Supplier Code Of Conduct And Ethics

Responsibility & Compliance

Introduction

SEALMATIC’s commitment to compliance towards conduct and ethics is based on integrity, respect, reliability and sustainability as cornerstones of our actions. We are aware that our ability to meet our own compliance standards and those of our customers depends to a large extent on how we work together with our suppliers. Consequently, we expect our suppliers to adhere to a set of rules in order to ensure that we work on the basis of the same values and principles.

SEALMATIC's Supplier Code of Conduct and Ethics ("Supplier Code") thus sets forth the minimum requirements for all suppliers to conduct business with SEALMATIC.

1. Organizational Requirements And Management Responsibility

SEALMATIC requires from its suppliers that they install and maintain adequate compliance procedures in order to enable effective compliance with this Supplier Code or the supplier's own equivalent policy or code of conduct.

  • As a minimum, the supplier's procedures shall comprise:
    • identification of one or more individuals with senior management authority accountable for the implementation of the compliance management system (compliance officer or company director);
    • identification of key compliance risk areas;
    • sanctioning any violations of compliance regulations
  • We also request our suppliers to communicate this SEALMATIC Supplier Code to those of its employees concerned with the SEALMATIC business.

2. Supplier Commitment And Contractual Obligations

The undertaking by suppliers to comply with this Supplier Code shall form the basis of our business relationship. This Supplier Code shall form part of any agreement entered into by you as supplier. However, when entering into a contract with us, the supplier may be asked again to reconfirm his compliance with this Supplier Code.

3. Export Control

SEALMATIC requires its suppliers to comply with export control laws and to respect export and trade sanctions or other bans. If necessary, the supplier shall obtain any export permits required and/or assist SEALMATIC in obtaining its export licenses:

4. Human Rights And Fair Working Conditions

SEALMATIC expects its suppliers to support and protect human rights in the supplier’s workplace and business activities and to ensure that working conditions are in line with the law and with internationally applicable standards and conventions (such as ILO, OECD Guidelines for Multinational Enterprises, UN Global Compact Initiative or the Global Reporting Initiative). In particular, the supplier shall:

  • not engage in or benefit from any form of child labor, and in particular not employ any workers below 15 years of age (below 14 years of age in certain developing countries) or a higher minimum age according to national legislation in line with ILO Convention 138 on Child Labor;
  • not practice any form of discrimination in hiring and employment practices on the grounds of race, color, ethnic origin, religion, nationality, gender, sexual orientation, age, physical ability, health condition, political or social opinion, union membership, or marital status;
  • pay all workers at least the minimum wage required by law or applicable industry regulations (such as collective bargaining agreements or the like);
  • ensure that the workplace is safe and contains no health hazards, establish appropriate organizational structures and procedures for the effective management of health and safety risks, and train employees on these procedures. Suitable procedures and plans shall be developed and published.

5. Environmental And Social Responsibility, Sustainability

SEALMATIC expects its suppliers to manage their operations in a responsible manner with a view to fulfilling the environmental requirements defined in the applicable laws, regulations, or permits.

  • obtain and maintain the required permits and licenses and comply with the reporting requirements set forth therein;
  • endeavor to avoid or reduce waste or emissions resulting from his business activities and dispose of waste in a legal and responsible manner;
  • install an environmental management system (e.g. ISO 14001 or equivalent) at its worksites to make sure that measures are implemented to protect the environment and to be compliant in all processes concerned;.

6. Business Integrity

SEALMATIC requires its suppliers to conduct business with integrity and in compliance with legal requirements and to adhere to internationally agreed standards of business ethics. In particular, the supplier shall:

  • comply with all applicable laws and regulations in the country where it carries out its business activities;
  • not engage in or tolerate any form of corruption, bribery, extortion or embezzlement. This means that suppliers may not offer, promise, give, or authorize any sort of bribe or kickback in order to obtain or retain business or any improper business advantage;
  • comply with antitrust and fair competition laws. In particular, it must be ensured that suppliers do not discuss topics that could violate, or appear to violate, competition laws by price-fixing; terms of sale; bid-rigging; division of markets, territories or customers; tying and bundling products; using deceptive trade practices; or abusing a dominant market position;
  • avoid conflicts of interest, in particular, by disclosing any financial interest that an SEALMATIC employee may have in the supplier and by not offering or granting directly or indirectly any benefit to an employee of SEALMATIC with a view to obtaining business from SEALMATIC. However, no gift or favor should be bestowed that could be interpreted as being intended or is intended to influence the objective decision-making process by our employees;

7. Reporting, Monitoring, And Sanctioning

If you as a supplier become aware of a violation of this Supplier Code, you shall report such violation to. Depending on the gravity of the violation, adequate corrective measures may be requested by SEALMATIC from the supplier, including the termination of cooperation with an employee or sub-supplier of the supplier. For as long as the requested remedies are not implemented, SEALMATIC may withhold payments that would otherwise be due to the supplier. If the requested remedy is not able to prevent or repair harm to SEALMATIC or if the breach of the Supplier Code is considered to be a major breach of contract, SEALMATIC shall be entitled to terminate the contract relationship with the supplier immediately.

8. Intellectual Property Rights, Trade Secrets, And Data Privacy And Protection

SEALMATIC requires its suppliers to respect third-party intellectual property rights and trade secrets and to protect our own or our customers’ intellectual property rights, trade secrets, and personal data, which you as supplier may become aware of in the course of contract execution with SEALMATIC.

  • This implies taking adequate technical measures to avoid unintended disclosure of intellectual property or trade secrets and requiring confidentiality undertakings from business partners who need to have access to the foregoing on a need-to-know basis for the execution of their supplies to our company.
  • Furthermore, we expect our suppliers to respect the privacy of their employees’ and business partners’ personal data and to collect and retain personal data only as required to operate efficiently and as permitted by law. You as supplier to SEALMATIC are committed to handling personal data with care and to safeguarding and protecting such information to ensure it is not lost, misused, accessed without authorization, disclosed, altered or destroyed.