Flash Group Sustainable Procurement Guidelines

Green Procurement Guidelines

FEIPL/F/SQA/01
Ver. 0.0: Revised Sep 2023

Materials Department,

Flash Electronics (I) Pvt. Ltd.

These guidelines are attached to the Flash Group Sustainable Procurement Guidelines and provide
specific guidelines for green procurement.

Contents

1. Requests to our supplies for their cooperation in green procurement investigations ..2
1.1 Investigation overview ................................................................................................................................. 2
1.2 Content of investigation ........................................................................................................................ 2

2. Regulating chemical substances included in suppliers’ products .......................................... 4

2.1 Chemical substances regulated by Flash Group ................................................................... 4
2.2 Warranty of non-inclusion of chemical substances in procured products..................... 4
2.3 Guidelines for regulating information about chemical substances included in
products (prohibition and control) ................................................................................................... 4
2.4 Regarding changes in materials, manufacturing methods, and information about
included chemical substances ...................................................................................................... 5

Revision History ............................................................................................................................................ 6

Appendixes ...................................................................................................................................................... 7
Annexure I ............................................................................................................................................................ 7
Annexure II ....................................................................................................................................................... 8
Annexure III ...................................................................................................................................................... 9

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1. Requests to our suppliers for their cooperation in green
procurement investigations
With the support of our suppliers, the Flash Group will reinforce its endeavors to provide
environmentally-conscious products. Our suppliers (in an upstream supply chain) are encouraged to
cooperate with us in the investigation of their status.

1.1 Investigation overview

(1) Investigation categories

Investigations are to be conducted for each of the following categories:
(i) The status of the supplier's environmental activities
(ii) The status of reduction of the environmental burden of procured products
(iii) Information about chemical substances included in procured products

(2) Method for replying to investigations

Suppliers are kindly requested to provide the Flash Group with information, in general, by means of
submitting self declaration “Green Procurement Agreement”

(3) Investigation frequency

Suppliers are requested to review the following items periodically (once a year) and submit the self
declaration for status of their environmental activities
(i) the status of reducing the environmental burden of products delivered to Flash Investigations
related to
(ii) information on chemical substances included in the products, will be requested when necessary.
If applicable,

1.2 Content of investigation

(1) The status of environmental activities of suppliers

Investigations of the following items will be made for each supplier (or each business place of a
supplier):

(a) Items related to environmental certifications

■ Acquisition of the ISO 14001 certification or other external certifications approved by Flash
1) Already obtained the ISO 14001 certification.
2) Already obtained another EMS certification.
3) Facilitating or have finalized a plan to acquire external certifications including ISO 14001.

(b) Items related to endeavors for Green Procurement

■ Status of planning Green Procurement
1) Implementing Green Procurement.
2) Planning to implement Green Procurement.
(2) The status of reducing the environmental burden of procured products

(a) Reducing the environmental burden of delivered products

Regarding products the Flash Group procures from suppliers, suppliers are requested to comply with
the items below. Suppliers are also requested to make the same considerations for raw materials and
parts that they procure themselves.

(3) Information about chemical substances included in procured products

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 (a) Information about included chemical substances to be input into Green Procurement Agreement
In accordance with Annexure I, Annexure II, Annexure III enter the following information:

(i) Supplier Details

(ii) Annexure I
(iii) Annexure II
(iv) Annexure III
(b) Investigation format for chemical substances included in products
1. Rotterdam Convention:
Rotterdam Convention is a multilateral treaty to promote shared responsibility and cooperative efforts among
Parties in the international trade of certain hazardous chemicals in order to protect human health and the
environment from potential harm. It has 161 member countries (parties)
This Convention applies to: (a) Banned or severely restricted chemicals; and (b) Severely hazardous pesticide
formulations. All banned chemicals are listed under Annex III of the convention.
More details on Rotterdam Convention at: http://www.pic.int/
2. Stockholm Convention
POPs Convention (Stockholm Convention on Persistent Organic Pollutants) is ratified by more than 170 countries
of promote the abolish of it on a worldwide scale.
The POPs convention, in order to protect human health and environment from Persistent Organic Pollutants
(POPs), prohibits or restricts the manufacturing, use and international trade of chemical substance that are
(1)toxic, (2)persistent, (3)bioaccumulative, and (4)having potential for long-range environmental transport.
More details on Stockholm Convention at: http://chm.pops.int/
3. EU POPs Regulation (EC/2019/1021)
Stockholm Convention is implemented in the European Union by the POPs Regulation, under which ECHA
(European Chemicals Agency) helps to identify and propose new POPs from the EU to the Stockholm
Convention.
More details on EU POPs Regulation at: https://echa.europa.eu/understanding-pop
4. GADSL (Global Automotive Declarable Substance List)
GADSL communicates and exchanges information regarding the use of certain substances in automotive
products (that remains in a vehicle at point of sale). It also indicates the substances that are declarable or
prohibited in IMDS as per global regulations.
Download GADSL List at: https://www.gadsl.org/

3
2. Regulating chemical substances included in suppliers’ products
2.1 Chemical substances regulated by FLASH Group
The FLASH Group uses the "chemical substances regulated by the Customers guidelines to classify
chemical substances contained in procured products into two separate categories, prohibited
substances and controlled substances.

Chemical substances regulated by the Flash Group guidelines

Classification Regulated substances Main legal regulations
Level 1 - Substances Restricted/ Under discussion for restriction as Annexure I
Prohibited per Stockholm Convention
substances

Level 2 - GADSL communicates and exchanges information Annexure I I

Controlled regarding the use of certain substances in automotive
substances products (that remains in a vehicle at point of sale). It also
indicates the substances that are declarable or prohibited
in IMDS as per global regulations.
Download GADSL List at: https://www.gadsl.org/

Note that the regulation factors (such 31 as substance groups, control levels, and threshold values)
might vary depending on the operating division in the Flash Group due to circumstances such as
industry trends. Pay attention to the division's requested items, and check the items accordingly.
In addition, we might request an investigation of the chemical substances used in the production,
storage, and transport stages before delivery (even if the substances are not included in the delivered
product) with the objective of conserving supplies. Suppliers' cooperation is also requested.
2.2 Warranty of non-inclusion of chemical substances in procured products
In the Basic Agreement entered into when trading materials, the Flash Group requests our suppliers
to make certain considerations for the environment. Regarding chemical substances in theirproducts,
suppliers are requested to conduct quality control by warranting the non-inclusion of chemical
substances in their products as necessary.
If non-inclusion of chemical substances in products is stated as a purchase specification requirement
in the trade, documentations such as "Warranty of Non-Inclusion Concerning Banned Chemical
Substances in Products" (Warranty of Non-Inclusion) must be submitted to the Flash Group as a
delivery specification requirement.
"Non-inclusion" indicates that the following is rationally proved regardless of whether inclusion of
the substance is intentional:
- Certain chemical substances are not included, or they are included but at an amount less than the
designated threshold value.

2.3 Guidelines for regulating information about chemical substances included in

products (prohibition and control)
When collecting information about chemical substances contained in products, choose the best way
to do so from an economical and engineering standpoint.
Use of level 1 prohibited substances groups is basically prohibited according to regulations, so
legally, their non-inclusion in products must be guaranteed.
For level 2 controlled substance groups, appropriate management of inclusion information is
required regardless of whether the substances are included in the products. Suppliers are requested to
file reports in all cases; even statements such as "There is no information available that shows
inclusion of the chemical substances" are to be reported when appropriate.

4
2.4 Regarding changes in materials, manufacturing methods, and information
about included chemical substances
If any changes in materials, manufacturing methods, production location, major manufacturing
equipment, persons in charge of manufacturing, etc. are to be made for procured products, suppliers
are required to submit a notice about the details of the change and the scope of effect each time. In
addition, for information on inclusion of chemical substances, submission of a notice is mandatory
when a new inclusion is discovered, or when previously-reported inclusions have changed.

5
 No. Month Revision History
Ver 0.0 Sep 2023 First Issue

6
 Annexure 1
Table A. Substances Restricted/ Under discussion for restriction as per Stockholm Convention (Annex A), Rotterdam Convention (Annex III) & EU POPs
Regulation
CAS No
Sr Name of Substance
(List is only indicative)
70776-03-3
1 Polychlorinated Napthalenes (PCNs) 1321-65-9
1321-64-8
355-46-4
68259-08-5
2 Perfluorohexane sulphonic acid (PFHxS) its salts and related compounds* 1
3871-99-6
(list is not exhaustive)
3 2-(2H-benzotriazol-2-yl)-4,6-ditertpentylphenol (UV-328)*1 25973-55-1
4 Octamethylcyclotetrasiloxane*2 556-67-2
1
5 Dechlorane Plus* 13560-89-9
6 Chlordecone 143-50-0
7 Hexabromobiphenyl 36355-01-8
36483-60-0
68631-49- 2
207122- 15-4
8&9 Hexabromodiphenyl ether and Heptabromodiphenyl ether (commercial octa-BDE)
68928-80-3
446255-22-7
207122-16-5
40088-47-9
5436-43-1
10&11 Tetrabromodiphenyl ether and Pentabromodiphenyl ether (commercial penta-BDE)
32534-81-9
60348-60-9
12 Pentachlorobenzene 608-93-5
25637-99-4
3194- 55-6
134237-50-6
13 Hexabromocyclododecane – HBCDD:
134237-51- 7
134237-52-8
(list is not exhaustive)
14 Hexachlorobutadine - HCBD 87-68-3
15 Commercial Decabromodiphenyl ether (c-Deca BDE) 1163-19-5
335-67-1
3825-26-1
335-95-5
2395-00-8
16 Perfluorooctanoic acid (PFOA), its salts and PFOA-related compounds 335-93-3
335-66-0
376-27-2
3108-24-5
(list is not exhaustive)
85535-84-8
68920-70-7
71011-12-6
17 Short-chain chlorinated paraffins (SCCP) 85536-22-7
85681-73-8
108171-26-2
(list is not exhaustive)
NOTE: *1 - Substances not yet restircted but are under discussion for restriction; *2 - Substances proposed as POPs
Name : Name :

Signature: Signature:

Prepared by Designation Approved by

Designation
(Engineering Head/
(MD/ CEO/ Plant Head)
Quality Head)

Date: Date:

(Contd.) Table A. Banned/ Restricted Substances as per Stockholm Convention (Annex A) & Rotterdam Convention (Annex III)

1691-99-2
1763-23-1
24448-09-7
251099-16-8
2795-39-3
29081-56-9
29457-72-5
307-35-7
18 Perfluorooctane sulfonic acid (PFOS), perfluorooctane sulfonates, perfluorooctane sulfonamides and perfluorooctane sulfonyls
31506-32-8
4151-50-2
56773-42-3
70225-14-8
45298-90-6
306975-62-2
2991-51-7
(list is not exhaustive)
13654-09-6
19 Polybrominated Biphenyls (PBBs)
27858-07-7
20 Polychlorinated Biphenyls (PCBs) 1336-36-3
21 Polychlorinated Terphenyls (PCTs) 61788-33-8
22 Tetraethyl lead 78-00-2
23 Tetramethyl lead 75-74-1
1461-22-9
1983-10-4
2155-70-6
24 Tributyltin compounds 24124-25-2
4342-36-3
56-35-9
85409-17-2
25 Tris(2,3 dibromopropyl)phosphate 126-72-7
1332-21-4
77536-66-4
12172-67-7
13768-00-8
12001-29-5
132207-32-0
Asbestos (Actinolite, Anthophyllite, Amosite, Crocidolite, Tremolite, *Chrysotile)
26 77536-68-6
*Banned as per ISHL (Industrial Safety & Health Law, Japan) & Under discussion in Rotterdam Convention
14567-73-8
77536-67-5
17068-78-9
12001-28-4
132207-33-1
12172-73-5
Name : Name :

Signature: Signature:

Prepared by Designation Approved by

(Engineering Head/
7 Designation

(MD/ CEO/ Plant Head)

Quality Head)

Date: Date:
 Annexure II
Part/ Material/ Consumable Declared in IMDS
S.No. Part Number Name of the substance present
Description (Yes/ No)

Name : Name :

Signature: Signature:

Prepared by Designation Approved by Designation

(Engineering
(MD/ CEO/ Plant
Head/ Quality
Head)
Head)

Date: Date:

8
 Annexure III
Introduction
The substances given in Annexure I are restricted, under discussion for restriction or are proposed as POPs (Persistent
Organic Pollutants) as per the Rotterdam Convention, Stockholm Convention, EU POPs Regulation and GADSL.

1. Rotterdam Convention:
Rotterdam Convention is a multilateral treaty to promote shared responsibility and cooperative efforts among Parties in the
international trade of certain hazardous chemicals in order to protect human health and the environment from potential
harm. It has 161 member countries (parties)
This Convention applies to: (a) Banned or severely restricted chemicals; and (b) Severely hazardous pesticide formulations.
All banned chemicals are listed under Annex III of the convention.
More details on Rotterdam Convention at: http://www.pic.int/
2. Stockholm Convention
POPs Convention (Stockholm Convention on Persistent Organic Pollutants) is ratified by more than 170 countries of promote
the abolish of it on a worldwide scale.
The POPs convention, in order to protect human health and environment from Persistent Organic Pollutants (POPs),
prohibits or restricts the manufacturing, use and international trade of chemical substance that are (1)toxic, (2)persistent,
(3)bioaccumulative, and (4)having potential for long-range environmental transport.
More details on Stockholm Convention at: http://chm.pops.int/
3. EU POPs Regulation (EC/2019/1021)
Stockholm Convention is implemented in the European Union by the POPs Regulation, under which ECHA (European
Chemicals Agency) helps to identify and propose new POPs from the EU to the Stockholm Convention.
More details on EU POPs Regulation at: https://echa.europa.eu/understanding-pop
4. GADSL (Global Automotive Declarable Substance List)
GADSL communicates and exchanges information regarding the use of certain substances in automotive products (that
remains in a vehicle at point of sale). It also indicates the substances that are declarable or prohibited in IMDS as per global
regulations.
Download GADSL List at: https://www.gadsl.org/