Supplier Code of Conduct

Legal Conditions

Supplier Code of Conduct

Opening Statement

EPCON is a world leader in the manufacturing of high-quality industrial products for a broad scope of industries and applications. At EPCON, our social, environmental and ethical standards are high, but we also do our best to ensure that our values are reflected across our supply chain.

The EPCON Supplier Code of Conduct (hereafter the “Code”) embodies a framework outlining the standards of integrity for which we strive throughout our business and supply chain. Suppliers are expected to agree to the terms of this Code and uphold this Code in all of their business operations. The Supplier Code of Conduct applies to all suppliers, consultants, contractors, business partners, agents and more generally any third party with whom we do business (collectively “Suppliers”).

 

Labor and Human Rights

EPCON has the utmost respect for human and labor rights and require our Suppliers to also commit to these values.

  • Anti-discrimination
  1. Suppliers shall not discriminate against any worker in hiring, salary, promotion or termination on the basis of age, disability, race, ethnic origin, gender, marital status, national or social origin, political affiliation, skin color, religion, sexual orientation, or on the basis of any personal characteristic protected by law.
  • Anti-Harassment and Abuse
  1. Suppliers shall ensure a workplace free of harassment and abuse, including but not limited to verbal abuse, psychological harassment, mental and physical coercion, and sexual harassment.
  • Forced Labor
  1. Suppliers shall not use forced or compulsory labor; nor be complicit with any form of slavery or human trafficking.
  • Prevention of Child Labor
  1. Suppliers shall not engage in child labor in accordance with the Convention of the International Labor Organization.
  • Working, Hours Wages and Benefits
  1. Suppliers shall follow all applicable laws with respect to working hours, wages and benefits.

 

Environment, Health, Safety and Energy

Suppliers shall ensure a safe and healthy workplace, while also trying to protect the environment and natural resources for society at large.

  • Occupational Health, Safety and Hazard Protection
  1. Suppliers shall identify, evaluate, and manage occupational health and safety hazards. Suppliers shall provide workers with appropriate personal protective equipment and instruction.
  2. Suppliers shall develop and implement emergency plans, response procedures and a system for corrective action.
  • Environment and Energy
  1. Suppliers shall have systems in place to ensure safe management of waste, air emissions and wastewater discharges.
  2. Suppliers shall obtain, keep current, and comply with all required environmental permits, and strive for increasingly sustainable solutions and processes.
  3. Suppliers shall seek to reduce the use of energy, water, natural resources and hazardous substances by implementing conservation and substitution measures.

 

Business Ethics

Ethics and integrity are guiding principles at EPCON. We only want to do business with organizations that we can trust and that conduct their business with honesty and transparency.

  • Business Integrity
  1. Suppliers shall not be involved in corruption, influence peddling, extortion, embezzlement, or bribery in any form including facilitation payments.
  2. Suppliers shall abide by all applicable anti-corruption laws and regulations whether local or foreign, that apply to foreign operations, including but not limited to the US Foreign Corrupt Practices Act, the UK Bribery Act and the French Law Sapin 2.
  3. Suppliers shall maintain policies and practices to allow violations, misconduct or grievances to be reported by workers and addresses without fear or retaliation.
  4. Suppliers shall provide evidence of compliance with this section upon request of EPCON.
  • Disclosure of Information
  1. Suppliers shall accurately record and disclose information regarding its business activities, labor, health and safety, and environmental practices to all appropriate parties.
  • Protection of Intellectual Property, Confidential Information & Data
  1. Suppliers shall respect intellectual property rights and safeguard customer’s confidential information.
  2. Suppliers shall comply with the data protection laws and particularly the General Data Protection Regulation (GDPR) where applicable.
  • Conflicts of Interest
  1. A conflict of interest is any situation where a Suppliers employee has a close relationship with an EPCON employee who can make decisions that will affect the Supplier’s business.
  2. Suppliers shall avoid conflicts of interest and the appearance of conflicts of interest. Any conflict of interest or any potential conflict must be declared to EPCON.
  • Export / Import
  1. Suppliers shall act in compliance with all restrictions, regulations and the laws that govern the importing and exporting of goods, services, technologies and information, including re-exports and parallel trade.
  2. Suppliers should abide by any economic or trade sanctions issued by the United States or the Unite Nations and or any countries where the supplier operates.
  • Conflict Minerals
  1. Suppliers shall comply with Dodd- Franck Act and not purchase, trade, possess or use conflict minerals which are minerals where human rights violations and violent conflicts are occurring. 
  • Compliance with Competition laws
  1. Supplier shall not be engaged in collusive bidding, price fixing, price discrimination or other unfair trade practices in violation of fair competition.
  • Financial Integrity
  1. Supplier shall prepare financial statements in accordance with generally accepted accounting principles and keep proper and accurate records of all business operations and transactions.
  • Sub-Contracting
  1. Suppliers do not use subcontractors or assign to any other party its contractual obligations to EPCON, without prior written approval by EPCON or its subsidiaries. Prior written acceptance of this Code by the approved subcontractor or assignee is required before production begins.

 

Application and Acceptance

Suppliers will be selected during the Request for Quote/Request for Proposal phase based on several criteria including sustainability. Suppliers must diligently provide official answers, documents, and certificates related to sustainability as soon as it is requested by EPCON.

This EPCON Supplier Code of Conduct applies to all Suppliers, of EPCON. It is a requisite part of all contractual agreements between EPCON and its Suppliers from the indicated date of entry into force of this Code.

All Suppliers (including their affiliates) entering into a commercial relationship with any EPCON entity from the day of entering into such relationship will also be deemed as adhering to the EPCON Supplier Code of Conduct, and the written entitlement document (i.e. purchase order, contract, master service agreement, etc.) will be considered as acceptance.

 

Evaluation

By adhering to this Supplier Code of Conduct, each Supplier of EPCON accepts to be assessed or audited by EPCON or by a third party mandated by EPCON on the above-mentioned principles.

Suppliers shall implement an effective compliance program to deter and prevent breaches and violations of laws and policies. If any breaches or violations happen Suppliers shall implement adequate measures to prevent reoccurrence.

If any violation of this Code is identified, the applicable Supplier might, at EPCON’s discretion, be given time to remediate the problem, with EPCON assistance where possible. If the problem is not addressed in an effective way, and within a clear timeframe that is acceptable to EPCON, we reserve the right to terminate our business relationship with the violating Supplier.

 

Updated on 09.30.2023

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