MBUSA DVUSA Theft-Relevant Parts Policy

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MBUSA DVUSA Theft-Relevant Parts Policy February 21st 2022 Issued by the Dealer Assistance Center MBUSA Theft-Relevant Parts Policy Issued Date: January 30, 2015 Page 1, Revised February 16, 2022 Policy Profile Short Title Theft-Relevant Parts (TRP) Policy Policy Number TRP Policy dated February 21, 2022 Purpose of Policy/Summary This policy defines the process required for acquiring parts identified as parts that may be required to steal a vehicle and/or to give a vehicle a new identity. Scope of Application This policy applies to all MBUSA and DVUSA Authorized Dealers. Explanation on Scope of Application Dealers are required to provide verified documentation before fulfillment of an order identified as TRP. Period of Validity of this Version January 30, 2015 – December 31, 2024 Last Revision of this Version February 21, 2022 Approval Turan Coratekin Topic Compliance Policy Owner Kevin Harty, DM – Dealer Assistance Center Contact Person Bradley Strine, Supervisor – Parts Technical Documentation Published on NetStar and PAC websites Documents TRP Order Form (MBUSA-137754962792) Star Bulletin S-B-80.57/62H, (April 9, 2019): Ordering a Programmed DAS4 key when no keys are present. Service Information SI80.57-P-0008A Programming and ordering a replacement key or additional key, dated Februar 17, 2021 Form OF80.57-P-3000-01A Register vehicle as present for programming/ordering a DAS4 key Further Applicable Regulations Changes to Previous Version New hyperlink added to NASTF SDRM system added 2.D Note added for vehicle requirements for DAS4 fallback procedure 3.A.i Note added DAS4 keys and VSPs 3.C.i Annex 5 added, Service Information SI80.57-P-0008A Annex 6 added, Form OF80.57-P-3000-01A MBUSA Theft-Relevant Parts Policy Issued Date: January 30, 2015 Page 2, Revised February 16, 2022 Applies to: MBUSA Dealers Issued by: Dealer Assistance Center 1. Definitions A. Theft-Relevant Parts (TRP) TRPs are parts that may be required to steal a vehicle and/or to give a vehicle a new identity (see list of TRPs below for definition). The components listed below (series production parts and spare parts) retain their TRP status permanently. Only the current DAS designations are listed in the following listing. Regardless of what the list contains, all parts marked with the TRP and Theft-Relevant Information (TRI) identifiers in the documentation systems and Paragon, in compliance with the procedural instructions shall be considered theft-relevant. • Electronic vehicle key • Electronic steering lock (ELV, ESL, ESCL) • Electronic ignition switch (EZS/EIS) and workshop key for personalization • Electronic ignition switch with integrated central gateway (EZS/ZGW, EIS/CGW) • Electronic selector lever module (EWM/ESM) • Vehicle-related plates, identification plate, production plate, visible VIN plate, including base material • Transmission control unit (VGS, TCM) • Direct shift module (DSM, ISM) • Bodies and body sections/parts for placement of the vehicle identification number • Engine control unit (MSG, MCM) • Power electronics for electric drive with DAS (TUBE) • Hybrid and e-drive control unit (EMx, ME2) • Belt-driven or integrated starter-alternator (RSG, ISG) for DAS4 • Locking sets and mechanical keys B. Theft-Relevant Information (TRI) TRI is information that may be required to steal a vehicle and/or to give a vehicle a new identity (see list of TRI below for definition). It includes the following: • Locking data record • Initialization data • Personalization data • Disable/enable information 2. Theft-Relevant Parts Documentation and Record Keeping It is the dealer’s responsibility to verify the required documentation before accepting any order for, or delivering, a TRP. This precaution is necessary to safeguard our customers’ valuable properties and minimize your liability exposure. Failure to adhere to these requirements can expose you, your employees and your dealership to criminal or civil liability in cases of theft or fraud. For these reasons, it is essential that all personnel adhere to the following documentation process. MBUSA Theft-Relevant Parts Policy Issued Date: January 30, 2015 Page 3, Revised February 16, 2022 2. Theft-Relevant Parts Documentation and Record Keeping (continued) Theft-Relevant Parts may only be ordered by the vehicle owner, or his/her authorized representative, or authorized Mercedes-Benz or Freightliner dealerships completing a vehicle repair. TRP orders for any vehicle not physically located within the USA cannot be accepted. Instead, customers must be referred to the Mercedes-Benz or other Daimler-related service organization in the country where the vehicle is located. For vehicles which were not originally distributed or sold by Mercedes-Benz USA, LLC (“MBUSA”) or Daimler Vans USA, LLC (“DVUSA”), but reside in the USA, additional documentation requirements may apply when placing orders for TRPs (and any other spare parts) for these non-USA vehicles. All TRP transactions must be documented on the TRP form along with the necessary supporting documentation. A. TRP Documentation for the Vehicle Owner When an order for a TRP is placed by the vehicle owner, the following documents must be presented: • Proof of ownership: The original of the vehicle registration, title, or any ownership document which would be accepted by a Dept. of Motor Vehicles to issue a title. (Copy and retain on file). • Proof of Identity: The original of the vehicle owner’s government issued driver/operator license or passport. (Write details on TRP form. Do not copy or retain document). B. TRP documentation for the Authorized Representative of the Vehicle Owner When an order for a TRP is placed by an authorized representative of the vehicle owner, the following documents must be presented: • Proof of ownership: The original of the vehicle registration, title or any ownership document, which would be accepted by a state motor vehicle agency to issue a title. (Copy and retain on file). • Proof of Representative’s identity: The original of the authorized representative’s government issued driver/operator license with photo or passport. (Write details on TRP form. Do not copy or retain document). • Authorization: An original document authorizing the representative to act on behalf of the vehicle owner. (Retain original in vehicle file). • Proof of Owner’s identity: Original or photocopy of the vehicle owner’s government issued driver/operator license with photo or passport. (Write details on TRP form. Do not copy or retain document). An authorized representative may be: 1. A private citizen or family member acting on behalf of the owner 2. Independent workshop acting on behalf of their customer 3. An employee acting on behalf of their employer 4. A government official acting on behalf of their agency or department 5. An association member acting on behalf of their association An authorization letter must come from someone authorized by the company, agency or association to act on its behalf, and include a copy of the authorizer’s personal identification. MBUSA Theft-Relevant Parts Policy Issued Date: January 30, 2015 Page 4, Revised February 16, 2022 2. Theft-Relevant Parts Documentation and Record Keeping (continued) C. TRP Documentation for Dealership Employees When an order for a TRP is placed by a dealership employee for the purpose of repairing a dealer owned vehicle presented for service, or completing the key set for unsold vehicles (new or used), the following documentation must be presented: • A valid Repair Order authorized by the vehicle General Manager or Sales Manager, with the TRP clearly noted. • A legibly completed TRP form signed by the requesting employee and delivering employee. • Personal identification of dealer employees does not need to be presented. D. TRP Documentation for Vehicle Security Professionals (VSPs) participating in the NASTF Secure Data Release Model (SDRM) Registry When an order for a TRP is placed by a VSP, the following documentation must be presented: • TRP Authorization: Email authorization document that is received by the Dealer after the request is submitted through the SDRM Registry via the Mercedes-Benz Theft-Relevant Part D-1 order form (at https://sdrm.nastfsecurityregistry.org). (Retain printout in vehicle file) • VSP Authorization: VSP Registry Positive ID Authorization Form D-1. (Transfer owner details from D-1 onto TRP form, retain D-1 printout in vehicle file). Acts as an Authorization letter and Owner identification. A completed sample form is shown in Annex 4. • Proof of ownership: Copy of the vehicle registration, title, or any ownership document which would be accepted by a Dept. of Motor Vehicles to issue a title. (Copy and retain copy on file). • VSP Proof of identity: Original or photocopy of the VSP’s government-issued driver/operator license with photo or passport. (Write details on TRP form. Do not copy or retain document). • Repair Order: A valid repair order from the VSP’s business, with the customer name & address, VIN and TRP part number(s) clearly noted. (Retain copy in vehicle file) For more information on the SDRM registry and how to become a Vehicle Security Professional (VSP), please visit www.nastf.org → Vehicle Security Professional. E. TRP Documentation for Independent Service Providers (ISPs) who are not Vehicle Security Professionals (VSPs) ISPs who are not Vehicle Security professionals are considered Authorized Representatives as stated in Section 2.B. F. TRP Documentation Verification Process The dealership employee(s) both accepting and/or delivering TRP must verify that the person presenting the documents is in fact the person identified by the documents. There must be a clear match between the identification documents and ownership documentation and the person ordering/receiving the TRP. Discrepancies must be resolved or the TRP sale refused. G. TRP Form and Archiving The TRP form is an essential part of the TRP Process, providing a procedural guideline for TRP transactions and must be fully completed as instructed. The fully completed and signed TRP form together with all required documents (2A, 2B, 2C, 2D plus Repair Order) shall be archived and kept in a secure location for a period of 6 years. Legible archiving by means of electronic scanning is also possible. All files are subject to audit at any time, and must be available for presentation to representatives of MBUSA or other Daimler related entities or law enforcement authorities at any time for the entire retention period. MBUSA Theft-Relevant Parts Policy Issued Date: January 30, 2015 Page 5, Revised February 16, 2022 3. Mercedes-Benz/Freightliner Dealer Workshop and Independent Service Provider (ISP) Ordering Processes Irrespective of which TRP order process is used, vehicle referencing is mandatory for processing TRP and TRI within the workshop and customer process. This ensures a direct match between the vehicle owner/representative and his/her vehicle and between the TRP and TRI requirements and the vehicle identification number (FIN/VIN). A. Mercedes-Benz or Freightliner Workshop Process for Keys Particular emphasis shall be placed on ensuring the reliability of TRP handling procedures, with special focus given to the electronic vehicle key and the mechanical vehicle key. • Vehicle keys may not be handed over the counter (including mailing), except to VSPs in strict accordance with Section 2.C. below. • Vehicle keys shall in all cases be taken into operation on the vehicle and tested for proper functioning. Testing shall comprise both the mechanical and electronic (as applicable) functions: Opening and locking, release of the immobilizer when the engine is started. • The customer shall deliver the vehicle to the dealership for key testing. At the dealer’s option, a dealership employee may dispatched to the vehicle to perform the testing. • All documentation requirements remain in effect regardless of where the testing is performed. • A Vehicle Security Professional (VSP) may purchase keys as outlined in Section 2.C. without the vehicle being presented to the dealer for testing. Testing must still be performed. i) Process for Ordering Keys when No Keys are Available (DAS4 only) Dealer must follow the instructions given in Star Bulletin S-B-80.57/62H (or later). This involves completing a form from the Workshop Information System (WIS), creating a XENTRY Diagnosis XSF case, and awaiting the response that Daimler has registered the vehicle. The programmed key must be ordered immediately. Note Vehicle VIN referencing is critical in cases in where the fall back procedure is used further information can be found in the following Service Information SI80.57-P-0008A “Programming and ordering a replacement key or additional key”, and Form OF80.57-P-3000-01A “Register vehicle as present for programming/ordering a DAS4 key”. (These documents are available in the Work Shop Information System (WIS)). Note that for lost keys, the tracks for the lost keys must be blocked in order to comply with the TRP policy. A corresponding note must be made on the Repair Order if the customer declines the recommended repair procedure for keys. Important Note: It is prohibited for to sell un-programmed vehicle keys or mechanical key blanks. These parts are solely for use in the Mercedes-Benz / Freightliner Dealer workshop and cannot be sold over the counter. MBUSA Theft-Relevant Parts Policy Issued Date: January 30, 2015 Page 6, Revised February 16, 2022 3. Mercedes-Benz/Freightliner Dealer Workshop and Independent Service Provider (ISP) Ordering Processes (continued) B. Mercedes-Benz or Freightliner Workshop Process for TRP other than Keys Theft-relevant parts as a matter of policy should only be installed at authorized Mercedes-Benz or Freightliner workshops, certain exceptions apply. The replacement of TRP components shall be recorded on a repair order as documented proof that the parts were turned over to the customer (entitled customer or authorized representative) at an authorized Mercedes-Benz or Freightliner workshop and that they were installed in the vehicle. Taking components into service that were purchased elsewhere and brought in by the customer to complete the repair is prohibited. The separate legitimization can be omitted if there is an existing workshop order for these components. The components that apply to the requirements in this section are: • Electronic steering lock (ELV, ESL, ESCL) • Electronic ignition switch (EZS/EIS) and workshop key for personalization • Electronic ignition switch with integrated central gateway (EZS/ZGW, EIS/CGW) • Electronic selector lever module (EWM/ESM) • Vehicle-related plates, identification plate, production plate, visible VIN plate, including base material • Transmission control unit (VGS, TCM) • Direct shift module (DSM, ISM) • Engine control unit (MSG, MCM) • Power electronics for electric drive with DAS (TUBE) • Hybrid and e-drive control unit (EMx, ME2) • Belt-driven or integrated starter-alternator (RSG, ISG) for DAS4 • Locking sets and mechanical keys • If an updated threat analysis warrants the addition of further TRP, these shall be protected as well Completion and archiving of the TRP form for repair types listed above can be fully waived under the following five conditions (does not apply to keys, locking sets, key track disabling/enabling): 1. A valid repair order (noting VIN and customer name and address) is completed and the repair will be carried out in the authorized workshop. 2. The DAS components are properly listed and identified by part number on the customer/repair order. 3. The customer/repair order shall be archived for at least 6 years in line with the TRP form retention requirement. 4. The traceability to the chassis number is ensured. Example: For a TRP audit pertaining to a certain chassis number, please provide the repair order on which the installation of a DAS component was traceably documented. 5. The traceability to the part number is ensured. Example: For a TRP audit pertaining to a certain DAS component with a particular part number, please provide all the repair orders/chassis numbers on which the component was installed within a particular time period. If compliance with ANY of the items 1 to 5 above cannot be ensured, the TRP form shall be completed and archived in accordance with applicable instructions. MBUSA Theft-Relevant Parts Policy Issued Date: January 30, 2015 Page 7, Revised February 16, 2022 3. Mercedes-Benz/Freightliner Dealer Workshop and Independent Service Provider (ISP) Ordering Processes (continued) C. Independent Service Provider (ISP) Process for TRP Only registered VSPs may purchase the parts listed in this section. ISPs and other authorized representatives who are not VSPs may not purchase parts that are listed in this section. This ordering process provides a secure ordering channel for those ISPs that are enrolled in the NASTF Vehicle Security Professional (VSP) Registry. Authorized Mercedes-Benz and Freightliner dealers are able to sell the below-listed TRPs to ISPs under the following conditions: • ISP must be a member in good standing of the NASTF VSP registry • Validated order request is transmitted to the Parts Manager’s inbox which is located on the home page of NetStar • The dealer and the ISP should work out the terms and conditions prior to the dealer placing the order in the parts ordering system (Paragon) • The ISP must provide the dealer with all necessary documentation (see Section 2D and below) before taking possession of the TRP part • Dealer personnel must make sure that there is a clear match with the VSP that ordered the part and the person that is signing for it at the dealer Following are the part descriptions for parts that can be sold only to VSPs, and not to non-VSP ISPs. Actual part numbers will vary based on the vehicle’s application. An example of each part is provided for identification purposes only. • Electronic steering lock (ELV, ESL, ESCL) e.g., A208 462 04 30 / A 037 545 16 32 • Electronic ignition switch (EZS/EIS) and workshop key for personalization e.g., A 211 545 31 08, including EIS with integrated central gateway (EZS/ZGW, EIS/CGW) e.g., A 164 545 16 00 • Electronic selector lever module (EWM/ESM) e.g., A 220 267 33 24 • Transmission control unit (VGS, TCM) e.g., A 000 270 17 00 & A 220 270 31 06 • Direct shift module (DSM, ISM) e.g., A 000 270 33 52 • Engine control unit (MSG, MCM) e.g., A 278 900 13 00 • Keys (see Section 3.C.i below) Other TRPs not listed in this section may be sold over the counter to non-VSPs. The documentation process in Section 2B of this policy must be followed. i) VSP Process for Keys Vehicle Security Professionals (VSPs) participating in the NASTF Secure Data Release Model (SDRM) Registry may purchase pre-programmed and/or pre-cut Keys, subject to additional documentation requirements: • All documentation outlined in Section 2D must be presented • An additional certification (Annex 2) must be completed and presented to the dealer. Dealer must retain the original and keep it with the other TRP documentation for the transaction. • Keys may be shipped securely to a VSP. • Blank or unprogrammed keys may not be sold under any circumstances. • DAS 4 keys require the need for the VSP to maintain an active XENTRY Diagnosis subscription in order to mark the vehicle as present, in cases where an additional key needs to be ordered. MBUSA Theft-Relevant Parts Policy Issued Date: January 30, 2015 Page 8, Revised February 16, 2022 • For DAS 4 keys, when no keys are present, the VSP must perform vehicle and VIN referencing at the vehicle, along with the submission of all documentation required in section 2.D, to the authorized Mercedes-Benz dealer before the submission of form OF80.57-P-3000-01A via XSF ticket. Failure to complete these steps prior to ordering is in violation of the TRP policy; warnings and fines will be issued in cases where correct DAS 4 procedures are not followed. Note, additional information and process documentation for DAS 4 key ordering for Vehicle Security Professionals can be found on the PAC Website via NetStar. 4. Handling Vehicle Keys A fundamental rule is that when any vehicle is received, the keys that are handed in for customer vehicles, new vehicles, demonstration vehicles, used vehicles, hired vehicles and the company’s own vehicles must be tested to ensure that they function in the respective vehicle. Non- functioning keys must be determined in the presence of the person handing them in and recorded in writing, with the signature of both the person handing in the key and the person accepting the key. If a key is lost by the customer, or while the vehicle is in the care of an authorized dealership, the key track(s) in question must be disabled immediately and rendered inoperative by procuring and programming a replacement for the missing key. The complete mechanical lock set must be replaced to ensure vehicle security. The customer must be informed of the repair. A corresponding note must be made on the repair order if the customer declines the recommended repair procedure for keys. 5. Storage of Undelivered TRPs, Handling of Faulty or Unneeded TRPs Keys and other TRPs received by the dealer and awaiting installation or delivery must be stored in a secure location with limited and controlled access. Dealers must maintain control of the on hand inventory of all uninstalled TRP parts at all times. When a TRP is to be replaced, the old parts which have been removed are not to be handed over to the customer or the customer’s representative. The customer is to be informed of this prior to acceptance of the order. If the customer insists on being given the old part (customer-pay only), receipt of the part must be acknowledged by the customer in writing on the repair order. For quality analysis, the Quality Evaluation Center (QEC) can request TRPs replaced under warranty for evaluation. TRPs requested to be returned to MBUSA or DVUSA must be sent using a traceable method. All special order TRPs that are not collected by the Customer and all old TRP parts removed for repair purposes, for which return is not planned, must be destroyed and rendered completely inoperable and/or unusable by the dealer, this destruction must be recorded on the TRP form. MBUSA Theft-Relevant Parts Policy Issued Date: January 30, 2015 Page 9, Revised February 16, 2022 6. Important Notes Keys ordered by a dealer cannot be drop-shipped to a third party location (except as outlined in 3.C.i.). Shipments between Authorized Mercedes-Benz / Freightliner Dealers are permitted but discouraged. Any part that is uniquely coded to the vehicle is not returnable for credit; therefore, the dealer should make every effort to deliver the ordered part to the customer. If you encounter operational problems with a key or lock from the Fort Worth Key & Lock Site, please complete a Quality Control Sheet and return it with the respective key or lock. The Key & Lock Site will acknowledge the report and advise the corrective action to be taken. It is prohibited for to resell un-programmed vehicle keys or mechanical key blanks. These parts are solely for use in the Mercedes-Benz / Freightliner Dealer workshop and cannot be sold over the counter. 7. Policy Audits MBUSA or DVUSA will randomly select dealers and TRP orders for TRP process review. Selected dealers will receive a written listing of TRP purchases transacted by the dealer and will have a specified time period to respond in writing and provide the necessary TRP documentation. MBUSA or DVUSA will review the TRP documentation and advise the dealer of the issues and concerns identified. The following corrective actions will be applied for non-conformance of the policy: • First Offense – The dealer will be advised of the non-compliance and be re-audited within several months to verify effective corrective actions have been taken. It is expected that the dealer will implement robust processes to ensure compliance. • Second Offense (1st re-audit) – The dealer will be assessed a $500 administrative fee by MBUSA or DVUSA for each instance (VIN or Part Number) where the TRP process was not followed. A second re-audit will be scheduled. • Third Offense (2nd re-audit) – The dealer will be assessed a $1,000 administrative fee by MBUSA or DVUSA for each instance (VIN or Part Number) where the TRP process was not followed. Further or continuing non-compliance may incur increasing penalties and limitations, including but not limited to a mandatory review of all TRP orders placed by a dealer. MBUSA Theft-Relevant Parts Policy Issued Date: January 30, 2015 Page 10, Revised February 16, 2022 Annex 1 – TRP Order Form (MBUSA-137754962792) This is a sample of the TRP Form Sheet. Always download the latest version of this form before using it. This form can be found on the PAC website and at www.startekinfo.com MBUSA Theft-Relevant Parts Policy Issued Date: January 30, 2015 Page 11, Revised February 16, 2022 Annex 2 – VSP Key Certification Form This is a sample of a two-page form available from the PAC Website and www.startekinfo.com. Download the latest version of this form before using it. This form must be completed and retained by the dealer when selling any key to a VSP. Only original, hand-written signatures are allowed. MBUSA Theft-Relevant Parts Policy Issued Date: January 30, 2015 Page 12, Revised February 16, 2022 MBUSA Theft-Relevant Parts Policy Issued Date: January 30, 2015 Page 13, Revised February 16, 2022 Annex 3 – DAS4 Fallback process Star Bulletin S-B-80.57/62H, dated April 9, 2019 – Ordering a Programmed Key when no keys are present – “The Fallback process”. (First page only). Refer to complete document for important details. MBUSA Theft-Relevant Parts Policy Issued Date: January 30, 2015 Page 14, Revised February 16, 2022 Annex 4 – Sample completed NASTF D-1 form The North American Service Task Force (NASTF) required all Vehicle Security professionals (VSPs) to complete a D-1 form within 2 days of any TRP request. Here is a sample completed form. Any missing information (e.g., owner ID number) must be taken from the document (e.g., copy of owner’s driver license) in accordance with the requirements of section 2.D: MBUSA Theft-Relevant Parts Policy Issued Date: January 30, 2015 Page 15, Revised February 16, 2022 Annex 5 – Service Information: Programming and Ordering a replacement key or additional key, SI80.57-P-0008A Service information covering the workshop and parts department process for programming and ordering a replacement key or additional key. Refer to complete document for important details, found in the Work Shop Information System (WIS). MBUSA Theft-Relevant Parts Policy Issued Date: January 30, 2015 Page 16, Revised February 16, 2022 Annex 6 – Register vehicle as present for programming/ordering a DAS4 key, OF80.57-P-3000-01A Organizational Form required with XSF Ticket when conducting the DAS4 fallback procedure. Refer to complete document for important details, found in the Work Shop Information System (WIS).

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