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MANAGEMENT MANUAL Quality, Environmental and Occupational Safety Edition June 2009 GERMANY

Quality, Environmental and Occupational Safety - XELON · 2.2.1.5 Quality, environmental and occupational safety management, internal revision 22 2.2.1.6 Purchasing 23 2.2.1.7 Information

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MANAGEMENT MANUAL

Quality, Environmental andOccupational Safety

Edition June 2009GERMANY

ISO 14001:2004

SYSTEM CERTIFICATION

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General

Management responsibility

Resource management

Product realization

Measurement, analysis andimprovement

Terms and defi nitions

Management Manual

PRYSMIAN Kabel und Systeme GmbHDeutschland

Edition: Juni 2009

ii

Contents Page1 General 1

1.1 Foreword 1

1.2 Preparation, review and release 2

1.3 PRYSMIAN Kabel und Systeme GmbH 3

1.3.1 Company headquarter 3

1.3.2 Location Berlin 5

1.3.3 Location Schwerin 7

1.3.5 Location Eschweiler 11

1.3.4 Location Neustadt 9

1.4 Documentation 13

1.6 Control of records 14

2 Management responsibility 17

2.1 Commitment, strategy and planning 17

2.1.1 Corporate statement of policy 17

2.1.2 Management objectives and management programmes 17

2.2 Responsibilty, authorities and communication 18

2.2.1.1 Chief Executive Offi cer (CEO) 20

2.2.1.2 Business Units 21

2.2.1.3 Operations 21

2.2.1.4 Research, development and engineering 22

2.2.1.5 Quality, environmental and occupational safety management, internal revision 22

2.2.1.6 Purchasing 23

2.2.1.7 Information technology 23

2.2.1.8 Finance, administration and control 24

2.2.1.9 Human resources and organization 24

1.5 Control of documents 14

2.2.1 Organizational structure 18

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Contents Page2.2.2 Representatives for quality, environmental and occupational safety management 25

2.2.2.1 Representative for PKS management (quality, environmental and occup. safety) 25

2.2.2.2 Quality representative (QB) 25

2.2.2.3 Environmental protection representative (UB) 26

2.2.2.4 Specialist for occupational safety (SiFa) 26

2.2.3 Assignment of tasks in the fi eld of environmental protection and occupational safety 27

2.2.4 Communication 28

2.2.5 Factory and information security, data protection 28

2.3 Management review 29

3 Resource management 31

3.1 Provisions of resources 31

3.2 Human resources 31

3.2.1 General 31

3.2.2 Competence, training and awarness 32

3.3 Infrastructure 34

3.4 Work environment 34

4 Product realization 37

4.1 Planning of product realization 37

4.1.1 Workfl ow and procedures for environmental and occupational safety management 37

4.1.2 Statutory and other requirements 38

4.2 Customer-related processes 38

4.2.1 Process model 39

4.2.2 Determination of customer requirements 39

4.2.3 Review of customer requirements 39

4.2.4 Communication with customer 39

4.3 Development 40

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Contents Page4.3.1 Product realization process 40

4.3.1.1 Development planning 41

4.3.1.2 Development inputs 41

4.3.1.3 Development outputs 41

4.3.1.4 Development review 41

4.3.1.5 Development verifi cation 41

4.3.1.6 Development validation 42

4.3.2 Product adaptation process 42

4.4 Purchasing 42

4.4.2 Selection of suppliers 43

4.4.4 Orders, modifi cation of orders 43

4.4.5 Technical delivery conditions, quality assurance agreement 43

4.4.6 Acceptance and receipt of goods 44

4.4.7 Purchasing of trade products 44

4.4.8 Purchasing of intercompany products 44

4.5.1 Production control 44

4.5.2 Validation of production process 46

4.5.3 Identifi cation and traceability 46

4.5.4 Customer property 47

4.5.5 Product maintenance 47

4.5.5.1 Handling 48

4.5.5.2 Storage 48

4.5.5.3 Packing and preservation 48

4.5.5.4 Shipment 49

4.4.1 Defi nition of product descriptions, quality assurance and enviro. protection measures 42

4.5 Production 44

4.4.3 Qualifi cation and assessment of suppliers 43

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Contents Page4.6 Control of monitoring and measuring devices 49

5 Measuring, analysis and improvement 53

5.1 Planning 53

5.2 Monitoring and measurement 53

5.2.1 Custromer satisfaction 53

5.2.2 Internal audit 53

5.2.3 Monitoring and measurement of processes and products 54

5.2.3.1 Receiving inspection 54

5.2.3.3 Final inspection and testing 55

5.2.3.4 Inspection and test records 56

5.2.4 Monitoring and measurement of environmental relevant processes 56

5.2.4.1 Checks by the person responsible 56

5.2.4.2 Checks by the maintenance department 56

5.2.4.3 Checks by the environmental protection representative 56

5.2.4.4 External reviews 57

5.3 Control of nonconforming products and processes 57

5.4 Emregency provisions and measures 58

5.5 Risk minimization 58

5.6 Data analysis 59

5.7 Improvement 60

5.7.1 Continual improvement 60

5.7.2 Corrective and preventive action, precaution 61

5.7.3 Quality tools 63

6 Terms and defi nitions 65

5.2.3.2 In-process inspection and testing 55

5.2.4.5 Measurement 57

General > Foreword > Preparation, review and release > PRYSMIAN Kabel und Systeme GmbH > Company headquarter > Location Berlin > Location Schwerin > Location Neustadt > Location Eschweiler > Documentation > Control of documents > Control of records

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11 General

1.1 Foreword

The expectations of our customers, our social responsibility, corporate obligation and, last but not least, statutory requirements demand a high and constant quality of our products as well as a high environmental standard in compliance with occupational safety provisions and the generally rules of technology.

The Chief Executive Offi cer (CEO) of PRYSMIAN Kabel und Systeme GmbH in Germany (PKS) has expressed the obligation in the management policy to safeguard the quality of the products and to improve environmental protection and occupational safety through an integrated management sys-tem. For this purpose, objectives and continually effective measures related to planning, assurance and continual improvement of quality, environmental protection and occupational safety are establis-hed and followed-up. At regular intervals, the persons responsible ascertain the adherence to these objectives and measures and verify the adequacy and effectiveness of this management system.

The PKS management system for quality, environmental protection and occupational safety is based on management policy and is supplemented by documented procedures and provisions and fulfi ls the requirements on quality management according to the standard DIN EN ISO 9001 and the quality standard IRIS for the railway industry. The safety specifi cation KTA 1401 is a supplementary basis for the quality management, on environmental management according to the standard DIN EN ISO 14001 an on occupational safety management according to the specifi cation OHSAS 18001.

The management system for quality and environmental protection was recertifi ed by

• SGS Yarsley International Certifi cation Services, an international well know and active certifi cation body and accredited environmental verifi er,

in 2001 and is being monitored through an annual surveillance audit.

The management system for occupational safety was certifi ed by

• the Berufsgenossenschaft Energie Textil Elektro (BGETE)

in 2005 and is being monitored annually.

This management manual is applicable in PRYSMIAN Kabel und Systeme GmbH and instructs all employees of PKS. It also serves as information for our customers and is used by them as a basis for the assessment of the PKS management system.

General

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1 1.2 Preparation, review and release

Preparation and review of this management manual is coordinated by the department PKS QES. The manual is released by the PKS Chief Executive Offi cer. This printed edition is not subject to revision service. After substantial changes, the current edition will be prepared.

• Prepared and checked by: Organizational unit: PKS QES Name: Rolf Walter Lampe Date: June 2009

Signature:

• Released by:

Organizational unit: PKS CEO Name: Günter Philippi Date: June 2009

Signature:

General

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11.3 PRYSMIAN Kabel und Systeme GmbH

1.3.1 Company headquarter

The address of the corporate management is:

PRYSMIAN Kabel und Systeme GmbHAlt-Moabit 91DD-10559 Berlin

PRYSMIAN Kabel und Systeme GmbH (PKS) is a subsidiary of PRYSMIAN S.p.A. in Milan. The corpo-rate management has its headquarter at the location Berlin.

Production takes place at the locations Schwerin, Neustadt bei Coburg and Eschweiler. Sales activi-ties are car-ried out at the locations Berlin and Neustadt bei Coburg. The PKS management system applies equally to all these locations.

Headquarter Manufacturing location Sales location

Fig. 1-1: Locations in Germany

General

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1The PKS product range comprises medium and low voltage cables, installation and house wiring cables, industrial and special cables as well as fi ttings.

These products are manufactured and inspected and tested in accordance with national and inter-national standards, to own specifi cations and on request, to customer specifi cations.

The main customers in Germany and abroad are:

• power supply utilities• trade and installers• industry, infrastructure and equipment construction, e.g. shipbuilding, mining, medical technology

Additional company-related key data (rounded off):

Location Personnel

(Status 12/08)

Ground space

(m²)

Built-up area

(m²)

ProducedTonnage

(t/a)

(Financial year 2008)

Berlin 50 -- -- --

Schwerin 320 574.000 96.000 80.000

Neustadt b. Cbg. 400 199.000 89.000 26.500

Eschweiler 200 160.000 68.000 10.800

Total PKS 970 934.000 253.000 117.300

Tab. 1-1: Company data

The locations in Berlin, Schwerin, Neustadt bei Coburg and Eschweiler are described in detail in the sections 1.3.2, 1.3.3 and 1.3.4.

General

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11.3.2 Location Berlin

Address:

PRYSMIAN Kabel und Systeme GmbHAlt-Moabit 91DD-10559 Berlin

Fig. 1-2: Photograph location Berlin

Location description:The head quarter is located in the borough of Mitte/Tiergarten, in the district of Moabit on the pre-mises of Focus Teleport Berlin. In the south of the premises is the Spree river and in the north the city park “Kleiner Tiergarten”. In the west and east are further business, administrative and residen-tial buildings.In direct proximity (approx. 1 km) is the area of government district.

Road and railway connections:• Autobahn A100: 4 km• Airport Berlin-Tegel: 8 km• main station: 2 km

General

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1History of the location Berlin

1847 Founding of the company Telegraph-Construction Offi ce Siemens & Halske, Schöne-berger Straße

1876 First cable factory in Berlin, Markgrafenstraße / Kreuzberg1883 Location Salzufer, Charlottenburg1899 Cable factory in Westend, Nonnendamm / Siemensstadt1912 Cable factory in Gartenfeld, Gartenfelder Straße1945 Dismantling of Siemens factories including cable factory in Gartenfeld, re-construction

of the metal and cable factory after the war as power and communication cable fac-tory

1970-1990 Rebuilding of various production lines (PVC- and XLPE-insulated cable) as well as struc-tural improvement with modernization and refi tting older buildings

1993 Installation of a 600 kV testing hall1998 Name changed to Pirelli Kabelwerk Berlin following the sale of Siemens AG power ca-

bles division to Pirelli Cavi e Sistemi S.p.A. in Milan2002 Suspension of manufacturing at the location Berlin2005 Name changed to PRYSMIAN Kabel und Systeme GmbH2007 Removal to the new location Alt-Moabit

The following PKS organizational units are located on the location Berlin:• Corporate management• Central department Quality, Environmental and Occupational Safety Management• Central department Purchasing *)

• Central department Information Technology *)

• Central department Finance, Administration and Control *)

• Central department Human Resources and Organization *)

• Business unit Power Distribution• Business unit Trade and Installers • Business unit Telecom

*) with branch offi ces at the locations Schwerin and Neustadt b. Cbg. and Eschweiler

General

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11.3.3 Location Schwerin

Address:

PRYSMIAN Kabel und Systeme GmbHKabelwerk SchwerinSiemensplatzD-19057 Schwerin

Fig. 1-3: Photograph location Schwerin

Location description:Kabelwerk Schwerin (KWS) is located in the commercial and industrial district of Schwerin-Sacktan-nen, in its own part of the town without any residential buildings. In addition to KWS, which is the largest company, its factory premises also accommodate a number of mainly small fi rms and enter-prises. It is a drinking water conservation area.On the southern edge of the factory premises, the nearby community of Wittenförden has estab-lished a commercial estate with roughly 20 small and medium-sized enterprises, it border on Lake Neumühler in the north.

General

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1Road and railway connections

• airport Berlin-Tegel, via A24, direction Berlin, approx. 200 km• airport Hamburg-Fuhlsbüttel, via A24, direction Hamburg, approx. 140 km• Schwerin main station, approx. 9 km

History of the Kabelwerk Schwerin

1960 Founding of the Kabelwerk Schwerin as Kabelwerk Nord, part of KWO, 54 employees1963 Production of power cables, electric lines and shipboard cables, 1000 employees1968 Kabelwerk Nord given the status of an independent factory within the KWO collective

combine; foundation stone laid fort he telecommunication cable shop (Shop No. 13)1971 Kabelwerk Nord ist he second-largest cable factory in the German Democratic Repub-lic

(„East Germany“), 1600 employees1976 Production of telecommunication cable fi ttings, motorcar power cables, suspension ca-

bles and consumer products1982 Production start for XLPE-insulated medium-voltage cables1990 Commissioning of an electron accelerator; company converted to Schweriner Kabel-

werke GmbH1992 Merger with Siemens AG, start made to change the infrastructure and logistics by in-

vestments amounting to approx. DM 170 million1998 Name changed to Pirelli Kabelwerk Schwerin following the sale of Siemens AG power

cables division to Pirelli Cavi e Sistemi S.p.A. in Milan2002 Production transfer from Pirelli Kabelwerk Berlin to Kabelwerk Schwerin2005 Name changed to PRYSMIAN Kabel und Systeme GmbH

The Schwerin factory produces XLPE-insulated medium-voltage cables, installation and house wiring cables, halogen-free cables with improved behaviour in case of fi re, shipboard cables, PVC- and XLPE-insulated low-voltage cables as well as PVC compounds and rubber fi ller compounds. Further-more is the department Research, Development and Engineering for energy cables (PKS R&D E) located on the location.

Energy and water quantities (data: fi nancial year 2008)• electrical energy 39.140 MWh• gas 1.196.010 m³• well water 18.400 m³• fresh water 40.500 m³• waste water 40.500 m³

General

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11.3.4 Location Neustadt

Address:

PRYSMIAN Kabel und Systeme GmbHKabel- und Leitungswerk NeustadtAustraße 99D-96465 Neustadt bei Coburg

Fig. 1-4: Photograph location Neustadt

Location description:Kabel- und Leitungswerk Neustadt is located in a growing industrial area on the southern edge of Neustadt bei Coburg. The nearest residential area is roughly 300 m away in the north-east. Beyond this, at a distance of about 1.2 km, there is a water conservation area (wells for the water supply of the town Neustadt bei Coburg). The small river Röden fl ows by roughly 600 m in west.Most of the water supply comes from the company’s own wells. Drinking water is taken from the public main.

Road and railway connections• approx. 65 km to Autobahn A9 (north/south/east)• approx. 70 km to Autobahn A70 (north/south/west)• approx. 10 km to Autobahn A73 (north/south)

General

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1• Regional station of the Deutschen Bahn AG in Neustadt• Inter city train stop Lichtenfels (approx. 25 km)• Airport Nürnberg (approx. 120 km)

History of the Kabel- und Leitungswerkes Neustadt1937 Factory founded by Siemens Schuckert, production of power cables1943 Wire drawing shop established1951/1952 Production of telecommunication cables started1955 Shop No. 2 and offi ce building constructed1962 CV cross-linking technology introduced1963 Rubber and PVC mixing plant extended, Shop No. 3 constructed for production of

telecommunication cables1975 Wire drawing shop extend, Technikum (Technical School) constructed1983 Set-up of an electron accelerator plant in the production sector1986 Production of fi bre-optics cables started1990 A salt bath cross-linking plant established1998 Name changed to Pirelli Kabel- und Leitungswerk Neustadt b. Coburg following the sale

of Siemens AG power cables division to Pirelli Cavi e Sistemi S.p.A. in Milan2002 Erection of a new CV-system to network special cables2005 Name changed to PRYSMIAN Kabel und Systeme GmbH

The Neustadt factory produces rubber-insulated power cables for transmission of electrical energy and control signals. Furthermore are the Business Unit Original Equipment Manufacturer, Contrac-tors (PKS OEM/C) and the department Research, Development and Engineering for special cables(PKS R&D S) located on the location.

The major product groups• rubber-insulated fl exible cables• X-ray cables assemblies• cables for cranes and lifting equipment• cables for mining industry• shipboard cables• airport cables• cables for use in drinking and waste water• cables for special applications (e.g. functional endurance in case of fi re)• cables for railway industry (Rolling Stock)

Energy and water quantities (data: fi nancial year 2008)• electrical energy 26.770 MWh• gas 1.104.410 m³• well water 534.630 m³• fresh water 5.510 m³• waste water (direct discharge) 348.000 m³• waste water (indirect discharge) 11.730 m³

General

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11.3.4 Location Eschweiler

Address:

PRYSMIAN Kabel und Systeme GmbHKabelwerk EschweilerDürener Straße 340D-52249 Eschweiler

Fig. 1-5: Photograph location Eschweiler

Location description:Kabelwerk Eschweiler (KWE) is located at the eastern outskirts of Eschweiler.The next-situated residential area is in approximately 100 m removal in northern direction. In southern direction, the factory-terrain borders on agricultural usefulness-area, with which river „Inde“ in ap-proximately 300 m removal. The water supply of the factory to cool-purposes taken place to the biggest part from the river.In eastern as well as western direction, the premises borders on growing industrial areas.

Road and railway connections• highway A4 (west / east) approx. 1 km• highway A44, west / east / north, approx. 6 km• regional railway station of the Deutsche Bahn AG in Eschweiler, approx. 3 km

General

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1• Inter city railway stations Aachen or Düren approx. 15 km• airport Cologne / Bonn approx. 80 km• airport Düsseldorf approx. 90 km

History of the Kabelwerk Eschweiler1815 Acquire the Hovermühle through the family Lynen to Manufacture of copper-wires and - pays1886 Foundation of the Lynenwerkes; fi rst cable-production at the location Eschweiler1890 Foundation a company sickness benefi t fund1896 Build a copper-wire drawing department and a condom - Rolling mill1910 Erection a lead-press1944 Evacuation of the work after beautiful-forest1945 Repatriation of the work after Eschweiler 1952 Foundation of the Indewerkes to the manufacture of plastic - Swim vests 1987 Co-founders the Berlin fi berglass - factory (BGF)1992 Modernization of the production-facilities above all for the manufacture of communication cables 2001 Foundation of the FACAB LYNEN GmbH; takeover the Lynenwerke GmbH & Co. KG

through the company Faber - Kabel2008 Foundation of the PYSMIAN cable factory Lynen Ltd. & Co. KG; merger by law of the

factory at the PRYSMIAN Kabel und Systeme GmbH.

The factory Eschweiler produces special-cables to the transfer of electric energy and from tax-signals under use of rubber - and plastic - materials. Moreover, cables are produced for the signal - and data transmission (telecom).

The major product groups• Rubber - hose lines• Mining-managements• Diving-motor-managements for the use in drinks - and dirty waters• Security-cables and - cores with function-receipt in the fi re-case• Signal - and communication cables• Rubber - Compounds and –Color concentrate

Energy and water quantities (data: fi nancial year 2008)• electrical energy 8.900 MWh• gas 750.000 m³• river water (Inde) 168.000 m³• fresh water 35.000 m³• waste water (directly) 598.000 m³ • waste water (indirectly) 6.850 m³

Allgemeines

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11.4 Documentation

On the basis of PKS management policy, this manual serves the purpose of describing the integrated management system of PKS, as well as the documentation of competences and responsibilities fort he business processes. In addition to the company profi le, it contains the basic provisions related to the processes, procedures and operations used. Furthermore, it serves as a guideline for procedures, operational documents and other documents which describe processes, procedures and measures in detail. It is the responsibility of the superiors to ensure that the contents of the manual are know to the staff.

Procedures contain regulations and process descriptions (sequences) applicable throughout the PKS group whereas operational documents give concrete operational details of internal activities related to planning, control, testing and inspection and improvement of processes, from Marketing through Recycling. These documents ensure that the relevant activities are carried out under controlled con-ditions.

All employees are obliged to notify any changes in processes, operations and procedures, to the competent superiors who shall initiate the up-dating of the documentation concerned.

The PKS documentation has the following structural arrangement:

Further reference documents for the documentation of the PKS management system are manuals and guidelines/directives of PRYSMIAN S.p.A., which have overriding status.

General

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1 1.5 Control of documents

Our document control system ensures that necessary current documents are made available in an appropriate manner, in proper time and at the required location/workplace.

Controlled documents and data are defi ned as documents and data which describe the functions of all operational processes at PKS, interprocess interfaces, as well as the interfaces to other manage-ment systems. They can be available as hard copies or stored as data fi les. These documents and data are produced, checked, released, distributed, registered, revised and archived by the organiza-tional units responsible.

The data system technology for document control system at PKS is based on a suitable software with defi ned rights of processing and access. It is assured that the computerized data is available in all relevant departments of the company.

1.6 Control of records

Records provide evidence of an effective quality, environmental and occupational safety manage-ment. They also provide for documentation of the fulfi lment of customer, statutory, standards, qual-ity and environmental requirements of the delivered products. These records include the manage-ment review protocols and reports on internal and external audits.

Other records are listed below:• test and inspection records, test certifi cates, tests and inspection check lists• (acceptance) inspection protocols• test and inspection reports, also from suppliers• calibration data• overview of nonconformities, statistics• inspection catalogues

The annual location-related reports on environmental protection and the central report of loss pre-vention are an important part of records related to environmental protection and occupational sa-fety.

Other subject-related records are listed below:• annual report over transportation of dangerous goods• annual environment report• annual health- and occupational safety report• protocols concerning revisions of dangerous goods• annual reports over radiological protection• overview of environment-relevant plants• statements on current status or on accomplishments related to waste, water, energy• records from committee for occupational safety (ASA)• accidents analysis and reports• patrol inspection records, site inspection protocols• measurement records (e.g. emissions)• records on instructions issued

These records are fi led in a proper manner by the responsible organizational units and archived at an appropriate location for the specifi ed period of retention. If required by contract or law (e.g. for nuclear power stations), the records shall be accessible to authorized external persons.The retention periods for documents and records are specifi ed.

General

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Management > Commitment, strategy and planningresponsibility > Corporate statement of policy > Management objectives and management programmes > Responsibility, authorities and communication > Organizational structure - Chief Executive Offi cer (CEO) - Business Units - Operations - Research, development and engineering - Quality, environmental and occupational safety management, internal revision - Purchasing - Information technology - Finance, administration and control - Human resources and organization > Representatives for quality, environmental and occupational safety management - representative for PKS management system (quality, environmental and occupational safety) - Quality representative (QB) - Environmental protection representative (UB) - Specialist for occupational safety (SiFa) > Assignment of tasks in the fi eld of environmental protection and occupational safety > Communication > Factory and information security, data protection > Management review

16

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2

2 Management responsibility

2.1 Commitment, strategy and planning

2.1.1 Corporate statement of policy

The top management of PKS has established and documented a management policy. It is geared to the fulfi lment of requirements and expectations of customers. Furthermore, it contains statements on general principles and fundamentals of activities related to quality, environmental protection and occupational safety.

The application and continual improvement of the integrated management system of PKS ensure that our policy is understood and implemented at all levels.

The management plan is used for strategic alignment of the work areas and for precisely defi ning the corporate objectives. The requirements placed on the integrated management system are defi ned under this planning system. This plan covers:

• environmental analyses of the market, customers, suppliers and competition (benchmar-king)

• derivation of requirements placed on the integrated management system in order to accom-plish targeted market positions and improvement potentials

• clear, demanding, attainable and measurable objectives• provision and approval of the necessary resources• time schedules and plans of action for goal accomplishment

The results of planning are documented.

2.1.2 Management objectives and management programmes

PKS manages all organizational units of the company with agreed objects which are documented in annual management plans.

Monthly and annual reporting is conducted within the Group in accordance with uniform instruc-tions.

At the beginning of each fi nancial year, the Chief Executive Offi cer sets the objectives for quality, environmental and occupational safety management. These objectives form an essential part of the continual process of improvement within the PKS management system and support the overall ob-jectives of the company.

At the beginning of each fi nancial year, within the scope of a cascade of goals, sub goals are derived in the organizational units in the form of goal programmes for quality, environmental and occupatio-nal safety management, partial goals derived, persons with responsibility nominated, the completion date determined and, where necessary, the required resources defi ned and approved.

Meetings are held at regular intervals between assigned persons and responsible persons to review and document the level of goal accomplishment.

Managementresponsibility

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2

2.2 Responsibility, authorities and communication

This chapter describes the PKS organization, defi nes responsibilities and authorities, describes the delegation of duties, defi nes the assignment of tasks, and regulates communication, data protection and the factory and information security.

2.2.1 Organizational structure

The basic principle of the PKS organization and its management system is the greatest possible delegation of responsibilities and tasks in order to provide scope for action to enable customer re-quirements to be met fully and on schedule.

Within the scope of his organizational responsibility, the Chief Executive Offi cer has the obligation to organize the company in suffi cient detail so that only conforming and safe products are brought onto the market.

Structure of organization:

• Chief Executive Offi cer (CEO)• Business Units• Factories• Central Departments

The organization chart of PKS is updated at least once a year and distributed as controlled docu-ment. Organisation sheets and assignment of tasks in the business units, factories and central de-partments are subject to the same requirements. Detailed processes related to quality, environmen-tal and occupational safety management in the business units, factories and central departments are described and defi nitely covered by operational documents.

The representative for the integrated management system at PKS (quality, environmental and occu-pational safety) reports directly to the Chief Executive Offi cer. He participates jointly with the repre-sentatives for quality and environmental protection and the specialists for occupational safety in the organizational units, in the further development of the management systems.

Managementresponsibility

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2

The job-related coordination with the Sector PRYSMIAN S.p.A. is made by the organizational units “Corporate Quality” and “Operations, Health, Safety and Environment”.

Fig. 2-1 Operational chart quality, environmental and occupational safety management

Managementresponsibility

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2

2.2.1.1 Chief Executive Offi cer (CEO)

PRYSMIAN Kabel und Systeme GmbH is the Germany subsidiary of PRYSMIAN S.p.A. in Milan and is engaged in design and development, manufacture and sales of cables, wires and systems. For this, the Chief Executive Offi cer bears the management responsibility.

Relating to the management system for quality, environmental protection and occupational safety, this responsibility encompasses the following:

• defi nition and enforcement of management policy, -goals and targets• coming into effect of the management manual• guarantee customer requirements and needs• approval of market strategy, prices policy and product ranges• compliance with statutory requirements and other regulations• maintenance of the management system with clear organizational structure, responsibilities

and delegation of tasks• defi nition of target programs for a continuous improvement of management systems• provision of the necessary resources for performance in all organizational units• performance of management reviews

The Chief Executive Offi cer coordinates the business strategies, ensures their implementation in the individual PKS organizational units and represents the PKS externally and internally.

Within the scope of his overall responsibility, he also bears the responsibility for product. This in-cludes the responsibility for product safety and product design commensurate with safety require-ments. Furthermore, product responsibility also covers among other things the aspects of circular fl ow economy and waste disposal laws. He is authorized to delegate partial responsibility, e.g. within the scope of design and development, construction, fabrication or marketing and sales.

The Chief Executive Offi cer delegates partial responsibilities for the individual processes in the fi elds of quality, environmental and occupational safety management to the managers of factories, busi-ness units and the central departments. However, this does not relieve him of his overall responsi-bility. These managers are supported in the fulfi lment of these tasks by the representatives for qual-ity and environmental protection, and by the specialist for occupational safety, appointed by them.

For the control of nonconforming products, the Chief Executive Offi cer appoints persons and depu-ties to bear responsibility for the technical aspects of products and confers on them the authority to issue directives. In the case of nonconformities, they take decisions regarding the action to be taken.

Managementresponsibility

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2

2.2.1.2 Business Unit

Together with their organizational units, business units are responsible for business with products, plants and services and are, therefore, direct partners of customers.

Depending on business-related activities, the main tasks of the business units are:

• sales• marketing, planning and controlling• handling of enquiries and preparation of bids• handling of sales activities• technical marketing / application technology• plant service• export management• participation in national and international standards and regulations• participation in specialist and standards committees

The contents of these tasks are defi ned by the individual business units in keeping with the demands of their specifi c market.

Within the scope of these tasks, the business units are also responsible for providing instruction for the products they issue. This includes furnishing complete and correct information in a clear form concerning proper use and including any necessary warnings in respect of foreseeable misuse.

They are, in addition, the people to be contacted by customers for dealing with claims and com-plaints, and accordingly are responsible for the preparation of product recalls (taking immediate action in the event of any problems relating to safety). The decision of a product recall is made by the Chief Executive Offi cer.

Product observation by the business units encompasses performance of the products when used for different applications, and ensures feedback of information for any possible product adjustmentprocess.

2.2.1.3 Operations

The operations (PKS O) encompasses the three factories Neustadt bei Coburg (FM N), Eschweiler (FM E) and Schwerin (FM S) with cross-location, coordination tasks: Investments, special mainte-nance projects, methods and productivity.

Each factory is managed by a factory manager. They bear the responsibility for logistics, production, quality, maintenance and for occupational safety and environmental management and are at same time, managers of the locations.

Details of tasks in these areas of responsibility are given in the organization schedules and assign-ment of tasks in the respective factories.

Furthermore, the factory managers are responsible for the fabrication of products manufactured in their factories.

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2.2.1.4 Research, development and engineering

The central department research, development and engineering (PKS R&D) is responsible for the product, material, process and test engineering for the manufacture, servicing and strategic refi ne-ment of existing and new products.

The important tasks are:

• development of concepts for core insulations and outer sheaths• selection, design and development of new materials for cables and systems• ecologically benefi cial product design• specifi cation of product and construction data• specifi cation of manufacturing technologies• production servicing• testing new products• design and development of new test techniques and procedures• assessment of claims and complaints• partner of scientifi c institutes and Universities• development and technical servicing of patents• project management

The results of implementation of the above noted activities are made available to the organizational units of PKS in an appropriate manner.

The managers of the central department research, development and engineering are responsible for the technical aspects of products. They are also responsible for design and development and construction. These partial responsibilities delegated by the PKS Chief Executive Offi cer are defi ned and documented.

2.2.1.5 Quality, environmental and occupational safety management, internal revision

The central department quality, environmental and occupational safety management (PKS QES) has the task of supporting the organizational units in accordance with a uniform and effective manage-ment system for quality, environmental protection and occupational safety. Awareness of process importance must be promoted to assure business success in the long term and to intensify the inte-gration of staff and customers and suppliers in the continual improvement progress.

The main activities include the solution of the following tasks:

• coordination, further development and monitoring of the quality, environmental and occu-pational safety management system in coordination with the QUM-Team

• documentation of the management system (manual, procedures, regulations applicable throughout PKS)

• monitoring the effectiveness and suitability of the management system (organization of management reviews)

• planning and performance of internal audits, reporting, auditor qualifi cation and audit work-shops, measures for further education

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• taking care of external audits and certifi cations• working on the documents for the suppliers self information for our customers• assisting the assignment of tasks and appointment of quality and environmental protection

representatives, the safety offi cers, the safety representatives and the instructed represen-ta-tives for the transport of dangerous goods

• assisting the quality and environmental protection representatives, the safety offi cers, the safety representatives and the instructed representatives for the transport of dangerous goods

• reporting on quality, environmental and occupational safety management activities• internal revision and data protection

2.2.1.6 Purchasing

The central purchasing department (PKS PU) is responsible for purchasing and procurement. The manager of the central purchasing department with his purchasing organizations bears the respon-sibility for the purchasing and procurement activities.

The main activities include:

• identifi cation, selection and evaluation of suppliers, supplier development • inviting tenders• negotiating and defi ning conditions, in particular pries, terms of payment and terms and

conditions of sale• approval and release of purchase orders, basic agreements and basic contracts• negotiations on claims with fi nancial effect resulting from delivery of nonconforming sup-

plies and services• maintenance and updating of the System SAP

2.2.1.7 Information technology

The manager of the central department information technology (PKS IT) is responsible for the pro-vision, maintenance and care of the entire information system for PKS.

The central department information technology is a service provider for all PKS-organizational units within the company as regards information processing.

It is therefore the contact for any problems which arise in connection with communications techno-logy, hardware, software and information protection.

Main activities are:

• implementation of the uniform PRYSMIAN standards in information technology• provision of hardware and software for the organizational units• software design and development, installation and care• installation, repair and care of hardware• installation and operation of data lines• operation of the communications network• guaranteeing short response times• guaranteeing high system availability

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• implementation of central data protection within the company• maintaining data integrity and information protection• guaranteeing compliance with the requirements laid down in the German data protection

law

2.2.1.8 Finance, administration and control

The manager of the central department fi nance, administration and control (PKS FC) bears the responsibility for the legal, economic and risk aspects being duly taken into account at PKS. He is responsible for controlling the costs and assets and the observance of accounting principles.

Important fi elds of activity are:

• general bookkeeping with auditing, accounts payable and fi xed-asset accounting• in-house accounting, stocktaking and invoicing• planning and controlling for the business units and the operating units• credit management and treasury• legal and tax matters• monthly, quarterly and annual accounts in accordance with HGB and IFRS• planning according to corporate guidelines (IFRS)• public relations (non-technical) and organization of the external communication

2.2.1.9 Human resources and organization

The manager of the central department human resources and organization (PKS HR) is responsible for the human resources work in the company, especially in the fi elds of staff support, staff planning and development, staff assignment, staff recruitment, staff reporting, human resources cost ma-nagement and the pay systems.

Other activities of the central department human resources and organization are:

• giving advice on training matters• controlling the need for training• documentation and assessment of training courses held• further education• organization management• documentation of the structural organization• internal communication• organization of factory security• time management• travel management• employee pension scheme• coordination of PKS-company cars

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2.2.2 Representatives for quality, environmental and occupational safety management

2.2.2.1 Representative for PKS management system (quality, environmental and occupational safety)

The representative for the PKS management system (quality, environmental and occupational safe-ty) appointed by the Chief Executive Offi cer assists him in the fulfi lment of tasks related to quality, environmental and occupational safety management. He is also the manager of the central depart-ment PKS QES. His duties include the implementation as well as internal and external presenta-tion of PKS management policy. Furthermore, he has to ensure that the requirements of the Standards and Regulations DIN EN ISO 9001, KTA 1401, DIN EN ISO 14001, OHSAS 18001 and IRIS are fulfi lled and continually adhered to at PKS.

Over and above that he has the following tasks:

• participation in the planning for the strategy of quality, environmental and occupational safety and further development of the integrated management system

• design of the management manual• organizing the assessment (management review) of the management system• monitoring the PKS objectives and corrective actions• organization of the PKS audit programs• monitoring the revision of modifi cations/remarks from internal and external audits• representing PKS in matters concerning fundamental questions related to the management

system• coordinating solution of issues pertaining to quality, environmental and occupational safety

management

He reports directly to the PKS Chief Executive Offi cer (Executive meeting).

2.2.2.2 Quality representative (QB)

The managers of PKS organizational units are assisted by the quality representatives appointed by them in the implementation of the quality management system. For this purpose, the quality repre-sentatives are given the necessary authority.

The main tasks of the quality representatives include:

• further development and documentation of the management system in the areas of their responsibility in coordination with the central department PKS QES (QUM-Team)

• monitoring the effectiveness of the management system• counselling and assisting in the implementation of the management system within the cen-

tral department• monitoring up the realization of quality objectives• participation in the preparation and maintenance of the PKS management manual and the

instructions applicable• submitting reports to the manager of the organizational unit• coordination of activities pertaining to environmental management issues (if environmen-

tally signifi cant)• performance of internal and if necessary, external audits• follow up the revision of modifi cations/remarks from internal and external audits,• refi nement of quality assurance at own responsibility at work location

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2.2.2.3 Environmental protection representative (UB)

The factory managers are assisted by the environmental protection representatives in the implemen-tation of the environmental management system.

The factory managers delegate commitments and tasks to the environmental protection representa-tives appointed by them, on the basis of statutory provisions and internal regulations and grant them the necessary authority. The areas of their responsibilities include also the premises and employees of the PKS central departments at the respective locations.

The main tasks of an environmental protection representative are:• further development and documentation of the environmental management system in co-

ordination with the central department PKS QES (QUM-Team)• monitoring the effectiveness of the environmental management system• participation in the preparation and maintenance of the PKS management manual and in-

structions applicable throughout the PKS Group• training of company staff on environmental topics• to give a statement of opinion and provide risk assessment of environmental effects at

projects• negotiating with the licensing authorities on all aspects of environmental performance• counselling and assisting the organizational units in the factories and central departments

in the implementation of the environmental management system• monitoring up the realization of environmental objectives• participation in the preparation of environmental program• annual report on measures realized and planned• performance of internal environmental audits in coordination with the relevant quality

representative• organization and documentation of UWS patrol inspections (round tours)• submitting environmental reports to the factory manager (Factory Meeting)

2.2.2.4 Specialist for occupational safety (SiFa)

It is the legal responsibility of factory managers to establish and assess all hazards connected with the work of employees in their particular area. For this purpose the factory manager concernednominates a specialist for occupational safety (or a safety engineer) to advise and support him.

The area of responsibility also includes the premises and employees of PKS central departments at the respective location.

The main tasks of the specialist for occupational safety are:• to inspect, test and check the plant installations, machinery and equipment• to propose measures for the elimination of defi ciencies• to work towards the implementation of the suggested measures• to investigate the causes of accidents at work• to demonstrate possibilities for the prevention of accidents at work• to encourage the employees to adopt a safety awareness attitude• to make sure personnel protection equipment is used• to monitor the realization of the occupational safety objectives

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• statements and acquire risk assessment of projects, if necessary• to prepare annual reports (accident statistics, number of sick days, etc.)• to organize and document petrol inspections (round tours) relating to occupational safety

In addition, the specialist for occupational safety advises the factory managers in all decisions rela-ting to planning, purchasing, planning and assessment of aspects relating to occupational safety and health protection.

2.2.3 Assignment of tasks in the fi eld of environmental protection and occupational safety

The responsibility in the fi eld of environmental protection and occupational safety rests with the Chief Executive Offi cer. He assigns in writing the responsibilities in the fi elds of environmental pro-tection and for transportation of hazardous goods, as well as for occupational safety to the location managers, the managers of the Central Departments and the managers of the business units.

The organization at all levels within a location is regulated as follows:

• in his function as factory manager, the location manager assigns the tasks and duties for protection of the environment, for transportation of hazardous goods and for occupational safety in writing to the managers in the following organizational units

• the environmental protection representative and/or the specialist for occupational safety ar-ranges for the assignment of duties to be brought up to date when personnel or organiza-tional changes are made

• PKS QES defi nes together with the environmental protection representative, the specialists for occupational safety and the responsible quality representative at the beginning of each fi nancial year the plan of audits to be carried out and coordinates the dates with the respon-sible location managers and managers of the central departments

• on the basis of these results targets, programs and measures are defi ned• the location manager controls the respective departments at least half yearly within the

sco-pe of environmental and occupational safety inspections (round tours)• the responsible superiors as well as the Maintenance at the locations and job-related repre-

sentatives participate in the petrol inspections (round tour)• complaints and improvement measures established are documented by the plant operators

and followed up according to schedule• organization and documentation of the petrol inspections are carried out by the environ-

mental protection representatives and/or by the specialist for occupational safety

Additional persons with assignments are listed in the PKS competence matrix “environment pro-tection and occupational safety”. This matrix is continually updated by the central departmentPKS QES.

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2.2.4 Communication

Following the commitment of employees to continually improve process operations, PKS has set up discussion committees to meet at regular intervals.

• executive meetings (Management level)• factory meetings / SOP-meetings (manufacturing locations)• employee meetings (all employees at a location)• meetings on „new products“• quality meetings• department meetings• committees for occupational safety and environmental protection• daily meetings, etc.

These meetings serve to inform the employees, to analyse strong and weak points of the busi-ness environment and the management system, and to establish written corrective and preventiveactions.

Further necessary communication and information is provided by way of an IT-supported infor-mation system with a „get“ obligation by every user of this data technology.

The duty to inform employees who do not have access to the IT-supported information system rests with the responsible superior.

Other information media are PKS staff newspapers.

The relevant environmental protection representative is the person who maintains contact with the local environmental protection authorities, and the relevant specialist for occupational safety is the person who maintains contact with the responsible “Berufsgenossenschaften” (employers liability insurance associations).

Information to external, interested parties and press releases is provided only by way of a person who has been nominated and authorized for this purpose by the management.

2.2.5 Factory and information security, data protection

Within PKS distinction is made between two areas of security:

• factory security (protection of humans and goods)• information protection (protection of information, know-how)

The responsibility for factory security rests with the manager of the central department „Information Technology“, and the responsibility for information security rests with the manager of the central department „Human Resources and Organization“.

To provide support in connection with compliance with such specifi cations and requirements asstated in the German data protection law, a data security representative is assigned to PKS.

The attained level of data protection is documented by critical-point analyses that are carried out at regular intervals.

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2.3 Management review

In addition to the periodical internal audits conducted in the organizational units, an assessment of the management system (management review) is carried out by the Management once during each fi nancial year to verify its adequacy and effectiveness.

This review is prepared by the representative of PKS management system supported by the team of the quality and environmental protection representatives in cooperation with the specialists foroccupational safety with the key focus on the following topics:

• a survey of the management system and description of the development, on the basis ofselected topics

• review of the current management policy and passing an up to date management policy,if necessary

• results of internal and external audits• claims and complaints, questions concerning product safety• status of implementation of the target achievement program• environmental performance of R&D, product improvement and product change• evaluation of compliance• assessment of the management system by the management, new management objectives

may be set based on the results of the assessment

Management reviews are documented and the protocol is passed to all managers of the business and central units, the factory managers, the quality representatives, the specialists for occupational safety and the environmental representatives.

Managementresponsibility

Resource > Provisions of resourcesmanagement > Human resources > General > Competence, training and awareness > Infrastructure > Work environment

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3 Resource management

3.1 Provision of resources

At PKS the resources needed to implement policy, strategies and objectives regarding the manage-ment system are established and duly made available. These include, among other things, employ-ees, suppliers, necessary information, infrastructure, work environment and the necessary fi nancial resources.

In particular, consideration is given to the following:

• effi cient and timely provision of resources (customer satisfaction)• realization and support facilities (tangible resources)• intellectual property/occupational know-how (intangible resources)• clear organization structures (structural and sequence organization)• resources and mechanisms to promote the innovative and continual improvement of the

processes• enhancement of skills and abilities of our employees (training programs, courses of instruc-

tion)• economical handling of natural raw materials and energy• measures for occupational safety and workplace design• planning for future resource needs

3.2 Human resources

The ever-increasing demands of the market and the rapid development of technologies as well as consideration of issues of the environmental an occupational safety make it necessary to increase and update the knowledge of our employees by means of appropriate further education and trai-ning.

This creates the personnel prerequisites for the employees, by the quality of their work, to meet the requirements to the quality of our processes, products and services with due consideration of environmental aspects and in compliance with safety requirements.

3.2.1 General

The respective superior is responsible for:

• selection and assignment of only those employees who are suitable and qualifi ed for the job in question

• initiation of the necessary further education and training of his staff• compliance with statutory, in-house or other provisions related to qualifi cations of his staff

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3.2.2 Competence, training and awareness

The necessary educational measures already start with the recruitment of new employees, e.g. in an initial staff appraisal interview or by means of a personal familiarisation plan.

Every employee shall be instructed by his superior about his tasks, in particular, within the frame-work of the management system. The superior has to review the qualifi cations of the staff directly under him at regular intervals in terms of their respective activities and to establish whether and to what extent educational and further training measures are required. The staff appraisal interviews are suitable for this purpose.

If there are statutory, in-house or other provisions or regulations relating to the necessary qualifi ca-tions of the employees for certain activities, the superior must ensure that:

• the appropriate employees are recruited and trained• certifi cates or confi rmation of their qualifi cations are available• any prescribed examinations for re-qualifi cation are passed in good time• only those employees who meet the provisions or regulations perform the relevant activi-

ties

Settling, training and information of employees are documented by records. External measures for further training are proven by participation confi rmations or certifi cates, and then they are to be sent to the human resources department.

During the fourth quarter of the current fi nancial year a plan for training and further education is to be prepared for the upcoming fi nancial year. This plan is prepared by the superior for the staff in the area of his responsibility and agreed on with the human resources department responsible. The employees can and should also make suggestions themselves for their own further training. They are informed by their superior about appropriate training programmes. On request, every employee receives an up-to-date printout of his personal training pass and is self-responsible for its actualisa-tion.

Tasks, appointment, specialised qualifi cations in environmental protection and occupational safety:The representatives appointed by the location manager in writing indicating the relevant tasks and obligations involved are responsible for giving those responsible at the locations job-related advice, and for monitoring the measures demanded by law or laid down internally.Preconditions for the appointment of a representative are his personal aptitude and suitability in accordance with the statutory requirements profi le for the job-related qualifi cations.

Training courses and their documentation in environmental protection and occupational safety:The training concept of the locations not only provides for the representatives to undergo further job-related training but for all employees to be familiarised with environment-relevant activities, environmental protection legislation and the internal regulations. These training courses are to strengthen and promote understanding and awareness of the responsibility for the requirements of environmental protection. The selection of suitable seminars is made by the environmental protection representative in consultation with the human resources department responsible. (see table 3-1)The basis for the training courses in the fi eld of occupational safety is generally the range of courses offered by the employers‘ liability insurance association. The safety specialist makes the choice in consultation with the superiors responsible.

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Personnel Type and frequency of training

Superiors engaged in the production area, with written assignment of duties relating to envi-ronmental protection and transportation of ha-zardous goods as well as occupational safety, and personnel entrusted with envi-ronmental protection tasks in the mainte-nance area

Seminars/trainings on plant environmental protection; normally every three years

Superiors assigned with duties in the fi eld of environmental protection and transportation of hazardous goods and occupational safety, in the non-production area

Seminars/trainings on plant environmental protection; normally every fi ve years

Superiors, staff with environment relevant tasks, and occupational safety representa-tives

Instructions on statutory requirements and in-ternal provisions; every year

Sales personnel with environment related du-ties

Written information and communication, tar-geted training courses

Environmental protection representatives and other persons with specifi c assignment in envi-ronmental protection, safety specialists, occu-pational safety representatives, coordi-nators and fi rst aid helpers

Regular participation in internal and external courses for further education and refresher training

Representatives and other responsible per-sons engaged in the transportation of haz-ardous goods

Participation in external training courses; at least once every three years

Tab. 3-1: Training concept for environmental protection and occupational safety

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3.3 Infrastructure

The need for manufacturing, inspection and testing facilities is determined, provided and maintained to guarantee that optimum product quality is achieved. This includes the necessary resources to boost performance at the production and administration locations, the necessary equipment, hard-ware and software as well as the organization and provision of the supporting services.

These are primarily:

• systematic management and control of the process fl ows including the production pro-cesses and production facilities

• measuring and monitoring devices/equipment

This takes place in compliance with the regulations on environmental protection and occupational safety as well as special specifi cations and statutory provisions, operating instructions/manuals and maintenance instructions.

The production, inspection and test procedures are planned, tried out, released and regularly revie-wed (process validation) if process results cannot be verifi ed to the full extent through subsequent quality inspections and testing.

The processes are automatically monitored and controlled as far as possible. The maintenance of the production facilities is laid down according to frequency and extent on the basis of internal require-ments and must be performed without adverse environmental impacts.

Maintenance and service plans serves to secure the product conformity.

3.4 Work environment

PKS determines and controls the personal employment and the job conditions in such a way that the required product quality is achieved. All applicable statutory and offi cial regulations are observed in order to satisfy the requirements of environmental protection and comply with occupational safety standards including the workplace design.

The company has announced a specialist for occupational safety and transfered the assignment of the occupational safety to the managers of the business units, locations and central departments. In cooperation with the occupational safety committee they pay attention to a safe and appropriate work environment.

The work environments are described in more detail under 1.3.1 to 1.3.4 (location descriptions) and 4.1.1 (Workfl ow and procedures for environmental and occupational safety management) and 4.1.2 (Statutory and other requirements).

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Product realization > Planning of product realization > Workfl ow and procedures for environmental and occupational safety management > Statutory and other requirements > Customer-related processes > Process model > Determination of customer requirements > Review of customer requirements > Communication with customer > Development > Product realization process - Development planning - Development inputs - Development outputs - Development review - Development verifi cation - Development validation > Product adaptation process > Purchasing > Defi nitions of product descriptions, quality assurance and environmental protection measures > Selection of suppliers > Qualifi cation and assessment of suppliers > Orders / modifi cation of orders > Technical delivery conditions, quality assurance agreement > Acceptance and receipt of goods > Purchasing of trade products > Purchasing of intercompany products > Production > Production control > Validation of production processes > Identifi cation and traceability > Customer property > Product maintenance - Handling - Storage - Packing and preservation - Shipment > Control of monitoring and measuring devices

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4 Product realization

4.1 Planing of product realization

All realization processes within PKS are planned with the establishment and documentation of the tasks to be performed in such a way that the manufacturing of the products under controlled conditions and in compliance with environmental provisions and occupational safety regulations isguaranteed.

Environment-relevant processes are planned, documented, checked and released with the participa-tion of the environmental protection representative. This representative regularly monitors the envi-ronment-relevant processes.

The processes are laid down for every product to be manufactured, in the manufacturing and testing sequence plans by the organisational units responsible for order processing, production planning and control, production, quality assurance and product maintenance.

We continuously work at the improvement of our processes (refer to chapter 5).

4.1.1 Workfl ow and procedures for environmental and occupational safety management

Environmental protection and occupational safety are major elements of the management‘s respon-sibility. It is equally a part of the obligations of all employees to help achieve the objectives of envi-ronmental protection and occupational safety within their possibilities on their own responsibility.

The management and works council jointly pursue the objectives of environmental protection and occupational safety including the ergonomic workplace design.

The environmental and safety aspects are determined, recorded, described and evaluated at the production locations. This includes all plants, facilities and activities, waste producers as well as the location in its entire environmental relevance, which are crucial for the protection of the ground, water and air.

The environmental and safety aspects are determined, recorded, described and evaluated in accor-dance with the established regulations by the environmental protection representative (acting as ge-neral coordinator) responsible at the location. The corresponding documents are updated annually, in the event of major changes, immediately.

The documentation on this is made in the environmental log and in plant logbooks which have been prepared for every environment-relevant plant and which is locally available at the plants involved or can be obtained from the employee responsible.

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4.1.2 Statutory and other requirements

Regulations of general applicability as well as specifi c regulations concerning protection of the envi-ronment and occupational safety relevant to the respective manufacturing locations are given in a list of regulations.

Procurement and compilation of EU, federal and federal state regulations, company directives, local and other location-specifi c regulations are carried out by the responsible environmental protection representative and the specialist for occupational safety, respectively.

Regulatory requirements imposed in license permits are to hand. The plants and equipment con-cerned are listed in a schedule which includes information on the type and designation of the plant, the organizational unit responsible for operating it, the approval mark with approval date, and the licensing authority.

These PKS internal documents are available in the organizational units involved, and the full scope of documents is available from the competent environmental protection representative and the spe-cialist for occupational safety, respectively.

4.2 Customer-related processes

Fig 4-1: Process map

LEADERSHIP PROCESSES

SUPPORTING PROCESSES

BU

SIN

ES

S P

RO

CE

SS

ES

BU

SIN

ES

S P

RO

CE

SS

ES

4

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4.2.1 Process model

The representation in fi g. 4-1 shows like the processes of PRYSMIAN: Leadership processes (F1 - F5) = yellowBusiness processes (K1 - K6) = blueSupporting processes (U1 - U5) = green

together in interrelation stands and is portrayed as process model in the sense of the norms as process map. The internal and external tidings-bearings stand in accordance with the Management policy with PRYSMIAN in the foreground of all actions.

The further applicable documents and procedures of the integrated management system became associated in accordance with the respective processes.

4.2.2 Determination of customer requirements

Customer requests are checked and then lead to bids.

The compliance with the customs laws and the current regulations / laws for the export customs are part of the check at exports and is being monitored from the export control representative.

For the determination of the quality-relevant steps with the bid preparation the following points must be valid:

• inquiries directly from the customer (letter, fax, email, phone)• determination of product, selling price, terms of payment and delivery time• the bid processing fi nally has to be deposited, checked and shown with the SAP-system• submission of bid• after clarifi cation of the customer demands in writing• by phone (with documentation)

If bids are made by phone, a documentation with date and signature shorthand has to be made. The documentation is fi led into the customer record.

4.2.3 Review of customer requirements

If suggestions for the further development of products or new products result form the bidding and the general market observation, these are to be assessed and placed at the disposal of PKS R&D.

4.2.4 Communication with customer

For the communication with our customers we use the following procedures:

• Internet (PRYSMIAN website)• PRYSMIAN e-commerce• product presentations (fairs, seminars)• customer visits• phone calls and correspondence

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4.3 Development

The quality of PKS products and processes is determined by the objectives formulated in the product planning stage, and by the controlled processes, technologies and manufacturing facilities applied for product realization and adaptation. Consideration is given to environmental protection require-ments by way of the measures taken for environmentally compatible product design and in addition measures of occupational safety for the design of machines and systems (incl. modifi cations) and for the design of the working environment. Accordingly, the decisive course has been set for envi-ronmental compatibility and occupational safety with regard to production (fabrication), product use and disposal.

By controlling, verifying and validating product design and development, the responsible organizatio-nal units ensure that the defi ned quality and environmental requirements for the product are clearly and fully described and are able to be met.

This applies in particular to the product realization process (design and development) and to product adaptation (design and development changes).

4.3.1 Product realization process

A design and development project is normally prompted by a new product idea, a R&D suggesti-on (e.g. results of order processing or market observation), by changed regulations or standards,customer specifi cations and by suggestions for rationalization and improvement.

The organizational units responsible for design and development convert customer requirements, legislative requirements and company requirements into appropriate quality characteristics for the fi nal product. For these characteristics technical solution concepts are sought and optimized.

Suitably qualifi ed personnel, equipped with appropriate resources, are assigned design and develop-ment activities in the central department PKS R&D.

The implementation of design and development (process of design and development) and defi nition of the organizational units involved (interfaces) are normally defi ned in R&D projects and/or in ex-perimental tasks or terms of reference.

To meet the requirements of product responsibility regarding §22 Krw-/AbfG, products are designed such that the generation of waste during production and use is minimized. The environmentally com-patible recovery and disposal of the waste arising after the use of the products is assured.

The responsibility and the actions taken to ensure environmentally friendly product design and pro-duct recycling are documented at PKS.

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4.3.1.1 Development planning

Design and development planning is carried out by the central department PKS R&D. Planning, appli-cation for, approval and reporting of design and development projects are carried out on the basis of up-to-date specifi cations issued by PKS and PRYSMIAN S.p.A. The plans for design and development projects are prepared and updated by PKS R&D. Planning, control and responsibility for processing the design and development project rests with the lead-managing PKS R&D organizational unit and the project manager. These coordinate the work of all functions/departments participating in the design and development project, if necessary also by enlisting the aid of other organizational units.

PKS R&D coordinates the cooperation with external research departments, ministries, institutes, and universities.

Design and development is, if necessary accompanied by a design and development plan (e.g. project management with MS Project), by reports and cost behaviour patterns.

4.3.1.2 Development inputs

At the initial phase of design and development, market and customer requirements based on product specifi cations prepared by the Business Units, including the requirements arising out of contract reviews, are reviewed by PKS R&D for adequacy and practicability, and following clarifi cation of incomplete or confl icting requirements set down in writing (e.g. draft design, product-related envi-ronmental aspects).

4.3.1.3 Development outputs

For documentation of design and development outputs, design documents (design sheets, drawings and specifi cations for inspection and test plans) are prepared, reviewed and released by PKS R&D.

4.3.1.4 Development review

In the implementation phase, the technical documents (e.g. draft designs, draft inspection and test plans and, if necessary, product specifi cations) are, if required, revised and translated into pro-ducts.

In the process, documented tests and inspections of the design and development outputs (including design and development review) are carried out after particular development stages (prototype ma-nufacture, initial production under series production conditions, start of series production).

4.3.1.5 Development verifi cation

Design and development verifi cation is carried out by testing and inspection of the products from tri-al and prototype productions. Operational specimens are verifi ed after fi nal agreement of the quality and environmental requirements with the customer and the factories.

The results of testing and inspection are compared with the specifi cations and documented within the scope of a fi nal design and development review.

After verifi cation of the design and development outputs, fi nal documentation is carried out in the relevant documents (e.g. design sheet, production plan, test and inspection plan, installation instruc-tion, drawing). These documents are then reviewed and released.

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4.3.1.6 Development validation

To ensure that they have been met, the defi ned needs and/or requirements of the user are checked within the scope of design and development validation, which follows on from design verifi cation, and may possibly necessitate testing under service conditions at the customers‘ premises.

After positive conclusion of design and development validation, the product is released for series production of a type series (product release) by the person responsible for the technical aspects of the product.

4.3.2 Product adaptation process

Where products and processes have been released, it may prove necessary to make changes and adaptations due to special customer requirements arising during the inquiry or order processing phase, to modifi cations of rules/laws or in the course of rationalization measures.

Given a positive production trend and having passed the tests, delivery release is confi rmed by the person responsible for the technical aspects of the product.

The changes carried out in product adaptation processes shall be documented, e.g.• product requirements in the purchasing documents• design changes made to a product in the design sheet• supplementary stipulations in the manufacturing and testing sequence plans and process

data documents• if necessary, adaptation of the product specifi cations

4.4 Purchasing

The purchasing of raw materials and semi-fi nished products, of merchandise and services is car-ried out on the basis of partnership collaboration between purchaser and supplier. In terms of the integrated management system and important processes, purchasing is an environment-relevant process and has a decisive infl uence on the environmentally compatible realization of products and processes. Purchasing ensures that the ordered products and services are in accordance with purchasing specifi cations and in compliance with environmental provisions.

Purchasing at PKS is normally done by the central department purchasing (PKS PU) on basis of mu-tual (buyer-supplier) written declarations. PKS PU also coordinates the contacts between other PKS organizational units and the suppliers.

4.4.1 Defi nition of product descriptions, quality assurance and environmental protection measures

Appropriate descriptions, technical delivery conditions and quality assurance and environmental pro-tection specifi cations are defi ned in respect of purchased raw material and services, including semi-fi nished products and merchandise.

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The purchasing documents contain, among other things:

• product descriptions, such as e.g. designation, type and grade• the standards and regulations to be observed for the products• quality and environment requirements to be observed.

These purchasing documents are reviewed and released.

4.4.2 Selection of suppliers

Taking into account economic aspects, PKS PU selects the suppliers from the „List of approved ma-terials“, in accordance with defi ned requirements and on the basis of:

• technical documents, e.g. data sheets of approved materials, catalogues• technical purchasing documents, e.g. terms and conditions of supply and delivery• commercial purchasing data

and in accordance with their capability to meet quality and environmental requirements.

4.4.3 Qualifi cation and assessment of suppliers

Supplier qualifi cation is carried out by PKS R&D and PKS PU on the basis of the SAP of approved materials. This is effected by

• evidence of the suppliers capability to meet the requirements of the contract (quality capa-bility), and

• evidence of a documented quality management and environmental management system either by certifi cation, declaration of conformity or by way of auditing of the supplier or self assessment on basis of our check list.

A continual assessment process (at least once a year) is carried out on the basis of defi ned criteria. The results of the assessment are taken into consideration for approval of suppliers and are sub-stance of the supplier development.

4.4.4 Orders, modifi cation of orders

After processing/confi rmation of the requirement demands the purchasing department releases the order with a complete description of the scope of supply. Modifi cations are always carried out with supplementary orders that are subject to the same conditions as the original order.

4.4.5 Technical delivery conditions, quality assurance agreement

Requirements extending beyond our normal product descriptions and technical data sheets aredefi ned in technical delivery conditions.

Products will be described in product-specifi cations if no technical standards exist respectively indi-vidual product-requirements are beyond that.

The objective of a quality assurance agreement (QSV) is to commit the suppliers to implement qua-lity assurance measures; in other words, to involve them in our management system. The quality assurance agreement is signed by PKS R&D.

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4.4.6 Acceptance and receipt of goods

On delivery of products, receiving documents are prepared by the goods receiving department. The delivered products are subjected to a receiving inspection defi ned according to type and scope. In case of any deviations from specifi cations, PKS PU is informed and that department in turn agrees and initiates the necessary action to be taken with the supplier.

All products that do not conform to the defi ned receiving inspections are indicated as nonconforming and stored so as to rule out their use, processing or delivery to customers.

4.4.7 Purchasing of trade products

For merchandise purchased by the business units from other vendors, technical product descriptions form a component part of all contracts. If necessary, quality assurance agreements shall be also be concluded in such cases. This grants the responsible organizational units of PKS the right to check with other vendors whether the defi ned quality requirements are met and an effective QM and EM system is in place.

4.4.8 Purchasing of intercompany products

For fi nished products purchased by FM LOG from manufacturers of PRYSMIAN, technical product descriptions are decisive as well. The necessary supplies are agreed on PKS PU; and - if necessary -with the cooperation of PKS R&D. The process of purchasing is documented by procedures.

4.5 Production

4.5.1 Production control

To achieve the required quality with due consideration being given to the environmental aspects and in compliance with the provisions for occupational safety, the type and mode of production and service activities at PKS are defi ned and documented. The production facilities and working environ-ment are continually checked for suitability, an if required, adapted or optimized. In this connection, all applicable laws, standards and rules are adhered to.

Process parameters and product characteristics are monitored and optimized during manufactu-ring.

If required and where appropriate, processes and equipment are released via an appropriate appro-val procedure.

All criteria for performance of the work are defi ned in a clear and practical manner (documented regulations, specimens, illustrations). Suitable maintenance of the equipment ensures continuing process capability.

Processes whose results cannot be fully verifi ed by tests and inspections are controlled by constant monitoring and control of process parameters. (Item 4.5.2).

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Logistical control of production and service-providing is performed by application of suitable soft-ware beginning with the reception of an inquiry, from receipt of the order through to delivery to the customer.

As a rule, copper or aluminium are used as conductor materials, and PVC, PE, XLPE and EPR as insulating and sheath materials. Plastic, copper or aluminium strip, as well as copper wire, is used for outer sheaths and shields.

The main processes used in cable production are:

Conductor productionBought-in unfi nished wire of copper or aluminium is drawn as round and fl at wire, or sector-shaped, to specifi ed dimensions on special wire drawing machines. Conductors are used in the form of solid wire (round, sector-shaped) or twisted strands (round, sector-shaped).

Core insulationThe conductors are normally isolated by using extruders (with PVC, XLPE or EPR).

Core strandingFor multicore cables or lines, the insulated cores are bunched together in special stranding ma-chines to form stranded elements. A contra rotating reinforcement helixes ensures the necessary stability for certain product types.

Armouring, shieldingStranded elements or single cores with Al- or Cu-bands/wires are armoured with taping and/or shielding machines (added mechanical protection function) or are given a shielding (additional electromagnetic protection).

SheathingInner and outer sheaths are normally extruded out of materials PVC, PE or EPR. They are de-signed to protect the inner elements of the cable against mechanical damage, moisture and chemical effects.

If technically possible, several of these processes are linked together to form one work operation.

Packing and shipment are normally effected by means of cable drums, where cables can also be packed as reels.

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The main environment-relevant aspects, processes and activities are established and documented at PKS. These include in the main:

Emissions:• plant and equipment emitting hazardous substances into the atmosphere• plant and equipment with noise emissions

Ground protection and water pollution control:• plant and equipment containing water-endangering substances• plant and equipment producing wastewater• in-plant handling of water-endangering substances and hazardous materials

Waste:• waste collection• disposal of waste which is unavoidable and cannot be recycled• plant and equipment generating waste subject to special controls• transportation of waste and waste subject to special controls• awarding of disposal orders to certifi ed waste disposal companies• mediation activities concerning the disposal of waste on behalf of customers

Hazardous materials:• purchasing, use and handling of hazardous materials• hazardous materials in the product

Product improvement and service-providing activities:• environmentally compatible product design• environmentally relevant customer counselling• careful treatment of resources and economizing with energy and raw materials

4.5.2 Validation of production processes

Processes whose results cannot be fully verifi ed through inspection and testing, are validated through continual monitoring and control of the process parameters. This includes the continual qualifi cation of the applied processes, the facilities used and of the assigned personnel. The estab-lished methods and procedures are continually reviewed, and if required, modifi ed or adapted. The process data is fully documented.

4.5.3 Identifi cation and traceabilityIn order to ensure an unambiguous identifi cation of products and their traceability to the individual process steps, material and products are provided with an identifi cation (marking), from material/products receipt through delivery to the customer.

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Every product is identifi ed by the organizational unit responsible for the production process and/or for order processing through, e.g.:

• type designation,• code No./Ident. No,• material designation or batch/heat number,• job No., order No., cable drum No.

and through the documentation/traveller accompanying the complete manufacturing process as well as through identifi cation markings on the product itself. The completion of every manufacturing and test/inspection step is documented in the accompanying manufacturing and inspection and test documents.

4.5.4 Customer property

Customer property relates to products supplied by the customer for further processing at PKS.

Customer-supplied products shall be received, stored, taken out and used in an appropriate man-ner and protected against loss and damages, with due consideration being given to environmental aspects and in compliance with occupational safety provisions.

Customer-supplied products shall be clearly indicated as such in the purchasing documents with cross reference to the order number. In each case they are clearly indicated in the technical docu-ments and in the purchase order form.

Normally, customer-supplied products are not subjected to a receiving inspection. As a minimum, the products delivered are checked for compliance with the data in the delivery note concerning quantity and type designation and for transport damages. In the case of compliance with the speci-fi cation, the products are released and clearly indicated as released products by the organizational units which receive or use the products. These store the products in an appropriate manner if not required for immediate processing or installation, and check their condition at regular intervals.

4.5.5 Product maintenance

By product maintenance we mean methods of handling, storing, packing, preservation and shipping laid down at PKS. These processes are normally out housed processes, they are performed by an external service provider and are monitored by LOG and QES.

All products are to be protected against damage or detrimental effects by means of appropriate action from the receipt of the goods, during the production processes down to the contractually established hand-over to the customer. The handling, storage, packing, preservation and shipment represent relevant processes in the management system, i.e. they have a crucial impact on aspects of quality and environmental protection. Particularly strong importance is placed on checking com-pliance with occupational safety regulations in these processes.

The packing should also ensure that the products are protected against damage or detrimental ef-fects by means of proper handling during shipment and when accepted by the customer and that any risk to the environment is excluded.

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4.5.5.1 Handling

Suitable occupational vehicles and lifting facilities are used to handle the products. They are assigned to certain organisational units which are responsible both for the condition and correct handling of the equipment itself as well as the products.

Identifi cation on the product or its packaging as well as generally applicable instructions and regu-lations shall be observed during handling.

4.5.5.2 Storage

Materials/products are stored by the organisational units responsible on/in the areas and rooms made available for this purpose.

The employees in the warehouses carry out acceptance, storage and delivery in accordance with instructions and regulations in such a way that damage or detrimental effects are prevented or are detected at the earliest possible moment and then the established action is taken to prevent proces-sing or delivery to the customers and any damage to the environment.

The warehouse rules laid down permit the products to be found and identifi ed as well as ensure proper access.

If a limited storage period is specifi ed, an assessment of the properties of the material/product is organized by the person responsible for the technical aspects of the product on expiry of this period in order to detect any damage and then exclude processing or delivery to the customers.

4.5.5.3 Packing and preservation

The organisational units responsible receive packing and identifi cation specifi cations in the working papers accompanying the material/product and the instructions which apply in general to certain materials, products, forms of storage, receipt areas, methods of shipment or customers.

Compliance with the specifi cations and observance of the instructions are monitored by the organi-sational unit responsible for packing in order to exclude any adverse effects on properties, damage to the materials/products and the environment.

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4.5.5.4 Shipment

The carrier is chosen and a transport order placed by the organisational unit responsible, allowing for the specifi c customer requests and depending on the product, destination, delivery date and transport costs.

The products are loaded in accordance with instructions and regulations in order to prevent product damage and any hazards to the environment as well as industrial accidents.

The organisational unit responsible performs a fi nal check (shipment inspection) which clarifi es whether the correct products have been loaded in a perfect condition using the proper transport securing devices. Proper hand-over to the carrier is expressly confi rmed.

The carrier receives all instructions in writing in the accompanying papers (e.g.: delivery note, freight list) relevant to the transport order.

At PKS representatives are appointed in writing for hazardous goods transportation „Waste trans-portation“ and for hazardous goods transportation „Product transportation“.

4.6 Control of monitoring and measuring devices

Measuring and monitoring devices that are relevant to product quality and protection of the en-vironment and used for setting up and monitoring all processes operating in the factories, and to en-sure conformity with environmental regulations and laws, are provided with an identifi cation, and „geeicht“ (calibrated by the authority), calibrated, tested for measuring accuracy (comparison measurement), or monitored at defi ned intervals.

The responsibility for control of measuring and monitoring equipment is regulated for the PKS pro-duction locations. In this connection, the person responsible in each case is supported by the perso-ns entrusted with control of the measuring and monitoring devices.

All measuring and monitoring devices subject to controls are recorded in the card fi les for measuring and monitoring devices, and identifi ed in terms of calibration status such that it is clearly recogniza-ble or comprehensible (e.g. with stickers) whether they have been

• „geeicht“ (calibrated by the authority),• calibrated or• tested for measuring accuracy (comparison measurement).

After expiration of calibration intervals, the organizational unit responsible initiates the control of the measuring and monitoring devices involved. The results of these controls are documented and maintained.

If the results of this calibration control (accuracy verifi cation/comparison measurement) is unsatis-factory, the function performing the control shall notify the organizational unit responsible for these measuring and monitoring devices.

Measuring and monitoring devices which are not relevant for product quality and environmental aspects are not subject to regular controls and are, therefore indicated as such.

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Measuring and monitoring devices which are defect or presumed to be out of calibration shall be withdrawn from service and an immediate control initiated.

The procedures established and implemented within the organizational units ensure that all measu-ring and monitoring devices are adequately maintained and the methods of handling, protection and storage are such that the accuracy and use ability are maintained.

Furthermore, it is ensured that only the appropriate measuring and monitoring devices are selected and put into service, depending on their grades and purpose of application.

If installation work is done by a service provider, the requesting organizational unit is responsible to ensure that the service provider is in possession of measuring and motoring devices appropriate for the required inspections and tests purpose and are controlled and calibrated.

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Measurement, analysis > Planningand improvement > Monitoring and measurement > Customer satisfaction > Internal audit > Monitoring and measurement of processes and products - Receiving inspection - In-process inspection and testing - Final inspection and testing - Inspections and test records > Monitoring and measurement of environmental relevant processes - Checks by the person responsible - Checks by the maintenance department - Checks by the environmental protection representative - External reviews - Measurement > Control of nonconforming products and prozesses > Emergency provisions and measures > Risk minimization > Data analysis > Improvement > Continual improvement > Corrective and preventive action, precaution > Quality tools

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5 Measurement, analysis and improvement

5.1 Planning

At PKS the necessary inspection and testing activities are defi ned, planned and implemented. Con-formity of products and services with the defi nitions is assured and a continual improvement achie-ved. For this purpose, the need for and use of appropriate methods and statistical techniques are established.

The necessary control and corrective actions are also defi ned, planned and implemented within the scope of the integrated management system.

5.2 Monitoring and measurement

5.2.1 Customer satisfaction

Ascertainment of customer satisfaction or dissatisfaction is at PKS an important measure for the effectiveness of its management system.

Criteria for assessment of customer satisfaction are• for products: - quality, dependability and environmental compatibility• for delivery capability: - delivery reliability, adherence to deadlines, and correct deliveries• for customer care: - accessibility, information, support, counselling• for claims and complaints: - action taken in the shortest possible time

Customer opinions about these criteria are appropriately determined and assessed by the Business Units (e.g. by personal interviews at seminars and visits to customers or by results of the supplier assessment of our customers). The resultant assessments and consequences are incorporated as corrective and preventive actions in the continual process of improvement.

If the results of the receiving inspection are unsatisfactory, the materials/products involved shall be precluded from further processing.

5.2.2 Internal audit

With internal audits we verify the proper implementation of the integrated management system. They serve as documented assessments of the application of and the compliance with requirements relating to the management system. This is demonstrated through objective evidence (e.g. ma-nagement policy, management manual, procedures, work instructions, plant instructions/operating instructions) to ensure that the current laws and specifi cations are observed, process operations are adhered to, reviewed for their suitability and effectiveness and continually improved.

At the beginning of each fi nancial year, internal audits are scheduled with a central PKS audit plan and conducted as combined audits (quality, environment, occupational safety).

Process audity can be necessary in addition, but have to be incorporated according to their fo-cuses.

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Additionally, environmental performance is assessed at least once every three years through an in-ternal environmental audit. This environmental audit forms a component part of the audit schedule for the year in which it is due. It is conducted by the technical expert for environmental protection in cooperation with the relevant environmental protection representative, PKS QES and the involved organizational units at the locations. The results are documented in an audit report and the neces-sary corrective action is established.

Over and above this, a scrutiny of the hazardous goods is carried out at the manufacturing locations at least once a year.

The procedure for the performance of internal audits at PKS are documented.

On basis of the “Policy of loss prevention” dismissed the risk management of PRYSMIAN carries out an analysis over risks of fi re, explosion, electrical and mechanical failure and natural disasters. These analysis are used to draw up a report on loss prevention with a description of the development in comparison to previous year.

This report will be available at all locations.

5.2.3 Monitoring and measurement of processes and products

Adequate inspection and testing, the scope of which is anchored in the inspection and test plans, ensure that the product fulfi ls the specifi ed requirements. Documentary evidence is provided in the test records.

If the results of tests/ inspections on a product are unsatisfactory, the procedure for the handling of nonconforming products / nonconforming processes shall be applied. (s.a. 5.3)

5.2.3.1 Receiving inspection

Receiving inspections ensure that the materials/products delivered comply with the quality specifi -cation.

Delivered materials/products are identifi ed and the receiving inspection confi rmed on the basis of the delivery notes and purchase documents.

Receiving inspection is carried out on the basis of the specifi cation (inspection and test plan) prepa-red by the organizational unit responsible.

Delivered materials/products are released for further processing only when the fulfi lment of requi-rements is demonstrated.

Delivered materials/products which do not fulfi l the requirements, shall be indicated as nonconfor-ming, and segregated if applicable. The necessary measures shall be initiated, leading to rework in the factory or return of the products to the supplier.

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5.2.3.2 In-process inspection and testing

In-process inspections and tests serve the purpose of inspecting and testing the materials/products during manufacture to verify their compliance with quality specifi cation, and monitoring the manuf-acturing processes.

In-process inspections and tests are carried out in accordance with the manufacturing and testing specifi cation (inspection and test plans) by personnel of the organizational units assigned with qua-lity assurance tasks or by authorized manufacturing personnel (self-inspection).

Performance of inspections and tests and conformance of the product with quality specifi cation are documented e.g., in the manufacturing documents, test records, inspection and test lists, etc. mate-rials/products in conformity with the specifi cation are released for further processing.

In the case of nonconformities, the materials/products are put on „hold“, indicated as nonconfor-ming and withdrawn from manufacturing process.

Reworked materials/products shall be retested prior to release and delivery for further processing.

5.2.3.3 Final inspection and testing

Final inspection and testing serves the purpose of demonstrating the fulfi lment of quality require-ments on fi nished products, leading to delivery release.

Final inspection and testing of fi nished products is carried out in accordance with the basic testing specifi cation (inspection and test plans) and the order-related specifi cation. Performance of specifi ed inspections and tests is documented in the inspection and test documents. If required by the con-tract, specifi ed test records shall be presented to the customer (acceptance inspection by customer) for perusal and to countersign.

If necessary, confi rmation of products‘ compliance with customer requirements is documented in relevant inspection and test certifi cates. In the case of nonconformities, the products shall be put on „hold“, i.e. indicated as nonconforming.

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5.2.3.4 Inspections and test records

The results of receiving, in-process and fi nal inspections and tests of materials/products are docu-mented on the inspection and test documents and/or are computerized. The following are examples of inspection and test documents:

• machine operator‘s log book• inspection and test lists• test protocols• test reports• test certifi cates

Records are available as hardcopy or on electronic media. They are fi led according to the legal de-terminations and PRYSMIAN internal regulations.

5.2.4 Monitoring and measurement of environmental relevant processes

5.2.4.1 Checks by the person responsible

The person responsible/operator has to have regular checks conducted (for example, for leaks in a visual inspection) on his environment-relevant plants or environment-relevant activities. The person who conducts these checks is established on a case-to-case basis. The checks are to be documented in the plant log book or in a similar form. Further details are laid down in a procedure.

The contents of the plant log book include:• plant lists with monitoring plans• description of environmental relevance• data on normal operations or improper operation (emission of substances)• results of safety checks• measurement and monitoring methods• nonconformities, complaints and action initiated to rectify them

5.2.4.2 Checks by the maintenance department

The maintenance department conducts regular checks as part of the maintenance work in consulta-tion with the plant operators and with the environmental protection representative. This monitoring activity also includes the external service providers working on the location premises, if their activi-ties are relevant to the environment.

5.2.4.3 Checks by the environmental protection representative

To check the environmental performance, petrol and site inspections of environment-relevant plants and areas are carried out by the environment protection representative of the location. The realiza-tion of these inspections are documented in the plant log book or in a petrol/site inspection report.

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5.2.4.4 External reviews

In addition to the audits by external certifi cation bodies, checks are conducted by the factory in-spectorate, the German technical inspectorate agency (TÜV), the employers‘ liability insurance as-sociation or the authorities responsible on the basis of statutory provisions. These checks are made sporadically after making a prior appointment or for acute reasons.

5.2.4.5 Measurement

Monitoring and measuring devices for environment-related measurements are jointly selected by the environmental protection representative and the specialist for occupational safety in accordance with the measuring requirements. Monitoring and measuring devices must be suitably calibrated on the basis of statutory and company provisions. Whether a self-inspection is admissible or demanded by the authorities or whether measurements are prescribed by independent and accredited institutes is to be taken into account.

Heat, energy and water meters are selected and approved by the offi ce responsible for these plans.

The required measurements and tests are recorded for environment-relevant plants and facilities in the plant log books, for environment-relevant activities in separate lists if necessary.

External accredited institutes are commissioned to take measurements on environment-relevant plants. If internal analyses are conducted, the procedure shall comply with the regulation in Section 4.6 of this manual.

5.3 Control of nonconforming products and processes

At PKS a special procedure, e.g. removal from the production fl ow or exclusion from the installation area, is ensured through appropriate procedures for the disposition of nonconforming products and processes from external deliveries and the company‘s own production. All products which do not conform with the quality and environmental requirements are put on „hold“ (blocked), indicated as nonconcorming and registered. The type of nonconformity is documented.

Records are prepared of all products and prozesses not conforming to the quality and environmental requirements so that action can be initiated.

The further treatment of nonconforming products and prozesses is dealt with in each case by the authorized personnel of the organisational unit responsible, until a decision has been taken on further procedure.

The person responsible for the technical aspects of the product and prozesses is always responsible for the evaluation and disposition of these products. The following decisions, which are laid down in detail internally at the organisational units responsible, may be taken:

• rework, repair• release• rejection• scrap

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All organisational units affected are informed of nonconforming products and prozesses and their further use. In the case of nonconformities which result in a delay in delivery or reduce the customer demands, the customer shall be informed via the competent business units, and is consulted on the decision about further procedure.

5.4 Emergency provisions and measures

To ensure emergency provisions are in place, potential, not removable accident sources are establis-hed and regularly reviewed. These are recorded and included in future plans. Possible environmental implications from accidents are established, recorded in the environment register of the locations, and assessed.

In the case of deviations from the intended operation of the plants - i.e. plant faults or accidents with emissions into the environment – measures are initiated immediately in order to minimize harm to man and the environment. This applies both to minor accidents and also to more signifi cant oc-currences. The responsible environmental protection representative shall be notifi ed immediately.

Measures to be carried out in the event of environmental accidents as well as alerting those persons signifi cantly involved and responsible are documented in the ´Brand- und Katastrophenschutzplan` (fi re protection and catastrophe control plan), in the ´Betriebliche Katastrophenschutzorganisation (BKO)` (in-plant organization for protection against catastrophic hazards) and in other internal re-gulations issued by the locations. Also, details concerning immediate measures and what to do in case of accidents are given in the operating instructions/plant instructions concerning hazardous materials.

In the fi eld of occupational safety, precautionary measures are derived from the results of the inter-nal and external reviews/audits and implemented. Such precautionary measures are guided by eco-nomically acceptable and technically possible criteria as a function of the presumable risk potential to personnel.

5.5 Risk minimization

As a general principle, risk analyses are carried out for the environment relevant plants during the planning phase or before substantial alterations are made to such plants, and suitable measures adopted in order to reduce the potential of an accident as much as possible.

After plant faults or accidents, analyses are again carried out for the plant affected and for all similar plants and appropriate measures derived from them (precautionary measures). These analyses are carried out jointly by Maintenance, the plant operator(s), the environmental protection representa-tive, and the specialist for occupational safety.

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5.6 Data analysis

At PKS data analysis are carried out to assess the adequacy and effectiveness of the management system and to identify possibilities for improvement. For this purpose, the following data is recorded and analyzed:

• results of measuring and monitoring activities• information on customer satisfaction or dissatisfaction• information concerning fulfi lment of customer requirements• data on suppliers

This data is analyzed to obtain details of process and product characteristics and their trends or, e.g. for evaluation of suppliers.

Depending on requirements, statistical techniques are utilized for the determination, monitoring and assessment of process capability and product and quality characteristics.

The scope of statistical quality inspections and tests is defi ned during the planning stage for inspec-tions and tests and recorded in the inspection and test plans, testing instructions etc.

For the purpose of documentation and evaluation of inspection and test results and for the determi-nation, monitoring as well as assessment of process capability and product-/quality characteristics, the following, are taken into account, e.g.:

• list of nonconformities• histograms• quality control cards• quality statistics (s.a. 5.7.3 Quality tools)

Analysis of environment-relevant plants and processes are carried out in-house or by external accre-dited bodies. These include, e.g.:

• waste water analysis• cooling water analysis• cooling lubricant analysis• waste air analysis• waste analysis• noise measurements• analysis of electrical /magnetic fi elds

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5.7 Improvement

5.7.1 Continual improvement

The further development of our management system goes according to the PDCA cycle so that a permanent and systematic improvement process is going on with the aim to supply a positive con-tribution to the value added. This method essentially contributes to the process safety and process quality.

PDCA-cycle:

• Plan - Planning of an improvement• Do - Realiyation of an improvement• Check - Checking of the success• Act - Fixing the improvement and restart the cycle

Fig. 5-1: Contiual improvement of the management system (PDCA)

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The processes which are necessary for continual improvement, are planned, initiated and controled. These include:

• the management policy• management objectives and programs• audit results• data analysis• evaluation of training assessments• corrective and preventive action, precaution• management evaluations• Continuous improvement (CI)

CI is a management method designed for the continual improvement of processes at PRYSMIAN. Focal points in the management plan are taken up and solutions worked out by teams. At regular meetings the CI teams at the factories report on the progress made in the implementation of their self-formulated tasks.

A further objective of our CI method is to achieve autonomous maintenance. In order to increase the running times of production plants, inspection and maintenance work is carried out by the ma-chine driver themselves. In this connection preventive maintenance is given top priority for better utilization of reserves.

The company success essentially depends on the qualifi cation, the engagement, the activities and the knowledge of our employees. In this connection the suggestion for improvement is an substantial constant and supporting and plays a motivating role. The effectiveness is tested and is monitored.

5.7.2 Corrective and prevetive action, precaution

Corrective action serves to eliminate the causes of defects or nonconformities which have already occurred in order to prevent their reoccurrence. Preventive action/precaution is intended to funda-mentally eliminate the causes of possible defects or nonconformities.

We feel obliged to introduce precautions to avoid accidents and diseases caused by work. These precautions will minimize accidents in order to insure the safety and health of all employees and3rd parties and to improve the health protection. The occupational medical care is regulated by the works medical department.

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On the basis of an analysis of the nonconformities detected in quality and environmental manage-ment arising from:

• production processes,• results of external or internal audits,• work operations related to preparation of offers and orders processing,• quality records,• customers service reports,• damage reports and• environmental and occupational safety inspections

fundamental weaknesses in the processes and products as well as in the management system itself are determined by the organisational unit responsible. This creates the basis for initiating the neces-sary corrective and preventive action to avoid reoccurrence, with the inclusion of the organisational units affected.

The type of corrective action to be taken is decided, depending on the signifi cance of the noncon-formity or the fault,

• by the manager of the organizational unit responsible or someone appointed by him• the person responsible for the technical aspects of the product or his appointed represen-

tative

by involving the concerned organization units.

In particular, the preventive action/precaution is laid down at regular meetings of the organizational units and at inspection tours on the basis of similar products and processes and the implementation of corrective action and its effectiveness are carried out and followed up.

The circle of participants is laid down at the respective organizational unit. Organizational units which are affected but do not participate are informed and included in the implementation of any action decided on.

The results of these discussions are documented. Nonconformities and major sources of faults re-main on the agenda until the appropriate corrective action takes effect or the unsatisfactory state has been rectifi ed.

The punctual and proper implementation of corrective action is monitored by the managers of the organizational units responsible and, if necessary, by the quality and environmental protection repre-sentative or the specialist for occupational safety responsible.

Potential faults and possible sources of faults are identifi ed on the basis of statistical evaluations and fault analyses as part of the regular quality, environmental and occupational safety reports and discussions.

Furthermore, preventive action/precaution is decided on and its punctual and proper implementation and effectiveness reviewed.

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5

5.7.3 Quality tools

With support of the MB of PRYSMIAN, one keeps an eye on it that as standardized as possible me-thods and instruments go location - and inter-divisional in the framework of the continuous impro-vement-process into action and the knowledge are available over it.

To this, especially following quality tools count:• Histograms, rule-cards,• 8 D - report• Brainstorming• FMEA• Prozess keys• ABC-analysis• Process management• Process - and machine capability determination• Strengths - / weaken-analyses

In the framework of Workshops and trainings, it is striven by qualifi cation of the areas of authority for the co-worker to recognize the action-demand with the use of quality-tools to the continuous improvement process of PRYSMIAN and to move.

Measurement, analysisand improvement

Terms and defi nitions

64

65

6

6 Terms and defi nitions

Al Aluminium

AS occupational safety

ASA Committee for occupational safety

b. Cbg. near Coburg

BGETE Berufsgenossenschaft Energie Textil Elektro

BKO in-plant organization for protection against catastrophal hazards

CAP Common accounting principles

CEO Chief Executive Offi cer

CI Continuous improvement

Cu Copper

CV continual vulcanization (cross-linking)

DV data processing

EN European Standard

EPR Ethylene Propylene Rubber

EVU Power supply utilities

FM E Factory Eschweiler

FMEA Failure Method Effect Analyses

FM N Factory Neustadt near Coburg

FM S Factory Schwerin

FuE Research & Development (R&D)

GJ Financial year

HGB German Law (Handelsgesetzbuch)

IC Inter City Train

IFRS International Financial Reporting Standards

IRIS International Railway Industry Standard

ISO International Standards Organization

KLN Cable and Wires Factory Neustadt near Coburg

KrW-/AbfG Circular fl ow economy and waste disposal law

KTA Committee for nuclear technology

KTA 1401 Safety regulations relating to quality assurance control requirements

KWE Cable Factory Eschweiler

KWO Cable Factory Oberspree

KWS Cable Factory Schwerin

Terms and defi nitions

66

6

MB Representative for the management system

MSR Instrumentation and control

OHSAS Occupational Health and Safety Assessment Series

PE Polyethylene

PKS PRYSMIAN Kabel und Systeme GmbH

PKS FC Central Department Finance, Administration and Control

PKS HR Central Department Human resources and Organization

PKS IT Central Department Information Technology

PKS O Operations

PKS OEM/C Business Unit Original Equipment Manufacturer, Contractors

PKS PD Business Unit Power Distribution

PKS PU Central Department Purchasing

PKS QES Central Department Quality, Environmental and Occupational Safety Management

PKS R&D Central Department Research, Development and Engineering

PKS TI Business Unit Trade and Installers

PKS TLC Business Unit Telecommunication

PVC Polyvinylchloride

QB Quality representative

QSV Quality assurance agreement

SAP Systems, applications, products in data processing (software company)

SiFa Specialist for Occupational Safety

SOP Sales Operation Meeting

TÜV German Technical Inspectorate Agency

UB Environmental protection representative

UWS Environmental protection

VPE vulcanized (cross-linked) polyethylene

Terms and defi nitions

67

History Moments

Special Cable Ship „Faraday“, year of construction 1874

Laying of a „Stadtbahnkabel“ in Berlin, 1926 - 1928

Transport of a 60 kV energy cable in Kassel, 1922

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Notices

Management ManualQuality, Environmental and Occupational Safety© 2009 PRYSMIAN Kabel und Systeme GmbHLayout: PRYSMIAN Kabel und Systeme GmbHPrint: Ruksaldruck GmbH + Co.KG

The preparation of text and illustration has been carried out with great care.Nevertheless mistakes can not be excluded.Do not scale the drawings.All photographs are the exclusive property of PRYSMIAN Kabel und Systeme GmbH.PRYSMIAN Kabel und Systeme GmbH does not accept any liability for casual or consequentialdamage in connection with the use of the information.Improvement proposals and advice are to be sent to the address on the reserve side.

All rights reserved. This document must not be used or copied, translated into another language or saved to electronic media in the whole or in parts.

PRYSMIAN Kabel und Systeme GmbH - Alt-Moabit 91D, D-10559 Berlin - T +49 30 3675 4770 - F +49 30 3675 5770 - www.prysmian.de