Business Policy Statements

[Last updated 21 Mar 2019]

Purpose

On this page you can read Copernicus Technology's business policy statements on the following topics.

Revision Details

All of these policy statements are kept under review and updated 2-yearly or when legislation or standards change - whichever is sooner.

Quality Policy

Copernicus Technology Ltd was established in 2008 with the original aim of marketing Intermittent Fault Detection (IFD) test equipment in the EU, Australia and New Zealand. The Company evolved to be the leading experts in IFD and No Fault Found solutions outside of the USA. Over time other lines of business have been added, so Copernicus Technology now provide the following products and services:

IFD test equipment products, services & training
Maritime Patrol Aircraft training & consultancy
Through-Life Technical training & consultancy

It must be noted that whilst the Quality Management System is ISO9001:2015-accredited for our IFD activities only, Copernicus Technology’s policy is that our Quality Management System shall be applied consistently and fully across delivery and support activities for all 3 lines of business.

At CTL quality is the foundation of our company and we strive to provide our customers with quality products and services which meet their requirements in full. We are committed to continuous improvement and have established a Quality Management System designed to meet the exacting requirements of our customer sectors and comply in full with the requirements of ISO9001:2015. CTL employees are involved in, and dedicated to, achieving high quality standards for our customers through the application of the CTL Quality Management System. The Directors, Management and staff have developed and put in place the following systems and procedures to support us in our aim of total customer satisfaction and continuous improvement throughout our business:

Regular gathering and monitoring of customer feedback.
A customer complaints process.
Employee Training and development.
Auditing of our internal processes.
Measurable quality objectives which reflect our business aims.
Management reviews of audit results, customer feedback and complaints. Our processes and internal procedures are reviewed regularly and are held in a Business Operations Manual which is made available to all employees.

Though the MD and the Board of Directors have ultimate responsibility for Quality, all employees are responsible within their own areas of work for ensuring that Quality is embedded within the whole of the company. The CTL Quality Management System is composed of three main elements:

Quality Standards capture the knowledge and expertise of CTL employees to ensure the consistent application of what we know. Quality standards are managed through locally defined Quality Procedures, Standard Operating Procedures and Travelers.
A Continuous Improvement Cycle to ensure an effective and efficient management of quality processes, to measure performance, and drive enhancement of our quality culture.
A Process-based management system encompassing the whole value chain in which all functions are responsible for defining the processes that impact on product quality and safety.

Product Safety

Copernicus Technology Ltd (CTL) provides mission critical products & services that companies depend on. Our commitment to product safety is at the heart of everything we deliver to a customer in our product - hardware, software, services and documentation, whether delivered separately or integrated into systems.

Five principles govern our approach to product safety:

1. Leadership Commitment and Accountability

The CTL Board of Directors champion product safety and prioritize it so that safety-related tasks get the right attention, time and resources. We take accountability for and ensure that our staff understand what they are accountable for with regard to product safety.

2. Maintaining and Improving Product And Service Safety

Our core product is setting industry standards and best practice therefore CTL is committed to the continuous improvement of product safety. We measure our performance and rigorously investigate and resolve any safety related issues, systematically embedding the learning from these back into our practices and processes. Everyone is encouraged to report any product safety concerns.

We manage product and services safety by the application of risk assessments (based on As Low As Reasonably Practicable (ALARP)/So Far As Is Reasonably Practicable (SFAIRP) methodology) and method statements.

3. Conforming Product

Robust quality is an essential building block of product safety and by following our processes we ensure that our products conform to specification. Products placed on the market hold declarations of conformity approved by the CTL Chief Engineer. Conformity of product is linked to UK and international standards where appropriate.

4. Safety Awareness and Competence

Everyone who works in CTL shares responsibility for product safety and we are mindful of the safety implications of our actions. Training is provided so that our people understand the CTL Product Safety Policy and processes and can fulfil their collective and personal responsibility. Training is given at induction and on an annual basis.

5. Continuous Improvement

Our policies and procedures are constantly reviewed for correct content and applicability. Post project lessons learned and customer feedback reviews are carried out that these valuable opportunities for improvement are recorded and acted upon.

Counterfeit Parts Prevention

Introduction

It is the policy of Copernicus Technology Ltd (CTL) to conduct all business activities in compliance with the rules and regulations applicable to our industry and the laws in the countries in which the company operates. In all cases, these business activities are conducted to the highest ethical standards. CTL’s reputation is built on the integrity of our employees and their commitment to maintaining the highest standard of business practice. CTL is committed to preventing the introduction of counterfeit electronic and material components into our products.

Counterfeit Products

There is increased evidence that the number of counterfeit and suspect electronic components in the market is rising. Counterfeit electronic components are defined as being those that are misrepresented in their origins or quality. Although we are not aware of any specific manufacturers producing counterfeit parts and selling them on, we understand the potential for this situation.

Risk-Based Approach To Procurement Of Materiel

It is CTL policy to employ a risk-based approach to reducing the likelihood, frequency and impact of counterfeit materiel entering our supply-chain system and processes by:

Not knowingly procuring counterfeit materiel.
Maintaining a register of authorised suppliers of components that are purchased for intended production. These suppliers will normally be franchised distributors and brokers.
Ensuring that, when there is no possibility of purchasing from franchised distributors, non-franchised suppliers and independent brokers are evaluated for their capability to meet the requirements of this document prior to purchase.
Continually improving purchasing processes aimed at reducing the risk of procuring counterfeit parts.
Contractually defining our expectations, this includes a statement of requirement on our Purchase Orders:
- "The Supplier shall warrant that only new, unused, authentic, genuine and legitimate items shall form part of the Supplies supplied to the Purchaser"
Carrying out quality inspections and testing upon receipt of materiel to ensure the part is compliant to manufacturing specification.
Maintaining a quality system accredited to ISO 9001:2015 with QMS procedures detailing methods of purchasing, controlling material, receipting, inspecting, verifying, validating, storing and through-life traceability of materiel.
Providing Anti-Counterfeit training to employees.
Ensuring that, In the event of discovering counterfeit materials, those materials are quarantined and an investigation is undertaken to discover the source. Full details of the infringement will be reported to the appropriate government trading standards agency for criminal investigation.

Waste Electrical and Electronic Equipment (WEEE)

The UK Waste Electrical and Electronic Equipment Regulations were introduced in 2007, with the aim of reducing the amount of electrical and electronic equipment ending up in landfill. They require ‘producers’ and ‘distributors’ to finance the collection, treatment and recycling or reuse of this fast-growing and problematic waste stream.

EU Customers

Copernicus Technology Ltd (CTL) is committed to the WEEE Regulations, EU Directive. This requires that electrical and electronic equipment, when being disposed of at the end of its useful life in an EU Member State, must be recycled and/or disposed of in accordance with the EU directive as it is applied in local laws of that State. These regulations go further by making the manufacturer, or importer (the producer) of the goods, responsible for their disposal/recycling in the correct manner.

Under the WEEE directive CTL is considered the producer of certain products we supply and in line with the demands of the legislation we are pleased to offer the opportunity for you to return these products to us for treatment and recycling. CTL products will generally be labelled with an identifying mark and the common symbol of a crossed out wheelie bin. Any other product is either considered outside the scope of WEEE or CTL is not technically the producer of the product. All CTL-supplied WEEE returned to CTL will be recycled in appropriate treatment and recycling centres in accordance with the legislation.

International Traffic In Arms Regulations (ITAR)

This statement explains the CTL compliance method for the management of International Traffic In Arms Regulations (ITAR) related product and data.

CTL does not design or produce any ITAR restricted items. Any ITAR controlled items required to be used during a project will be at the request and under the control of the customer. We will not accept or handle ITAR materials during a customer project until it is confirmed that we have received the necessary TAA clearance or sub-licence. We do not export ITAR controlled items and customers must notify us if a product/Part/Equipment falls under ITAR control.

CTL does not process unique capabilities or processes which do not exist outside the USA and there is nothing inherent in the products, components and sub-assemblies supplied by CTL which indicate that they are used on or in an ITAR controlled device.

CTL apply the following safeguards to ITAR related projects:

All copies of ITAR controlled documents are labelled across their face.
When not in use ITAR controlled documents are stored in a secure cabinet or if in electronic format in a secure folder with controlled access.
Electronic documents are also controlled by encrypted password only accessible by approved individuals.
For internal use whilst carrying out projects working copies of drawings and documents will be made which remove any information not needed during use.
ITAR controlled documents will not be distributed outside of CTL premises or Server without specific need. Transmitting any controlled document to a third party will only be undertaken where the 3rd party is correctly cleared/licensed and they must agree to follow all ITAR guidelines. Documents will be transmitted using recognised industry standard encryption tools. Prior to transmission all unnecessary information will be redacted.
If the case should arise where ITAR designated item(s) are required to be shipped a license is to be in place prior to any shipping activity.
Should a non-ITAR item that has previously been shipped to a customer be reclassified as ITAR, the customer shall be informed at the soonest opportunity.

Corporate Social Responsibility Statement

Copernicus Technology Ltd (CTL) is committed to meeting its social, economic and environmental responsibilities and recognises that doing so is integral to the long term success of the business. In order to achieve this commitment, we will work hard to find a balance between the financial sustainability of CTL as a business against wider ethical responsibilities.

We will comply with all legislation, standards and statutory obligations relevant to our activities and the jurisdictions in which we operate. We will also comply with other obligations, client policies and best practice where reasonably possible and relevant to our activities and the jurisdictions in which we operate.

This policy aims to support CTL as a socially and environmentally responsible company, with financial stability that protects our employees, provides value to our clients and actively engages with stakeholders. Our wider aim through the operations that we under-take is to have a positive impact on communities and the environment.

Responsibilities

The Board of Directors is responsible for reviewing and approving the content and implementation of this policy and will refresh and reinforce this policy where appropriate. Directors are responsible for having an awareness of the social and environmental impacts of CTL operations and taking appropriate measures to help staff act in adherence and compliance with this policy.

All our staff are required to comply with the policy requirements and share responsibility for our performance in implementing it.

Implementation

Our business culture aims to uphold environmental sustainability, social inclusion and equality. We pay all staff above the legal minimum wage.

We consider the social, economic and environmental aspects of our business decisions in accordance with our Environmental Policy and operate in a way that guards against unfair business practice.

We operate in accordance with our Equality and Diversity Policy, Working Standards and Grievance policies to ensure all current and potential employees are treated fairly and with respect. This includes promoting a working environment that is free from discrimination, bullying or harassment. Remuneration packages offer equal pay and opportunities regardless of gender that accurately reflect qualifications and experience.

We do not use slave, illegal child or forced labour (including human trafficking) either directly or through our supply chain and record the actions we have taken to avoid this in our Policy Statement on Modern Slavery.

We provide and maintain a clean, healthy and safe working environment and operate in accordance with our Health and Safety policy statement.

We operate in an open and honest way with stakeholders, including our clients and suppliers. We maintain a Gift Log and carry out Bribery and Corruption Risk analysis in accordance with our Anti-Corruption and Bribery policy. We apply a zero tolerance approach to acts of bid-rigging, mis-selling, bribery or corruption by any of our business partners or agents working on our behalf.

We seek to use local and national suppliers to support our business wherever possible. Our contracts with suppliers clearly set out the agreed terms and conditions. In accordance with our Finance Policy we pay our suppliers in a timely fashion and operate in accordance with the Prompt Payment Code.

We seek to protect the environment and operate within our Environmental Management Policy. We identify and dispose of waste arising from our operations in a manner that minimises harm to the environment and prevents pollution to land, air and water. We aim to reduce the consumption of energy and use renewable and/or recyclable resources wherever practicable. Staff are required to dispose of waste in recycling bins (paper, cardboard, batteries and WEEE products).

We acknowledge the value of the local community and the wider industry community and aim to build positive relationships wherever possible, in particular:

We maintain close links with the senior management and STEM staff of the University of Highlands & Island’s Moray College campus.
We represent the technology SME community by maintaining seats on the Scottish Technology Advisory Group and national technical committees in ADS, the trade association for the aerospace, defence and security industries.
We actively support and participate in the Royal Aeronautical Society’s Highland Branch events.
Our staff are involved in a diverse range of local groups and activities including music, the RAF air cadets organisation and orienteering.

Modern Slavery

This statement is made pursuant to s.54 of the UK Modern Slavery Act 2015 and sets out the steps that Copernicus Technology Ltd (CTL) has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business operations or our supply chain.

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. CTL has a zero-tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.

CTL is a small company and is not required by law to meet the requirements of the Modern Slavery Act. However, we have chosen to voluntarily produce a ‘Slavery and Human Trafficking statement’ setting out our approach to tackling modern slavery in order to provide a level of assurance to our customers.

CTL operates predominantly in the aerospace, defence, transport and technology sectors in the UK, EU and USA. We operate a preferred suppliers list and sources the majority of materials associated with its operations from reputable suppliers in the UK and the USA. A small number of product line components coming from manufacturing sources in China. Where possible we source materials from companies with a declared ‘Modern Slavery Statement’.

The area of our business which warrants the greatest contemplation is our involvement with other suppliers, in particular those who operate outside of the UK. Where possible we assess the operations of all the international suppliers we engage with. In the provision of electrical connectors and cables, we operate with suppliers in China and have taken steps to ensure as a minimum, they must be compliant with ISO 9001:2015 as an indicator that the supplier will have adequate processes and procedures in place.

Our targets for the coming year

CTL is committed to ensure modern slavery does not exist within its organisation and supply chain. Targets set for this year include the following:

Issue of a Modern Slavery and Human Trafficking policy
Inclusion of the Modern Slavery and Human Trafficking policy in its Employee Handbook
Provision of training with respect to the Modern Slavery regulations and issues