirements of AS9102 and/or ISO 13485 and ISO 14971, as relevant to the product type and regulatory context.

In accordance with AS9102 and applicable medical device standards, suppliers shall perform a full or partial FAI whenever any of the following conditions occur:

• Design changes that affect fit, form, or function

• Changes in manufacturing source, process, inspection method, production location, tooling, or materials that could influence fit, form, or function

• Changes to numerical control programs or data translations that may impact product characteristics

• Natural or man-made events that may affect manufacturing capability

• Implementation of corrective actions resulting from a previous FAI

The completed FAIR (full or partial) shall accompany the associated product shipment to Argus.

For deliverables that include software or embedded software, suppliers shall include evidence of software testing, installation, and configuration verification within the FAI documentation package.

3.15 Control and Notification of changes

Suppliers shall ensure planned changes are reviewed and controlled to avoid adverse impacts on product conformity. Suppliers shall establish and maintain processes to ensure product safety throughout the product life cycle. Suppliers shall establish, maintain and control configuration management processes to ensure consistency between design data, manufacturing and inspection.

The supplier shall notify Argus in writing prior to any proposed change to products, materials, processes, facilities or sub-tier suppliers that may affect fit, form, function, reliability or safety. The supplier shall notify Argus of any breakpoints originating from the above changes in writing. For Argus owned designs, the supplier shall seek approval from Argus prior to implementing the change.

3.16 Certificate of Conformance (CoC)

When required, suppliers must include a Certificate of Conformance (CoC) with or on the packing slip for each shipment. The original CoC must be retained by the supplier and made available to Argus upon request. Certificates must be written in English, relate to a single purchase order or delivery, and be protected to prevent deterioration or damage. The document must remain clear and fully legible when received at Argus facilities.

Each Certificate of Conformance must include:

• Date of shipment

• Supplier name and address

• Country of origin

• Argus purchase order number

• Part number and revision level

• Quantity of product supplied

• Serial numbers and/or lot or date codes

• A statement confirming that the goods or services meet all contractual and Argus specification requirements

• Export Control classification (where applicable)

• Signature, name, title, and date of the supplier’s authorised representative

Where a Supplier Concession Request (SCR) has been approved, the corresponding SCR record number must be referenced on the CoC. Deliveries accompanied by an incomplete or nonconforming Certificate of Conformance may be rejected upon receipt.

3.17 Non-Conformance Management

Suppliers shall ensure that non-compliant or non-conforming products are identified, segregated, and properly dispositioned as required per the supplier’s internal procedures. Only product that conforms to specified requirements, and is compliant with all applicable regulations, shall be shipped to Argus.

Suppliers shall:

• Establish a process for detection and feedback of product and process non conformances and non-compliance,

• Maintain records related to the control of non-conforming and non-complying product,

• Perform containment of non-conforming and non-complying product by segregating, identifying, and controlling, the product or process to prevent unintended delivery or misuse,

• Re-inspect and retest any reworked parts prior to shipment to Argus,

• Take necessary actions, within 48 hours, to ensure containment of the effect of the non-conformance on other processes or products, i.e. work-in-progress, stores stock, shipping areas, in transit, sub-tier/ subcontract activities, similar products, products already dispatched and delivered to Argus,

• Clearly and permanently mark product dispositioned for scrap until physically rendered unusable.

The supplier must provide detailed information including part numbers, lot numbers, affected quantities and the nature of the non-compliance or non-conformance. Argus reserves the right to request removal of affected products from circulation, replacement of non-compliant materials, and/or compensation for costs incurred.

Suppliers are required to notify Argus, in writing, within 24 hours of discovering any nonconformance that exists or is suspected of existing on product that has previously been shipped to Argus. This notification shall include the following information, at a minimum:

• Affected Part number(s),

• Description of the nonconforming condition and the affected requirement,

• Quantities, dates, purchase orders, packing slip reference, and destination of delivered shipments,

• Lots, batch numbers, serial numbers, or date codes of the affected items as applicable,

• Containment activities.

3.18 Supplier Concession Requests (SCR)

Suppliers must not ship nonconforming or suspected nonconforming materials to Argus without prior written approval through the Argus Supplier Concession Request (SCR) process. Any nonconformance identified — or suspected — within the supplier’s facility must be reported to Argus immediately.

Production or shipment of the affected product shall not proceed until a completed and signed Supplier Concession Authorization form has been received from Argus.

When shipping approved nonconforming hardware, suppliers must include a physical copy of the signed Supplier Concession Authorization form with the shipment and reference the corresponding SCR number on the Certificate of Conformance (CoC).

3.19 Corrective and Preventative Actions

Argus will inform the supplier of nonconformities that are highlighted at any stage of Argus‘s process flow. In some cases, these non-conformances will need to be addressed through a Supplier Corrective Action Request (SCAR). The supplier shall respond to the SCAR when raised. SCARs shall be processed in a timely manner by the supplier. Receipt is expected to be acknowledged and containment undertaken within 3 days, and the problem contained.

The supplier is expected to respond with a Root Cause Analysis and a detailed corrective and preventative action plan within 10 working days, including details on process, detection and actions. Corrective actions are expected to be performed quickly to correct the root cause(s), while preventative should be taken to prevent problem reoccurrence at the systemic level. Other activities of other similar parts or processes should be included, and the analysis should incorporate appropriate problem-solving tools such as, but not limited to, 5 Why, Ishikawa Diagram, and 8D/9S. These should be included as supporting evidence in SCAR response.

The supplier shall submit evidence of the implemented corrective/preventive action within 30 working days. This evidence will allow the Argus to close the SCAR. The SCAR can be rejected by Argus; the supplier will have a further 10 working days to resubmit for approval and closure.

3.20 Special Processes

Suppliers shall establish, implement, and maintain appropriate process controls to ensure that all special processes are performed in accordance with applicable specifications and consistently achieve the required results. These controls apply, but are not limited, to:

• Plating Operations,

• Specialty Coating,

• Chemical Cleaning,

• Welding/Brazing,

• Materials Testing,

• Heat Treating,

• Surface Treating/ Surface Enhancing,

• Non-Destructive Testing (NDT),

• Chemical Processing,

• Composites (non-metallic materials manufacturing),

• Non-Conventional Machining (including but not limited to EDM, water jet, laser beam machining).

All special processes must be carried out by trained and qualified personnel. Where certification is required, it shall be in accordance with relevant industry, military, or medical device standards. Personnel performing or supervising special processes must hold current certifications appropriate to their scope of work.

Suppliers shall certify that all parts conform to applicable industry, customer, and regulatory standards. Certifications must reference the exact specifications identified on the Argus drawing or purchase order and include any additional special processes performed beyond those originally specified.

Records of certifications, process validations, and audit results shall be maintained and made available to Argus upon request.

3.21 Record Retention & Destruction Requirement

Suppliers shall retain all records related to the quality of products or services delivered to Argus for a minimum of ten years, unless a longer period is specified by contract or regulatory requirement.

For regulated components — including those used in medical devices — suppliers shall retain records in accordance with applicable laws and standards, which may include maintaining documentation for the lifetime of the device plus an additional two (2) years.

All records must be readily retrievable and made available to Argus upon request. At the end of the required retention period, the supplier is responsible for ensuring secure destruction of records. Hard-copy records must be destroyed using a method such as cross-cut shredding that prevents reconstruction or recovery of the information.

3.22 Obsolescence Management

Suppliers are expected to proactively manage the lifecycle of all products and services supplied to Argus. Any planned discontinuation of a product or service must be communicated to Argus in writing at least twelve months in advance to allow for appropriate transition or redesign planning.

4.0 Environmental Compliance and Sustainability Commitment

4.1 Supplier Environmental Compliance

Suppliers shall comply with the Argus Group Supplier Code of Conduct, including ethical conduct, a safe and healthy workplace, protection of the environment and commitment to sustainability. Suppliers shall ensure compliance with applicable environmental, occupational health and safety, business operations, and sustainability regulations.

4.2 Environmental Management System

Argus encourages suppliers to maintain an environmental management system aligned with ISO 14001, demonstrating efforts to prevent pollution, consider product safety and lifecycle, manage waste, and minimize environmental impact.

4.3 Occupational Health and Safety Management System

Argus encourages suppliers to maintain an occupational health and safety management system aligned with ISO 45001, demonstrating their efforts to maintain a workplace safe for all stakeholders, including employees, contractors and the public.

4.4 Sustainability Commitment

Argus encourages suppliers to commit to ongoing sustainability initiatives to enhance environmental, ethical, and social outcomes. Argus actively looks to partner with organisations that align with Argus’ sustainability commitment, and have demonstrated commitment to carbon reduction, ethical mineral sourcing, and circular design.

5.0 Product Safety Compliance and Restricted Materials

5.1 General Product Safety Compliance

As per requirements, Argus and its partners, including customers, will require declarations for applicable legislations, depending on product type and application. Suppliers are required to maintain their own materials compliance process to make full material declarations. Suppliers are expected to respond to material declaration requests in a timely manner.

Suppliers shall notify Argus immediately in writing within 24 hours of any non-compliance, non-conformance or event that could potentially impact product safety.

5.2 Electrical safety compliance

Suppliers providing electrical or electronic components, parts, or materials shall comply with applicable product-safety standards and certifications. These may include applicable CE, IEC, VDE, VG, UL, ETL and CSA standards, including insulation, creepage, clearance, and wiring integrity requirements. Suppliers are expected to comply with national and regional electrical-safety regulations for design, testing and labelling. Suppliers must maintain and provide evidence of valid product-safety certifications where required.

5.3 Hazardous substance control

Suppliers shall maintain current RoHS and REACH declarations of conformity and ensure they are available for review upon request. Components that are exempt under the RoHS directive and REACH regulation shall be clearly identified and justified with reference to the applicable exemption clause. If a supplier becomes aware of any noncompliance, Argus shall be notified in writing within 24 hours, and immediate containment and corrective actions must be implemented.

Suppliers shall not supply materials containing the following restricted or prohibited substances:

• Polychlorinated biphenyls (PCBs)

• Asbestos and asbestos-containing materials

• Ozone-depleting substances (CFCs, HCFCs, Halons)

• Persistent organic pollutants (POPs)

• Radioactive materials

Use of these substances is strictly prohibited unless an exemption is granted by regulatory authorities and approved in writing by Argus.

5.4 Product Cybersecurity and Digital Safety

Suppliers shall implement and maintain appropriate technical and organisational cybersecurity controls proportionate to the products and services provided. Where products include software or networked functionality, and these products will form part of an Argus product to be supplied to customers, particularly for aerospace, defence and medical supply chain, suppliers shall: (a) maintain a secure-by-design development practice and vulnerability management process consistent with FDA/TGA guidance and industry best practice; (b) provide a Software Bill of Materials (SBOM) and evidence of secure build/test procedures upon request; (c) notify Argus of cyber-incidents affecting product safety, confidentiality, or availability within 72 hours of detection and cooperate with Argus and its customers on remediation and notifications; and (d) supply capability for secure updates/patching and provide timelines for critical patch deployment.

6.0 Legal Requirements

6.1 General Legal Requirements

Argus expects suppliers to understand and comply with and remain current on all applicable laws, regulations, directives, codes and industry standards in every jurisdiction in which they operate. Suppliers shall conduct all activities in an ethical, transparent and legally compliant manner consistent with the Argus Supplier Code of Conduct and applicable contractual requirements.

Argus suppliers are required to abide by requirements in component specifications, purchase order terms and conditions, end user agreements, non-disclosure agreements, supplier quality agreements, supply contracts, and to follow the Argus Supplier Code of Conduct, except where a deviation from requirements has been made subject to Argus approval.

6.2 Data protection and security

Suppliers handing Argus data shall comply with all applicable data-protection and privacy regulations, such as the New Zealand Privacy Act 2020, the EU General Data Protection Regulation (GDPR), or other local equivalents.

Confidential and controlled information shall be protected from unauthorized access, disclosure, or loss in accordance with contractual and regulatory obligations. Data security should meet requirements for ITAR/EAR where applicable.

6.3 Environmental, Chemical and Material Compliance

Suppliers shall ensure that all materials, components, and finished goods supplied to Argus comply with all applicable environmental and hazardous substance regulations. These include but not limited to the European Union RoHS Directive (2011/65/EU and amendment 2015/863) and the REACH Regulation (EC) No. 1907/2006. Suppliers shall ensure that all electrical and electronic components, subassemblies, and materials supplied to Argus meet the requirements of the RoHS 3 Directive (2015/863/EU).

Suppliers shall comply with the requirements of the EU REACH Regulation (EC) No. 1907/2006, ensuring that no products or materials supplied to Argus contain substances of very high concern (SVHCs) above the legal threshold of 0.1% (w/w) unless such substances have been declared and approved in writing by Argus.

Other applicable legislation includes the New Zealand Hazardous Substances and New Organisms Act 1996 (HSNO Act), Australian Industrial Chemicals (Notification and Assessment) Act 1989 (INCA Act), and American Toxic Substance Control Act (TSCA).

Some applicable material restrictions legislation may include, but not limited to:

All components and materials:

EU REACH Regulation (EC No 1907/2006)

EU Persistent Organic Pollutants Regulation (Regulation EU 2019/1021)

US iMERC Hg Registration and Labelling

California Proposition 65

California Management of Perchlorate Materials (22 CCR § 67384.1)

Canada Prohibition of Certain Toxic Substances Regulation

Canada Products Containing Mercury Regulations

Australia Asbestos Restriction

Canadian Asbestos Regulation

Components and materials incorporated into electrical and electronic products:

EU RoHS Recast (Directive 2011/65/EU)

EU RoHS Recast Amendment 2015/863 regarding phthalates

Batteries or components and materials incorporated into batteries:

EU Battery Directive (2006/66/EU) Packaging & Waste disposal

EU Packaging Directive (94/62/EC)

WEEE 2012/19/EU

US Toxics in Packaging Restriction

6.4 Conflict Minerals and Responsible Sourcing

Suppliers providing electrical, electronic or mechanical components, parts and materials containing tin, tantalum, tungsten or gold are required to acknowledge and comply with the Dodd-Frank Wall Street Reform and Consumer Protection Act, including Section 1502 Minerals provision regarding responsible sourcing of minerals. Suppliers must complete a current Conflict Minerals Reporting Template (CMRT) on request, and flow-down these requirements to all sub-tier suppliers involved in the manufacture of Argus products.

6.5 Labour, Human Rights and Ethical Standards

Suppliers shall comply with all applicable labour, employment, and human-rights laws in the jurisdictions that they operate. These include laws relating to:

• Child labour, forced labour, and modern slavery.

• Working hours, wages, and benefits.

• Non-discrimination, diversity, and equal opportunity.

• Workplace health and safety regulations.

Suppliers are expected to uphold fair labour practices, provide safe and humane working conditions, and conduct business ethically and transparently. For New Zealand jurisdiction, applicable laws include:

• Employment Relations Act 2000 (ERA),

• Minimum Wage Act 1983,

• Health and Safety at Work (Hazardous Substances) Regulations 2017

• Health and Safety at Work Act 2015 (HSWA),

• Worker Protection (Migrant and Other Employees) Act 2023,

• Human Rights Act 1993.

6.6 Sanctions

Suppliers must ensure that their business activities comply with all applicable trade compliance laws and regulations, including but not limited to:

• United Nations Security Council sanctions - United Nations Security Council Sanctions Committee lists

• New Zealand autonomous sanctions - New Zealand Ministry of Foreign Affairs and Trade (MFAT) Consolidated Sanctions List

• Australian trade and export control laws - Australian Department of Foreign Affairs and Trade (DFAT) Consolidated List of Sanctions Targets

• United States - U.S. Department of the Treasury Office of Foreign Assets Control (OFAC) Sanctions List, the U.S. Department of State International Traffic in Arms Regulations (ITAR), the U.S. Department of Commerce Export Administration Regulations (EAR)

• United Kingdom - United Kingdom HM Treasury Consolidated List of Financial Sanctions Targets

• European Union - European Union consolidated sanctions list

• Any other regional or local sanctions applicable to the supplier’s operations or end users

Suppliers must not engage in transactions, directly or indirectly, with any individual, organisation, or country that is subject to applicable sanctions or embargoes. This includes the provision of materials, components, or technical data sourced from sanctioned parties.

Where products, software, or technical data supplied to Argus are subject to export control classification, including ITAR, EAR, or EU dual-use regulations, suppliers are required to identify and communicate all applicable export control classifications, obtain necessary licences or authorisations before transfer or shipment, and ensure that controlled information is safeguarded against unauthorised access or disclosure.

Suppliers are required to perform due diligence on their own supply chains to ensure that no products, materials, or services originate from or transit through sanctioned entities or jurisdictions, that no funds or financial transactions related to Argus business are directed to or from sanctioned parties, and that sub-tier suppliers are aware of and compliant with these obligations. Argus may request evidence of such due diligence or screening as part of supplier qualification, audit, or ongoing monitoring activities.

Suppliers must notify Argus immediately if they become subject to any trade restrictions, sanctions, or export control investigations, if they discover that any materials or services provided to Argus may have originated from or been associated with a sanctioned entity or jurisdiction, or if they identify any potential breach of applicable trade or sanctions law related to Argus business. Timely notification enables Argus to assess potential impacts and take appropriate mitigating action.

6.7 Import and Export Control

Suppliers shall provide, upon request, the export classification (e.g., ECCN or local equivalent), applicable licence documentation, and retain export/import records for a minimum of 5 years (or as otherwise required by law). Suppliers shall ensure personnel handling export-controlled data receive training and shall immediately notify Argus if they believe a licence is required or if shipments are restricted. For the New Zealand jurisdiction, this includes compliance with the Customs and Excise Act 2018, and the Chemical Weapons Act 1996.

6.8 Medical Devices

Suppliers that provide materials, components, or services used in medical devices shall comply with all applicable medical device regulations and standards, including but not limited to:

• Medicines (Database of Medical Devices) Regulations 2003 (New Zealand)

• Medicines Act 1981 (New Zealand)

• Therapeutic Goods Act 1989 (Australia)

• Therapeutic Goods (Medical Devices) Regulations 2002 (Australia)

• Medical Device Regulation (MDR 2017/745) and In Vitro Diagnostic Regulation (IVDR 2017/746) (EU)

• Federal Food, Drug and Cosmetic Act – Chapter V: Medical Devices, Title 21 (USA)

• Medical Devices Regulations 2002 (United Kingdom)

• Any other local national legislation governing the manufacture and distribution of medical devices.

Suppliers of materials or components used in medical devices must support Argus in meeting applicable device regulatory obligations including UDI/label data, device registration, product master records, and post-market surveillance. Suppliers must notify Argus within 24 hours (or no later than 48 hours) of any event that could reasonably lead to a regulatory reportable adverse event, product recall, or impact device safety. Suppliers will supply evidence and support for regulatory submissions and inspections on request.

6.9 Defence and Aerospace

Suppliers in the aerospace and defence supply chain shall comply with all applicable industry regulation, including the Australian Defence Controls Act 2012 and amendments, including applying export controls according to the Defence and Strategic Goods List. For the EU, compliance shall include the EU’s 2021/821 and use national lists plus the EU’s Common Position on Arms Exports (2008/944/CFSP), and in the UK comply with Export Control Order 2008 (and subsequent amendments) along with the Dual‑Use Regulations (EC) No 428/2009 and the UK’s domestic Consolidated List of Strategic Military and Dual-Use Items. Where there is jurisdiction, the U.S. International Traffic in Arms Regulations (ITAR) and Export Administration Regulations (EAR) shall be complied with where applicable, including any export licensing, re-export, or end-use control obligations associated with controlled technology, software, or data.

If the supplier processes, stores, or transmits Controlled Unclassified Information (CUI) or performs under US DoD or applicable defence contracts, the supplier shall comply with DFARS clauses (including 252.204-7012) and implement the security requirements of NIST SP 800-171 (Rev.2). Suppliers shall provide evidence of compliance (self-assessment, POA&M, or third-party assessment/certification as requested) and will report cyber incidents in accordance with contractual and regulatory reporting timelines. Subcontractors must be flowed down the same obligations.

7.0 Revision History

Version Reason for the revision Date of change

1.0 Initial Draft Version; release 12/12/2025

8.0 Document References

• ISO 9001:2015 – Quality Management Systems ISO Standard

• AS9100D:2016 – Quality Management Systems – Requirements for Aviation, Space, and Defence Organisations Standard

• AS9102C – Aerospace First Article Inspection Requirements

• ISO 13485:2016 – Medical Devices ISO Standard

• ISO 14971:2019 – Risk management for medical devices

• ISO 14001:2015 – Environmental Management ISO Standard

• ISO 45001:2018 – Occupational Health and Safety ISO Standard

• VG/VDE/IEC – Product Standards

• UL/ETL – Product and component certification safety marks

• RoHS/REACH/WEEE – Environmental and chemical safety directives

• ECHA SVHC Candidate List – Verification of restricted substances

9.0 Document Properties

9.1 Document Type & Security

Document Type Supplier Manual

Security Level Approved for Limited External Use

9.2 Export Classification

This document does not contain any export-controlled technical data and is not subject to regulation by any U.S. Export control regime.

9.3 Legal Statement

© 2025 Argus Group Ltd. All rights reserved.
This document (including any attachments and addenda attached hereto) (“Document”) contains the confidential, proprietary, privileged and/or private information and/or trade secrets belonging to Argus Group Ltd. Argus Group Ltd. retains all title, ownership and intellectual property rights to the information and trademarks contained herein. This Document is provided to recipient on a confidential basis for evaluation purposes only, and may not be reproduced, redistributed or transmitted, in whole or in part, without the prior written consent of Argus Group Ltd.