Title: Environmental Product Compliance Requirement for Suppliers. Document No: Page 1 of 7

Title: Environmental Product Compliance Requirement for Suppliers Document No: 760-00001 Change Log Date Rev 2/15/15 A0 Author SS Change Descriptio...
Author: Noreen Peters
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Title: Environmental Product Compliance Requirement for Suppliers Document No: 760-00001

Change Log Date Rev 2/15/15 A0

Author SS

Change Description Initial release

Rev: A0

Approver RS, MP, MH

Page 1 of 7

Title: Environmental Product Compliance Requirement for Suppliers Document No: 760-00001

Rev: A0

1. Purpose : This document serves as a guideline to Tintri Operations and sets the minimum requirements for the entire Tintri Supply Chain for requirements and practices to be adopted for environmental compliance of products/items provided to Tintri. 2. Scope Define responsibility of suppliers in meeting regulatory environmental compliance globally. Define the documentation required of suppliers attesting compliance to noted environmental legislation. 3. Reference Documents 3.1. EU RoHS: 2011/65/EU and its amendments/subsequent versions/annexures. 3.2. EU REACh: 1907/2006/EC and its amendments/subsequent versions/annexures. 3.3. EU Battery Directive: 2006/66/EC and its amendments/subsequent versions/annexures. 3.4. EU Packaging Directive: 94/62/EC and its amendments/subsequent versions/annexures. 3.5. IATA Dangerous Goods regulation: Latest Edition 3.6. Conflict Free Mineral Regulation: Rule 13p-1 under the Securities Exchange Act of 1934 4. Definitions/Acronyms 4.1. RoHS: Reduction of hazardous substances. Widely implied restriction by EU ROHS as max concentration of : 1000PPM for Pb, Hg. Cr6+, PBB and PBDE, and 100PPM for Cd in homogenous material. 4.2. REACh: Registration, Evaluation, Authorization and Restriction of Chemicals. 4.3. SVHC: Substance of Very High Concern. Chemicals identified on European Chemical’s agency’s (ECHA) website that have REACH compliance requirements. 4.4. Tintri Supply Chain: including, but not limited to Contract Manufacturer, Original Equipment Manufacturer, Original Design Manufacturer, Joint Design Manufacturer, Supplier or Vendor 4.5. COC: A Certificate of Compliance that states the standard/ regulation and version to which the certificate applies. 4.6. Material Content Declaration (MCD): As part of REACh conformance, a form based on IPC1752 or IEC62474 filled out by a member of the Tintri supply chain, attesting product, as manufactured, is REACh compliant. 4.7. Conflict Minerals: "Conflict minerals", as defined by the U.S. Securities and Exchange Commission (SEC), is a broad term that means tin, tantalum, tungsten, and gold, regardless of whether these minerals finance conflict in the Democratic Republic of the Congo (DRC) or adjoining countries. 4.8. Packaging: All goods made of any materials of any nature to be used for the containment, protection, handling, delivery and presentation of products from the producer to the customer or the consumer. Packaging can be categorized but is not limited to primary, secondary and tertiary packaging. (JIG-201) 5. Responsibility: It is the responsibility of all Tintri supply chain partners to be compliant with the requirements of this document. Role Responsibility Supplier including Supplier and contract manufacturer to review this specification and sign Contract and return 1x COC ea for compliance with the EU RoHS Directive, EU Manufacturer REACH (include IPC1752/IEC MDS) and as applicable EU packaging directive respectively, for materials/parts supplied to or on behalf of Tintri. Procurement The Procurement manager will ensure that the suppliers & contract manufacturers have been provided this information & responded with a signature on the appropriate COC for each regulation Operations Maintain and update of this procedure. Provide guidance on any Engineering specification relation questions from suppliers.

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Title: Environmental Product Compliance Requirement for Suppliers Document No: 760-00001

Rev: A0

6. Flowchart NA 7. Procedure Product Environmental Compliance Requirements: Tintri is committed to protecting and promoting the natural environment in the communities with which it does business. Tintri will promote the preservation and renewal of resources and will practice socioecological responsibility in all of its corporate operations with a focus on continuous improvement in concert with applicable requirements. Tintri´s desire to identify RoHS conforming, REACH conforming components is in response to legislative mandates to ban hazardous material from electronic products and to meet the growing needs of our valued Customers to supply environmentally friendly products. As a result, we have identified how we would like our supply chain partners to handle this and what kind of communication needs to occur to Tintri. Suppliers shall: 7.1. Notify Tintri, by individual part number its EU-RoHS Compliance Level, including any exemptions claimed. o o o o

Initial compliance notification shall be via a COC. Biannually, supplier shall recertify all qualified Tintri products as being complaint with EU RoHS. Every shipment to a Tintri supply chain partner will be accompanied by an EU-RoHS COC. In order to reduce the reporting handling burden on our suppliers, we recommend a single REACh COC, that lists out all parts supplied to Tintri and exemptions, if any, by part no. See appendix B as reference.

7.2. Notify Tintri, by individual part number, if EU-REACh SVHC contained and compliance to EUREACh. o o o o

Initial compliance shall notification shall be via a COC and MCD. Biannually, supplier shall recertify all qualified Tintri products as being complaint with EU REACh. Every shipment to a Tintri supply chain partner will be accompanied by an EU-REACh COC for that item. Suppliers shall provide Tintri with Part Number attribute data, including but not limited to HAZMAT and EU-REACH SVHC content by percent by weight (%).  MDS for above will per IPC1752 or IEC62474 (provided biannually).

7.3. Additional for Packaging parts only: Notify Tintri, by individual part number, compliance to EUPackaging Directive. o

o o o

Initial compliance notification shall be via a COC.  Lead, cadmium, mercury and hexavalent chromium present in packaging or packaging components shall not exceed 100PPM in packaging or packaging components. Additionally all packaging items shall be marked for material type incompliance with the directive. Biannually, supplier shall recertify all qualified Tintri products as being complaint with EU Packaging Directive. Every shipment to a Tintri supply chain partner will be accompanied by an EU- Packaging Directive COC for that item.

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Title: Environmental Product Compliance Requirement for Suppliers Document No: 760-00001

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Rev: A0

All REACh requirements apply to packaging parts/items.

7.4. Tintri is committed to supporting responsible sourcing of conflict minerals from the DRC and adjoining region. Tintri has adopted a Conflict Mineral’s Policy as part of Tintri’s Environmental Compliance Requirements for Suppliers and expects its suppliers shall adopt similar policies.

Suppliers are required to meet the following expectations: o

Under this policy, suppliers are expected to supply materials to Tintri that are “DRC conflict free” which means either: 1) any 3TGs necessary to the functionality or production of supplied materials must not directly or indirectly fund armed conflict in the DRC or adjoining countries, or 2) any 3TGs must be from recycled or scrap sources.*  * Item 1.01(d)(6) for Form SD, 77 Fed. Reg. 56274, 56364 (Sept. 12, 2012).

o o

7.5. 7.6. 7.7. 7.8.

Establish Conflict Free sourcing practices and set up conflict minerals policies. Provide Tintri with annual supply chain conflict mineral reports documented via CFSI’s CMRT template. http://www.conflictfreesourcing.org/conflict-minerals-reporting-template/. Suppliers shall roll this requirement downstream to their suppliers and gather CMRT reports. o Privately held Tintri suppliers are required to comply with this initiative. Suppliers shall manage distinct Part Numbers when product with identical form, fit and function exists as compliant and non-compliant. Suppliers shall ensure no intermingling of RoHS/REACh conforming product with non-conforming product. Upon request, MCD shall be accessible by Tintri within 24 hours( 1 business day). Infringement of any legislation: Supplier shall notify of Tintri the following (at minimum) within 24 of identifying infringement

o Nature of infringement o Extent of infringement o Product affected, lots, serial nos, etc o Suggested legislative course of action o Planned corrective action o Plan to provide exchange for defective material including install base. 7.9. Suppliers shall identify and ensure compliance to all applicable Global Environmental legislation. Suppliers shall notify Tintri of upcoming legislation changes and consequential change in product/reporting. 7.10. Each individual supplier shall sign and return the Form in Appendix C to Tintri supply chain.

Please contact Tintri Operations Department, with questions about the above RoHS and REACh compliance requirements. 8. Metrics None 9. Records At Tintri, Arena PDM shall be a repository of COC by part no. Form in Appendix C shall be filed by Supply Chain as appropriate. CM partner to maintain COC by each item received. 10.

Forms NA

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Title: Environmental Product Compliance Requirement for Suppliers Document No: 760-00001

Rev: A0

Appendix A: Sample RoHS2 COC text: Company header/letterhead. Company details: Name, Address, location, D&B info.

DECLARATION OF CONFORMITY "Restriction of the use of certain hazardous substances in electric and electronic equipment" (RoHS2), European Directive 2011/65/EU "We (company name) hereby confirm that the products listed hereafter meet the requirements of DIRECTIVE 2011/65/EU OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 8 June 2011 on the restriction of the use of certain hazardous substances in electrical and electronic equipment and its amendments (RoHS2). Use of mercury, cadmium, lead, chromium VI, PBB and PBDE in any materials used to construct this assembly or any of its components do not exceed the maximum concentration values specified except in exempted applications." Item No

2011/6 5/EU RoHS2 Compli ant

123 124 125

Yes Yes Yes

Max Concentration in Homogenous Material of the product (PPM) Cd Hg Pb Cr6 PBDE PBB (limit (limit (limit (limit (limit (limit 100P 1000P 1000P 1000P 1000PP 1000PP PM) PM) PM) PM) M) M)