Code of Conduct
We comply with the laws, regulations, and social norms of the countries where we operate, and we implement and promote this code of conduct, which aligns with the RBA Code of Conduct compiled by the Responsible Business Alliance (RBA), to meet stakeholder expectations.
We are committed to upholding the human rights of workers and treating them with dignity and respect as understood by the international community. This applies to all workers, including temporary, migrant, student, contract, directly employed, and any other type of workers, as well as the workers of our direct and indirect suppliers.
- 1Prohibition of Forced Labor
We do not permit forced labor, bonded (including debt bondage) or indentured labor, involuntary or exploitive prison labor, slave labor, or human trafficking.
- 2Young Workers
We do not use child labor in any stage of manufacturing.
- 3Working Hours
We comply with the laws and regulations on working hours and do not exceed the maximum hours set by local laws.
- 4 Wages and Benefits
We pay compensation in accordance with applicable wage laws, including those relating to minimum wage, overtime pay, and legally mandated benefits. We pay overtime pay at rates greater than regular hourly rates in accordance with local laws.
- 5Non-Discrimination/Non-Harassment and Humane Treatment
We put measures in place to prevent offensive or inhumane treatment of workers, such as violence, gender-based violence, sexual harassment, sexual abuse, corporal punishment, mental or physical coercion, bullying, public shaming, or verbal abuse, or the threat of such treatment. We do not engage in harassment or discrimination based on race, color, age, gender, sexual orientation, gender identity and expression, ethnic or national origin, disability status, pregnancy, religion, political party affiliation, union membership, military service status, protected genetic information or marital status, in hiring and employment practices, such as wages, promotions, rewards, and access to training.
- 6Freedom of Association and Collective Bargaining
In conformance with local laws, we respect the rights of workers to form and join trade unions of their own choosing, to bargain collectively, and to engage in peaceful assembly as well as respect the rights of workers to refrain from engaging in such activities.
We recognize that in addition to minimizing incidents of work-related injury and illness, a safe and healthy work environment enhances the quality of products and services, consistency of production, and worker retention and morale. We also recognize that ongoing worker input and education are essential to identifying and solving health and safety issues in the workplace and have the following measures in place.
- 1Occupational Health and Safety
We identify and assess worker potential for exposure to health and safety hazards (chemical, electrical and other energy sources, fire, vehicle, and fall hazards) and take appropriate measures to mitigate such hazards.
- 2Emergency Preparedness
We identify and assess potential emergency situations and events and minimize their impact by implementing emergency plans and response procedures, including emergency reporting, employee notifications, evacuation procedures, worker training, and drills.
- 3Occupational Injury and Illness
We put in place procedures and systems to prevent, manage, track, and report occupational injury and illness.
- 4Industrial Hygiene
We identify and assess worker exposure to chemical, biological, and physical agents. If any potential hazards are identified, we take appropriate measures to mitigate such hazards.
- 5Physically Demanding Work
We identify, evaluate, and control worker exposure to the hazards of physically demanding tasks, such as manual material handling and heavy or repetitive lifting, prolonged standing, and highly repetitive or forceful assembly tasks.
- 6Machine Safeguarding
We evaluate production and other machinery for safety hazards and properly install and maintain safety mechanisms to prevent injuries or dangers to workers.
- 7Sanitation, Food, and Housing
We provide workers with access to clean toilet facilities, drinking water, and sanitary food preparation, storage, and eating facilities.
- 8Health and Safety Communication
We provide workers with appropriate health and safety information and training in their native language or in a language they can understand for the workplace hazards they are exposed to, including but not limited to mechanical, electrical, chemical, fire, and physical hazards.
We recognize that environmental responsibility is integral to producing world-class products. We identify the environmental impacts of our manufacturing operations and strive to minimize adverse effects on the community, environment, and natural resources from these operations while safeguarding the health and safety of the public.
- 1Environmental Permits and Reporting
We obtain, maintain, and keep current all required environmental permits (e.g., discharge monitoring), approvals, and registrations, and follow their operational and reporting requirements.
- 2Pollution Prevention and Resource Reduction
We endeavor to minimize or eliminate our emissions of pollutants and generation of waste either at the source or by practices such as adding pollution control equipment; modifying production, maintenance, and facility processes; or by other measures. We conserve our use of natural resources, including water, fossil fuels, minerals, and virgin forest products, through practices such as modifying production, maintenance, and facility processes, substituting materials, reuse, conservation, and recycling, or other means.
- 3Hazardous Substances
We identify, label, and manage chemicals, waste, and other materials hazardous to humans or the environment to ensure that they are handled, transported, stored, used, recycled or reused, and disposed of safely.
- 4 Reduction of Solid Waste and a Responsible Approach to Disposal and Recycling
We have implemented a systematic approach to identify, manage, reduce, and responsibly dispose of or recycle non-hazardous solid waste.
- 5Monitoring, Control, and Management of Air Emissions
We characterize, routinely monitor, control, and treat as required prior to discharge air emissions of volatile organic chemicals (VOC), aerosols, corrosives, particulates, ozone-depleting substances, and combustion byproducts generated from our operations. We effectively manage ozone-depleting substances in accordance with the Montreal Protocol and applicable regulations.
- 6 Adherence to Material Restrictions
We adhere to all applicable laws and regulations regarding the prohibition or restriction of specific substances in products or manufacturing, including labeling for recycling and disposal.
- 7Water Management
We implement a water management program that documents, characterizes, and monitors water sources, use, and discharge; seeks opportunities to conserve water; and controls channels of contamination.
- 8Energy Consumption and Greenhouse Gas Emissions
We establish a company-wide greenhouse gas reduction goal. We track and document our energy consumption and all relevant Scopes 1, 2, and 3 greenhouse gas emissions and publicly report this information alongside our greenhouse gas reduction goals. We also look for methods to improve energy efficiency and minimize our energy consumption and greenhouse gas emissions.
To meet our social responsibilities and to achieve success in the marketplace, we uphold the following ethical standards.
- 1Business Integrity
We uphold the highest standards of integrity in our business interactions and have a zero-tolerance policy prohibiting all forms of bribery, corruption, extortion, and embezzlement.
- 2No Improper Advantage
We do not promise, offer, authorize, give, or accept bribes or other means of obtaining undue or improper advantage. We also implement monitoring, record-keeping, and enforcement procedures to ensure compliance with anti-corruption laws.
- 3Disclosure of Information
We conduct all business dealings transparently and reflect them in our books and records accurately. We disclose information regarding our labor, health and safety, environmental practices, business activities, structure, financial situation, and performance in accordance with applicable regulations and prevailing industry practices. We do not commit any falsification of records or misrepresentation of conditions or practices in the supply chain.
- 4 Intellectual Property
We respect intellectual property rights, conduct transfer of technology and know-how in a manner that protects intellectual property rights, and safeguard customer and supplier information.
- 5 Fair Business, Advertising, and Competition
We uphold standards of fair business, advertising, and competition.
- 6Protection of Identity and Non-Retaliation
We maintain a whistleblower protection program that ensures the confidentiality, anonymity, and protection of supplier and employee whistleblowers, unless prohibited by law.
- 7Responsible Sourcing of Minerals
We adopt a policy and exercise due diligence on the source and chain of custody of the tantalum, tin, tungsten, gold, and cobalt used in the products we manufacture to reasonably assure that these materials are sourced in a way consistent with the Organisation for Economic Co-operation and Development (OECD) Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas or an equivalent and recognized due diligence framework.
- 8Privacy
We are committed to meeting reasonable privacy expectations for the personal information of everyone we do business with, including suppliers, customers, consumers, and employees. We comply with privacy and information security laws and regulatory requirements when personal information is collected, stored, processed, transmitted, and shared.
We establish and adopt a management system that is designed to ensure: (a) compliance with applicable laws, regulations, and customer requirements related to our operations and products; (b) conformance with this policy; and (c) identification and mitigation of operational risks related to this policy. This system also facilitates continual improvement and contains the following elements.
- 1Company Commitment
The formulation of policies concerning human rights, health and safety, the environment, and ethics that are endorsed by management executives and that affirm our commitment to due diligence and continual improvement.
- 2Management Accountability and Responsibility
A clear identification of the executives and company representative(s) responsible for ensuring implementation of the management systems and associated programs, and a regular review by senior management of the status of the management systems.
- 3Legal and Customer Requirements
The introduction and establishment of processes to identify, monitor, and understand applicable laws, regulations, and customer requirements.
- 4Risk Assessment and Risk Management
A process to identify the risks associated with our operations concerning legal compliance, the environment, health and safety, labor practice, and ethics, including the risks of causing significant impacts on human rights and the environment.
- 5Improvement Objectives
Written performance objectives, targets, and implementation plans to improve our social, environmental, and health and safety performance, including a periodic assessment of our performance in achieving those objectives.
- 6 Training
Programs for training managers and workers to implement this policy, our procedures, and improvement objectives, and to meet applicable legal and regulatory requirements.
- 7 Communication
A process for communicating clear and accurate information about this policy and our initiatives, expectations, and performance to workers, suppliers, and customers.
- 8Worker and Stakeholder Engagement and Access to Remedy
The establishment of processes for two-way communication with workers, their representatives, and other stakeholders, when appropriate or necessary, for the purpose of obtaining feedback on business practices and conditions outlined in this code of conduct and for fostering continuous improvement.
- 9Audits and Assessments
Periodic self-evaluations to ensure conformity to legal and regulatory requirements, the content of this policy, and customer contractual requirements related to social and environmental responsibility.
- 10Corrective Action Process
A process for timely correction of deficiencies identified by internal or external assessments, inspections, investigations, and reviews.
- 11Documentation and Records
The creation and maintenance of documents and records to ensure regulatory compliance and conformity to company requirements along with appropriate confidentiality to protect privacy.
- 12Supplier Responsibility
A process to communicate the requirements of this policy to suppliers and to monitor supplier compliance with them.
