MANAGEMENT SYSTEM AUDIT REPORT

MANAGEMENT CERTIFICATION OF NORTH AMERICA

MANAGEMENT SYSTEM AUDIT REPORT

Company Twin Brothers Marine LLC MCNA Ref. No

Address 322 Twin Brothers Road, Highway 83 South Audit Type Louisa, LA 70538

Name: Sead Kirlic

0001030 II

Recertification

Technical Contact Email: [email protected] Position Manager Employees 70

Tel: 337-923-4981 ext 204

Audit Criteria Standard(s) : ISO 9001 :2015 Accreditor ANAB Site(s) 1

Team Leader Mike Colvin Auditors N/A

Observer I N/A Trainee N/A I Expert NIA Witness Auditor

Audit Date Sept 3, 2021 (Day 1 Remote) Total Audit-day 4.5 I Risk Level High

Sept. 14 - 17, 2021 - (3.5 Days On-site)

Recommended Fabrication of Oilfield-Related Offshore Production Platforms, Decks

Certification and Underwater Structures ; Custom Fabrication of Large Diameter IAF 17 NACE 28.1 Scope Heavy Wall Tubulars; Modification and Repair of Steel and Aluminum

Vessels

No. of CARs CATI I 0 I CATII I 0

Audit team's conclusions about the effectiveness of the management system:

Choose Applicable Statement

Summary : This was Twin Brothers Marines recertification audit. Due to Covid-19 and Hurricane Ida Twin Brothers Marine, LLC recertification audit was broken up to complete day 1 of the audit remotely on 91312021 using MSTeams to review and assess the Management, Internal Aud it, and Corrective Action Processes . The remainder of the audit was completed 9/14-17/2021 on-site. The combination of the remote I on-site audit was effective in achieving the audit objectives.

There were no CARs issued and 1 Opportunities for Improvements identified .

For Surveillances and Re-Certification Audits Only Findings Are there any repeat I repetitive nonconformities from previous aud it(s)? No Are there any Changes or Recommended Changes affecting the Certification Scope? Yes (If ves comolete change section on page 2)

Next Audit Date: I July 26 - 28, 2022 Does audit team recommend additional time at the next audit to verify implementation and

I No

effectiveness of corrective actions resulting from identified nonconformities? If yes , state additional time required I N/A

Team Leader

Client representative

Accredited I Scheme Office Review

Form 04-2b Audit Report

©TWH Group Ventures LP 2008

Mike Colvin

Sead Kirlic (Emailed copy of repo,t)

:;J~~ lJ. N~

Rev 3

Date

Date

Date

9/22/2021

9/22/2021

9/23/2oz.,1

May 2 1, 202 1

Page I of9

Management Certification of North America


Form 04-2b Audit Report Rev 3 May 21, 2021 ©TWH Group Ventures LP 2008 Page 1 of 9

Company Twin Brothers Marine LLC MCNA Ref. No 0001030

Address

322 Twin Brothers Road, Highway 83 South Louisa, LA 70538

Audit Type Recertification

Contact Name: Sead Kirlic

Email: [email protected] Tel: 337-923-4981 ext 204

Position Technical Manager Employees 70

Audit Criteria Standard(s): ISO 9001:2015 Accreditor ANAB Site(s) 1

Team Leader Mike Colvin Auditors N/A Observer / Witness Auditor N/A Trainee N/A Expert N/A

Audit Date Sept 3, 2021 (Day 1 Remote) Sept. 14 – 17, 2021 – (3.5 Days On-site) Total Audit-day 4.5 Risk Level High

Recommended Certification Scope

Fabrication of Oilfield-Related Offshore Production Platforms, Decks and Underwater Structures; Custom Fabrication of Large Diameter Heavy Wall Tubulars; Modification and Repair of Steel and Aluminum Vessels

IAF 17 NACE 28.1

No. of CARs CAT I 0 CAT II 0

Audit team’s conclusions about the effectiveness of the management system: Choose Applicable Statement Summary: This was Twin Brothers Marines recertification audit. Due to Covid-19 and Hurricane Ida Twin Brothers Marine, LLC recertification audit was broken up to complete day 1 of the audit remotely on 9/3/2021 using MSTeams to review and assess the Management, Internal Audit, and Corrective Action Processes. The remainder of the audit was completed 9/14-17/2021 on-site. The combination of the remote / on-site audit was effective in achieving the audit objectives. There were no CARs issued and 1 Opportunities for Improvements identified. For Surveillances and Re-Certification Audits Only Findings Are there any repeat / repetitive nonconformities from previous audit(s)? No Are there any Changes or Recommended Changes affecting the Certification Scope? (If yes complete change section on page 2)

Yes

Next Audit Date: July 26 – 28, 2022

Does audit team recommend additional time at the next audit to verify implementation and effectiveness of corrective actions resulting from identified nonconformities?

No

If yes, state additional time required N/A

Team Leader

Mike Colvin

Date 9/22/2021

Client representative Sead Kirlic (Emailed copy of report) Date 9/22/2021

Accredited / Scheme Office Review Date

mmart

Highlight




Changes affecting the scope of certification(s) Instructions:

1. Contact MCNA office for approval prior to initiate changes. 2. Choose“Yes” box on page 1 of audit report to indicate changes identified.

Detail of change: Increase/decrease in number of employees Employee count changed from 93 to 70 employees. Audit Duration changed from 5.0 days to 4.5 days. Changed Certification Scope to: Custom Fabrication of Large Diameter Heavy Wall Tubulars, including pressure vessels and structural steel fabrication. Scope was modified to simplify and be more in line with product currently produced. Audit Criteria

The requirements of ISO 9001:2015 and the defined processes and documentation of the client’s management system.

Audit Objective

Recertification Audit:

The purpose of the recertification audit is to confirm the continued conformity and effectiveness of the management system as a whole, and its continued relevance and applicability for the scope of certification.

- The recertification audit shall consider the performance of the management system over the period of certification and include the review of previous surveillance audit reports.

- Recertification audit activities may need to have a stage 1 audit in situations there have been significant changes to the management system, the client, or the context in which the management system is operating (e.g.: changes to legislation).

- In the case of multiple sites or certification to multiple management system standards being provided by the certification body, the planning for the audit shall ensure adequate on-site audit coverage to provide confidence in the certification.

The recertification audit includes an on-site audit that addresses the following:

a) The effectiveness of the management system in its entirety in the light of internal and external changes and its continued relevance and applicability to the scope of certification

b) Demonstrated commitment to maintain the effectiveness and improvement of the management system in order to enhance overall performance,

c) Whether the operation of the certified management system contributes to the achievement of the organization’s policy and objectives

Objectives of the audit The Objectives of the audit were met. Yes If no, provide details on why they were not met and recommended actions: Deviations from audit plan Were there any deviations from the audit plan? Yes If yes, provide details: Due to Hurricane Nichols and reduction in employees the audit plan was modified from 5.0 days to 4.5 days. Start and End time was adjusted for Day 2 (9/14/2021). Appropriateness of the Certification Scope The scope of certification has been reviewed and is appropriate to the activities of the company Yes If no, provide details and recommended actions:

mmart

Highlight




Date and places where audit activities were conducted: (addresses of facilities assessed at this audit – including on-site or off-site, permanent or temporary sites)

Date Site Address On-site or Off-site Perm. or Temp # Audit Day(s) Sept 3, 2021 322 Twin Brothers Road, Highway 83 South,

Louisa, LA 70538 US Off site Perm. 1.0 Days

Sept. 14 – 17, 2021 322 Twin Brothers Road, Highway 83 South, Louisa, LA 70538 US On site Perm. 3.0 Days

Report Writing 322 Twin Brothers Road, Highway 83 South, Louisa, LA 70538 US Off site Perm. 0.5 Days

Shift Start Time of Shift End Time of Shift

1 7:00am 3:00pm

Auditing All Shifts Yes / No

Have all shifts been audited? Yes

If all shifts were not audited provide justification on why they weren’t all audited: N/A Facilities on Certificate and Activities at each site: 322 Twin Brothers Road, Highway 83 South, Louisa, LA 70538 US

Total No. of Employees at All Sites 70 Certificate: Issued on: 09/10/2018 Expires on: 09/27/2021 The information listed above was reviewed with the client and:

☒ Confirmed to be correct ☐ Changes Identified - Noted above in the Details of Change Section of Report

Requirements identified as not applicable Are there requirements of the Standard not applicable to Twin Brothers Marine LLC QMS? Yes

Requirement not applicable Justification

8.3 Twin Brothers produces product to customer specifications (Quality Manual Section 1.0 Introduction)

Outsourced Processes Does the organization have any outsourced processes? If yes, list these processes: 1. Heat Treating, 2. NDT Yes

If yes, has the organization implemented adequate controls over these processes? Yes

Quality Management Processes

Has the organization determine the processes needed for the QMS and the inputs required, and outputs expected from these?

Yes

Interested Parties Has the organization determined interested parties relevant to the Management System? Yes

Risks Has the organization determine the risks and opportunities that need to be addressed? Yes

Legal & Other Requirements

Has the organization identified applicable legal and other requirements? Yes




Verification of Corrective Action(s) on Previous Audit Nonconformities Were corrective actions for previous identified nonconformities verified as effective? N/A If no, please provide details: N/A Changes to the management system since the previous audit For Surveillance and Re-Certification Audits (Delete for Initial Audits) The use of the logo(s) of the accreditation body and of the MCNA logo was in compliance with the Rules for Use of the Mark established by MCNA (If the answer is "No", provide details here):

Yes

Were there any significant changes to the executive management of the organization? (If the answer is "Yes", list changes here): Darrell Webster is now President (previously General Manager) Sead Kirlic is now VP Technical & Quality (previously Technical Manager)

Yes

Were there any significant changes to the certified management system? (If the answer is "Yes", list changes here):

No

Management review: Yes / No

Management reviews met all requirements of the Standard and management review process is effectively implemented and maintained.

Yes

Inputs: ISO 9001, Section 9.3.2 Management Review Input Outputs: ISO 9001, Section 9.3.3, Management meeting agenda, Management meeting minutes, Action items Documents/Records: QPP 0930-01, Management Review, QA Form 29.0, Quality Objectives, QA Form 30.0, Management Review Record, Management Review Meeting minutes, 8/23/2021, QA 7.5 Risk Action Planning Document, QPP-0610-01 Risks and Opportunities Procedure, rev. B Audit Notes: (Including objective evidence of both compliance and noncompliance) President, VP Finance, and VP Technical & Quality were interviewed. QPP 0930-01 defined the requirements for management review. Management reviews were held annually as a minimum. QA Form 30.0 was used to document the management review meeting minutes. Additional attachments were included in the file of information covered in the meeting. QA Form 29.0 was used to document and monitor progress towards the Quality Objectives. Objectives are listed below in the report. Overall performance towards the goals were satisfactory. A Risk Action Planning form was updated annually to identify current risks. A rating system was used to rank the level of Occurrence and Impact of each identified risk. Based on the ratings short-term and long-term preventive controls were identified and status recorded. Management review meeting minutes dated 8/23/2021 was reviewed. Interested Parties identified by TBM included Customers, Suppliers, Employees, Owners / Management, Regulatory & Statutory Agencies. Needs and expectations for each interested party was identified in the Quality Manual.

Internal audits Yes / No

Internal audits were effectively implemented and in conformance with the requirements of the standard. Yes Inputs: ISO 9001:2015 Standard, Audit Schedule Outputs: Completed Internal Audits and Corrective Actions Documents/Records: QPP 0920-01, Planning and Execution of Internal Audits, Rev. E, Internal Audits for 2021 Audit Notes: (Including objective evidence of both compliance and noncompliance) QPP-0920-01 defined the requirements for internal audits. Audits were completed periodically throughout the year. Requirements were for each process to be audited at least once over a 3-year period. Internal audits for 2021 reviewed were:

• #21-01 Top Management • #21-03 Quality Objectives

• #21-04 Procurement • #21-08 Internal Audits / Corrective Actions

Audit planning form for the past 3 years was reviewed to ensure all processes were audited over the 3-year cycle. Nonconformities identified during internal audits resulted in a corrective action being issued and processed through the corrective action process.




Corrective actions / Continual Improvement Yes / No

Corrective actions were effectively implemented and in conformance with the requirements of the standard.

Yes

Inputs: Customer Complaint, Internal Audit Nonconformance, Internal Nonconformance Outputs: Completed Corrective Action Documents/Records: QPP-1020-01 Corrective Action rev. B, Corrective Actions Audit Notes: (Including objective evidence of both compliance and noncompliance) Requirements for corrective actions were defined in QPP-1020-01. A Nonconforming Product and Corrective Action Log (QA Form 50.0) was maintained for tracking both NCR’s and C/A’s. 1 CAR was issued in 2020 and 1 CAR was issued in 2021 YTD. CAR #01-2020 issued from Internal Audit #20-01 Painting was reviewed during the 2020 24-month surveillance audit. The CAR was for a painting storage issue. Correction, root cause and corrective action were completed. A follow-up was also completed to verify and record the effectiveness of the actions taken. CAR #01-2021 was issued 8/25/2021 for 2021 Quality Objectives for (Weld Repair Rate & Cost of Quality Ratio) not being met YTD in 2021. This CAR was recently issued and still in-process. TBM was analyzing the deficiencies to identify issues to improve the processes and reduce weld repair rate and improve the cost of quality ratio. Audit Summary – (Including Results of Processes Audited and conclusion regarding effectiveness of each process) Positive aspect in regard of the management system:

• Management’s commitment to the quality management system and customer satisfaction. • TBM’s maintains ASME Certification

Opportunities for improvement / Potential Risk / Observations

• Consideration may be given to attention to details during the estimating / contract review process. (Typo’s identified).

General Comments: Process: Contract Review Inputs: Customer Order Requirements, ASME Code Requirements Outputs: Finished Product Documents/Records: Customer Orders, Drawings, Specifications NDT Test Results, QPP-0820-01 Contract Review, rev. C, QPP-0820-02 Project Start-up Rev. C, QPP-0820-03 Project Management Rev. C, Audit Notes: (Including objective evidence of both compliance and noncompliance) Production process was audited for the Conrad Project (Job #2474 and 2475) and the Massman Project (Job #2470). Personnel interviewed were knowledgeable on the requirements pertaining to their area of responsibility. Conrad Project (Job #2474 & 2475) – 4 Tanks Contract Review / Project Management – Job Folder reviewed: Proposal PV0964(R2) – ASME Section VIII Div. 1 required, Customer PO was received and reviewed. Job Notification (Form QA13.2) and Job Work Order (Form QA 13.0) were completed and sent to required personnel. The tanks were in the early stages of Production. Massman Project (Job #2470) – Water Intake and Outfall System Proposal, Job Notification and Job Work Order were reviewed. Drawings were provided by the customer. Estimating generated spreadsheets calculating material and labor cost for the project. Customers contracts or purchase orders received were verified against the quote to ensure requirements matched. Overall Performance of Process Audited: Process effectively implemented and maintained







Process: Purchasing (including control of outsource processes) Inputs: Purchase Requisition for Product, Outsource Processes, or Service Outputs: Purchase Order to Approved Supplier Documents/Records: QPP-0842-01 Evaluation of External Providers, QPP-0843-02 Purchase Order Placement, QA Form 8.0 Vendor Performance Evaluation, QA Form 8.1 Subcontractor Performance Evaluation, QA Form 8.4A Vendor & Subcontractor Information Questionnaire, Purchase Orders, Purchase Requestions, Material Certificates. Audit Notes: (Including objective evidence of both compliance and noncompliance) Purchase Requirements were defined in QPP-0843-02 Purchase Order Placement and QPP-0842-01 Evaluation of External Providers. Purchase Orders reviewed clearly defined the requirements for the product, service or outside process.

• PO 112956 Universal Steel – Plate 0.500” x 96” x 384” ASTM A36/ABS, MTR’s required • PO 113139 Carbonline Company – Paint, MTR’s Required • PO 111851 Analytic Stress Relieving – Post Weld Heat Treat (PWHT). Project Work order provided. Supplier

came on-site and performed the PWHT. • PO 112689 Forged Components – Forged Nozzles (several sizes)

Purchase orders were found to provide clear detail requirements for the product or service provided. Purchase Orders were placed to suppliers on the Approved Suppliers List. An Annual Supplier Evaluation was completed. Approved Suppliers were maintained on an approved suppliers list. Annual evaluations were completed and a rating assigned. Rating for suppliers was different than the rating system used for outsourcing processors. Suppliers needed a rating above 21 and outsource processors needed a rating above 110. Evaluations were verified for:

• Universal Steel – rating 29 • Carbonline – rating 24 • Analytic Stress Relieving – rating 153

Overall Performance of Process Audited: Process effectively implemented and maintained Process: Project Management / Production Process Inputs: Customer Order Outputs: Completed Job Documents/Records: Customer Order, Drawing, Material Certificates, Job Orders, Weld Procedures, Welder Qualification Cards, Inspection Records, NDT Test Results, NCR Reports, X-Rays, QPP-0860-03 Process Pipe & Leak Testing, rev. B, QPP-860-04 Painting, Blasting & Inspection, rev. F, QPP-0860-05 Post Weld Heat Treat, rev. B, QPP-0860-06 Inspection & Testing, rev. B, QA Form 3.2 Coating Inspection Report, QA Form 3.3.1 Application Record, QA Form 14.1 Quality Inspection Report. Audit Notes: (Including objective evidence of both compliance and noncompliance) Project Management / Production Processes were audited for: Conrad Project (Job #2474 & 2475) – 4 Tanks Requirements defined in the Job Work Order (Form QA 13.0) and within drawings / specifications. (ASME Code Requirements Applied). Verified receiving for:

• Forged Components against PO 112688. Incoming verified quantity and visual for correct part. Heat Numbers were verified against the Material Certs. Receiving signed and dated the packing list to indicate acceptance.

• Steel Plate against PO 112787. SA36 Plate. HT #S24405 – Material Cert on file. Packing List signed & dated. Welding Process: Preheat 225o – Temp-stick used to monitor temperature. Verified Type of Weld and Welder Qualification against Weld Procedure. Welder – Trey Guyote / Stencil #59. The tanks were in the early stages of Production. Massman Project (Job #2470) – Water Intake and Outfall System Job Work Order reviewed. Drawings were provided by the customer. Verified Weld, Coating, and NDT Testing completed per requirements. Project near completion. (Non ASME project – API 2B / API 2A-WSD) Welds reviewed Joint P-3-4, Can PG-16, Plate 42 (Heat #S29752); Joint P-3-4, Can PG-18, Plate 38 (Heat #S29741). All




welds – E70xx per drawing. Structural Steel UT Tested 5% of Welds if > 10% defective (1 weld) then increase sample to 10%, if >10% defective, must 100% inspect welds. No welds were defective. For Piles welds were 100% RT. Coating requirements were CTE (Coal Tar Epoxy) 16 mils minimum. Paint records showed Mil Thickness requirements met, Coating Batch #, and Coating Shelf Life Expiration date. Inspection Release Certificate signed by customer. Observed shipping of Pile – Loading on Barge for shipment. Customer Representative on-site to supervisor and coordinate the loading of the Piles (5) on the barge along with additional components for the Job that was sent to Twin Brothers for loading on the barge. Post Weld Heat Treating completed by Analytic Stress Relieving service on-site at TMB. Nonconforming Product: 4 NCRs issued in 2021. Reviewed NCR’s: 001/2021 ASME Post Weld Heat Treat – charts weren’t signed by TBM. Charts signed. 002/2021 Material – Supplier JSW Steel 003/2021 ASME – Supplier Uniform Components – crack in head Overall Performance of Process Audited: Process effectively implemented and maintained Process: Calibration Inputs: IM&TE Requiring Calibration Outputs: Calibrated IM&TE Documents/Records: Calibration Records Audit Notes: (Including objective evidence of both compliance and noncompliance) A Calibration Log was maintained that tracked the IM&TE that required to be calibrated. The log identified the Equipment Type, Model #, Serial Number, Calibration Date, Next Calibration Date, Days from Last Calibration, and Instrument Location. IM&TE were calibrated by an outside calibration service. Calibration Certificates were maintained showing calibration status. IM&TE verified for calibration were:

• Digital Infrared Thermometer S/N 37771350WS, Cal 2/4/21, Due 2/4/22 • Coating Thickness Gage S/N 110005084, Cal 12/1/20, Due 12/1/21 • UT Thickness Gage S/N 03110708, Cal 4/29/21, Due 4/29/22 • Site Level Gage S/N 195-60726, Cal 2/24/21, Due 2/24/22 • Laser Distance Micrometer S/N 024512609, Cal 12/15/20, Due 12/15/21

Calibration Certificates showed the As Found / As Left Results and evidence of traceability to NIST. Overall Performance of Process Audited: Process effectively implemented and maintained Process: Resource Management Inputs: Training Required Outputs: Completed Training Documents/Records: Job Descriptions, Employee Training Records Audit Notes: (Including objective evidence of both compliance and noncompliance) Job Descriptions were available for each job. The Job Descriptions specified:

• Degree of Education Required • Experience Required • Training • Specific Knowledge / Skills • Essential Job Duties & Responsibilities

Training Records were verified for

• Huang Nguyen – Welder • Trey Guyote – Welder • Mike Blanchard – Purchasing • Stephan Paul – Roller • Chad LeJeune - Burner • Chris Migues – Quality Control Inspector

Overall Performance of Process Audited: Process effectively implemented and maintained




Process: System Documentation Inputs: Documents requiring to be controlled Outputs: Controlled Documents Documents/Records: Quality Manual, Procedures, and Forms. Audit Notes: (Including objective evidence of both compliance and noncompliance) Various documents were reviewed during the audit to ensure revision control and current revisions were being used. Documents sampled / verified included:

• Quality Management System Manual ISO 9001:2015, rev. 2 • QPP-0610-01 Risk and Opportunities, rev. B • QPP-0715-01 Control of Inspection, Measuring & Test Equipment, rev. B • QPP-0820-01 Contract Review, rev. C • QPP-0820-02 Job / Project Start-up, rev. C • QPP-0842-01 Evaluation of External Providers, rev. D • QA Form 13.0 Job Work Order, dated 6/30/21 • QA Form 13.2 Job Notification, dated 7/02/21

Overall Performance of Process Audited: Process effectively implemented and maintained Performance on quality objectives/targets: Current Quality Objective/Targets 2020 Goal

2021 2020 YTD 2019 YTD

Comments –Revised

Goal TRIR 1.00% 0.00% 0.00% 0.00%

C/A 01-2021 was initiate

for goals not met.

Lost Time Rate 0.00% 0.00% 0.00% 1.74% Weld Repair Rate – Yard ≤1.0% 0.00% 0.00% 0.47% Weld Repair Rate – Mill ≤0.9% 1.76% 0.86% 0.86% Weld Repair Rate – Process Pipe ≤10% 0.00% 0.00% - Cost of Quality 1.0% 1.81% 0.55% 0.59% No. of Returned Products 0 0 0 0 On Time Delivery 100% 100% 100% 100% Performance summary Effectiveness of the management system over the previous 3 years: Record the results of your review below: • previous audit report results including nonconformities trends and comments over the 3 years.

A review of the previous 3-year audits showed no adverse trends identified with minimum CARs. Actions taken were effective in addressing the nonconformities.

• the organization’s performance history including objectives & targets over the 3 years.

Performance to the companies KPIs were found to be acceptable with some minor issues over the 3 year certificate cycle.

Results of Review:

Based on the review of data over the past 3 year certification cycle it was determined that TBM has effectively maintained their QMS.

Disclaimer: Audits are based upon a sampling process of the available information which introduces an element of uncertainty and the audit recommendations are subject to independent review. Those relying or acting upon the information included in this report should be aware of the above.


Memorandum of Agreement

MEMORANDUM

WE ACKNOWLEDGE RECEIPT OF THE RULES AND REGULATIONS Rev 5, 16 February 2017 AND AGREE TO BE BOUND BY THEM.

CERTIFICATION CAN ONLY BE ISSUED WHEN THIS DOCUMENT HAS BEEN RETURNED.

TECHNCAL MANAGER SIGNED ............................................................... POSITION ......................................................

SEAD KIRLIC (PRINT NAME) .............................................................................................................................

0001030 ORGANIZATION Twin Brothers Marine LLC 322 Twin Brothers Road, Highway 83 South Louisa, LA 70538

07/07/2021

DATE ...............................................

Please return to:

Operations Manager Management Certification NA 51 E. Crystal Canyon Circle The Woodlands, TX 77389 Tel: 713-906-5176 Fax: 281-271-8112

Form 04-7 Memorandum of Agreement Rev 10 16 February 2017 ©TWH Group Ventures LP 2008 Page 1

Rules for Certification

Doc 02-3 Certification Rules Rev 5 16 February 2017

©TWH Group Ventures LP 2008 Page 1 of 2

1. Certification Operations In order to obtain and retain certification all applicants to the Operations must adhere to the following procedures and rules of the Operations. All information deemed necessary by Management Certification of North America in order to complete the initial audit / evaluation programme should be made available by the applicant. Management Certification of North America shall be responsible for all actions of certification, from the initial audit/evaluation of the client's System through periodic surveillance visits and re-assessment audits/evaluations. Management Certification of North America shall inform the applicant of the initial audit/evaluation results and if not satisfied that all the requirements for the certification are being met, shall inform the applicant of those aspects in which the application is deemed non-compliant. When the applicant can demonstrate that effective remedial action has been taken to meet all the requirements within a specified time limit, Management Certification of North America will review the remedial action and determine the suitability of awarding certification. All certificate holders will be entitled to provide feedback and suggestions relating to the potential areas for improvement. Management Certification of North America reserves the right to make minor changes and corrections to these Rules & Regulations without prior notification. Clients will be given 1 month’s notice of any changes that affect their responsibilities or liabilities. The applicant shall ensure that the question of responsibility to Management Certification of North America for the System is clearly defined, e.g. by appointing a designated person who is nominated to maintain contact with Management Certification of North America to ensure that the above provisions have been observed. The applicant shall permit Operations accreditation representatives all reasonable access for the purpose of observing Management Certification of North America’s auditors/evaluators performing initial audit/ evaluation and/or surveillance activities. Applicants will not be required to provide access on more than one occasion. 2. Initial Audit/Evaluation for Certification Initial audits/evaluations shall be conducted against the applicant's procedures and the requirements of internationally accepted - product certification Operations, - management system standards - European Directives - and/or sector Operations’ series of documents. 3. Certification When an initial audit/evaluation has been completed and systems deemed to be satisfactory by the Certification Board or its subcommittee, the relevant Operations Manager of Management Certification of North America shall inform the applicant accordingly and issue a certificate. Surveillance frequency will be stipulated at six month, nine month or twelve month intervals, but additional visits may be conducted at the discretion of the Management Certification of North America’s Operations Managers. The certificate is valid for three years from date of issue or re-audit. The certificate will remain the property of Management Certification of North America and shall be returned on request. All clients shall maintain a log of all complaints they receive which fall within the scope of registration for which a certificate has been awarded. 4. Extending Certification

A Company wishing to extend its certificate to cover additional products, processes, services or sites shall apply to the Operations Manager in writing. The Operations Manager shall review the nature of extension and decide on the necessary audits/evaluations to be performed. 5. Publicity by Certificate Holders (Clients) A client has the right to publish that the, process or service and company have been audited/evaluated by a member of Management Certification of North America and apply a mark of conformity to promotional materials for which the certificate applies. In every case, the client shall take sufficient care of its publications and advertising so that no confusion arises between certified and non-certified processes and/or services. The client shall not make any claim that could mislead purchasers to believe that a product, process, service, site or organization is covered by the certification when in fact it is not. 6. Confidentiality Management Certification of North America shall endeavour to ensure that its employees and agents maintain secrecy concerning all confidential information with which they become acquainted as a result of their contacts with the client. 7. Misuse of a Certificate Management Certification of North America shall take all reasonable precautions to control the use of its certificates. Incorrect references to certifications or misleading use of certificates found in advertisements; catalogues, etc. shall be dealt with by suitable actions, which could include legal or corrective action or publicising the transgression. Clients are invited to report to the Operations Manager any misuse of the Management Certification of North America ’s marks which comes to their attention. The source of all information received will be treated in confidence. 8. Suspension of Certification The certificate applicable to a specific product, process, service, site or organization may be suspended for a limited period, for example in the following cases: - - if the surveillance or re-audit shows non-compliance with the requirements which are of

such a nature that immediate withdrawal is not necessary. - if a case of improper use of the certificate, e.g. misleading prints or advertising, is not solved

by suitable retractions or other appropriate remedial measures by the client. - if there has been any other contravention of the rules and regulations of Management

Certification of North America. - if corrective action requests (CAR’s) have not been implemented within specified time

scales. - if the surveillance or re-audit is delayed by more than 1 month beyond the due date The client shall not identify as certified any product, process or service that has been offered under a suspended certificate. The Operations Manager of Management Certification of North America will confirm an official suspension of the certificate to the client. At the same time the Operations Manager shall indicate under which conditions the suspension shall be removed. At the end of the suspension period, an investigation will be carried out to determine whether the indicated conditions for reinstating the certificate have been fulfilled. On fulfilment of these conditions the suspension shall be removed by notifying the client that the certification has been reinstated. If the conditions are not fulfilled, the certificate shall be withdrawn. All costs incurred by Management Certification of North America, in the suspending and reinstating of certificates will be charged to the client. 9. Withdrawal / Cancellation of Certificate A certificate may be withdrawn in the following cases: - - if the surveillance or re-audit shows that the non-compliance is of a serious nature.

Doc 02-3 MCNA Certification Rules Rev 5 16 February 2017

©TWH Group Ventures LP 2008 Page 2 of 2

- if the surveillance or re-audit is overdue for specified time scales - if the client fails to comply with the due settlement of its financial obligation. - if inadequate measures are taken by the client in case of suspension. - if any actions are taken by the client which would bring the Management Certification of

North America ’s Operations into disrepute. In the above cases Management Certification of North America has the right to withdraw the certificate by informing the client. The Operations Manager shall then notify the Governing Board. The company shall have the right to appeal. Certificates will be cancelled in the following cases: - - if the client does not wish to continue to maintain certification to the Operations. - if the product, process or service is no longer offered - if the client ceases trading for whatever reason. 10. Corrective Actions When Management Certification of North America receives a report of certificate misuse the report shall be investigated. If misuse is substantiated, the cost of the investigation shall be paid by the certificate holder. Management Certification of North America will determine the scope of misuse and the type of corrective action to be undertaken. 11. Complaints against Management Certification of North America Should the client have cause to complain regarding the conduct of Management Certification of North America’s staff, the complaint should be made in writing and addressed to the relevant Operations Manager of Management Certification of North America. Should the complaint be made against the Operations Manager, the letter of complaint should be addressed to the President. 12. Appeals Procedure Notification of failure to comply with the requirements of certification may be given for, but not limited to, the following: - - deficiencies in management systems observed during initial audit, or surveillance visits,

revealing non-conformity with certification requirements. - misrepresentation or misuse of certification. - misrepresentation or misuse of the Accreditation Body’s logo The company / organization has the right to appeal against any notification given. Notification of an organization's intention to appeal must be made in writing, and must be received by the relevant Operations Manager of Management Certification of North America within fourteen days of receipt of notification of failure to comply with the certification requirements. All appeals shall be submitted to the Advisory Board. The Operations Manager of Management Certification of North America shall be required to submit evidence to the Advisory Board to support the decision to issue a notice of non-conformity. The company / organization has the right to object to involvement of particular members of MCNA’s Advisory Board in the appeals procedure if evidence can be provided that their impartiality is compromised. The appellants also have the right to present their case in person at their own expense. The decision of the Advisory Board shall be final and binding on both the organization and Management Certification of North America. Once the Advisory Board has made a decision regarding an appeal, no counter claim by either party in dispute can be made to amend or change this decision. Decisions on appeals will be made within 4 months of receipt of the appeal. In instances where the appeal has been successful and the award made or reinstated, reimbursement of costs of appeals will only be made at the discretion of the Advisory Board. 13. Fees Management Certification of North America shall be entitled to charge fees at a level to be determined from time to time having regard to its costs relating to administration. Commercial arrangements are detailed in contracts or other agreements between Management Certification of North America and the applicants or clients.

Cancellations, postponements or schedule changes requested by the Applicant between:

thirty (30) days’ and fifteen (15) days advance notice will incur a charge of 50% of the audit fee and any applicable non-reimbursable expenses occurred.

Fourteen (14) and seven (7) days advance notice will incur a charge of 75% of the audit fee and any applicable non-reimbursable expenses occurred.

Less than seven (7) days advance notice will incur a charge of 100% of the audit fee and any applicable non-reimbursable expenses occurred.

Audits in progress that are terminated prematurely at the request of the Applicant will be invoiced for the amount quoted for the complete audit. Stage I and II audits can be conducted back to back; (except for Aerospace Program Audits) however, we do not recommend this approach. If the Stage I requirements are not fulfilled and the auditor cannot recommend proceeding to a Stage II then there may be travel related change fees and audit cancellation/change fees associated with rescheduling or cancelling the audit. 14. Structural Changes to Systems and Organizations All clients are required to keep their system documentation up-to-date and to notify the Operations Manager of Management Certification of North America of any significant changes to the organization’s systems or structure. In particular, any changes which may affect the scope of certification or which result in a new appointment to the position of Senior Management Systems Representative must be reported. Management Certification of North America’s auditors must be notified of all changes made to the management system since the previous visit. 15. Disputes Any disputes subject to legal proceedings will be settled in accordance with the Laws of the United States of America. 16. Additional Requirements for AS9100 and AS 9120 (AQMS) Clients AQMS organizations may not request AQMS auditor changes/substitutions without substantiated evidence of auditor improper activity or contract violations. AQMS certified organizations shall allow MCNA to provide Tier 1 data (i.e., information on the issued AQMS standard certificate -public domain) and Tier 2 data (e.g., information and results of audits, assessments, nonconformances, corrective action, scoring, and suspensions -private domain) to the OASIS database. Organizations shall provide access to the Tier 2 data in the OASIS database to their aviation, space, and Defense customers and authorities, upon request, unless justification can be provided {e.g., competition, confidentiality, conflict of interest). If AQMS certified organizations lose their AQMS standard certification, they shall provide immediate notification to their aviation, space, and Defense customers. Organizations shall identify an OASIS administrator and be responsible for notifying the CB of significant changes within the organization (e.g., changes related to address, ownership, key management, number of employees, scope of operations, customer contract requirements).

Organizations shall assure that MCNA invoices for services and OASIS publication fees are paid timely. Organizations shall agree that ANAB’s, Industry OP assessors, customer representatives, and regulatory authorities may accompany an MCNA audit for the purpose of oversight witness or the confirmation of the effectiveness of MCNA’s audit process MCNA clients that must comply with classified material or export control requirements, related to MCNA auditor access, are advised that compliance with these requirements will affect audit planning activities. Clients are required to inform MCNA if such restrictions are in force. MCNA shall retain records of the disclosure and agreements regarding auditor access.

The scope of certification shall not include processes that were not audited to sufficient depth to verify client (organization) conformance. Where processes are not audited and are excluded from the potential scope of certification, any such exclusion shall be limited to those processes that are permissible exclusions within the AQMS standard and that are effectively documented by the client. MCNA shall not certify the client's quality management system, where the process exclusions do not represent permissible exclusions.

17. Addendum – IAF Communiqué on Expected Outcomes for Accredited ISO 9001 Certification