Supplier Integrity Guide

Supplier Integrity Guide - strives to perform with integrity and high standards of business conduct in everything we do, especially in our dealings with suppliers, contractors, agents and consultants (collectively “Suppliers”). bases its Supplier relationships on lawful, ethical, reasonable, efficient and fair practices, and Suppliers shall adhere to applicable legal and regulatory requirements in their business relationships as set out in this Integrity Guide for Suppliers (the “Guide”) in connection with their activities with 

Suppliers are responsible to ensure that they and their employees, workers, agent representatives, suppliers and subcontractors comply with the standards of conduct set out in this Guide and in other contractual obligations to Please contact the manager with whom you work or Compliance Resource if you have any questions about this Guide or the standards of business conduct that all Suppliers shall meet. 

Supplier Expectations

You, as a Supplier to, agree: 

Fair Employment Practices: To (i) observe applicable laws and regulations governing wages and hours, recruitment and employment contracts and working conditions; (ii) prohibit discrimination, harassment and retaliation; (iii) not utilize fraudulent or misleading recruitment practices; (iv) not hold or destroy a worker’s identity or immigration documents; and (v) provide workers with terms and conditions of employment in a language the worker understands. 

Health, Safety & Environment: (i) To comply with applicable environmental, health and safety (“HSE”) laws and regulations (ii) to provide workers a safe and healthy workplace; and (iii) not to adversely affect the local community. 

Human Rights: (i) To respect human rights of your employees and others in your business operations and your activities for; (ii) not to employ workers younger than sixteen (16) years of age or below the applicable minimum age, whichever is higher; (iii) not to use forced, prison or indentured labor, or workers subject to any form of physical, sexual or psychological compulsion, exploitation or coercion, or to engage in or abet trafficking in persons; (iv) to adopt policies and establish systems to procure raw materials from sources that have been verified as conflict free.

Working with Governments, Improper Payments and Dealings with

Employees and Agent Representatives: (i) To maintain and enforce a policy requiring adherence to lawful business practices, including a prohibition against bribery of government officials, (ii) not to offer or provide, directly or indirectly, anything of value, including cash, bribes, gifts, entertainment or kickbacks, including offers of employment, or participation in a contest, game or promotion, to any employee, representative or customer or to any government official in connection with any procurement, transaction or business dealing, and (iii) to provide supporting data to when requested. 

Competition Law: Not to share or exchange any price, cost or other competitive information or engage in any collusive conduct with any third party with respect to any proposed, pending or current procurement. 

Intellectual Property: Respect the intellectual and other property rights of and of third parties, including all domestic and foreign patents, trademarks and copyrights. 

Information Security and Data Privacy: (i) Respect privacy rights and secure the data of employees, customers, and suppliers (collectively, “ Data”); (ii) Implement and maintain physical, organizational and technical measures to ensure the security and confidentiality of Data in order to prevent accidental, unauthorized or unlawful destruction, alteration, modification or loss of Data, misuse of Data, or unlawful processing of Data; and (iii) Protect Supplier operations and facilities against exploitation by criminal or terrorist individuals and organizations. 

Trade Controls & Customs Matters: (i) Not to transfer technical information to any third party without the express, written permission of; (ii) Comply with all applicable trade control laws and regulations in the import, export, re-export or transfer of goods, services, software, technology or technical data including any restrictions on access or use by unauthorized persons or entities; and (iii) Be cognizant of US Antiboycott laws, regulations and guidelines and not to take any action or inaction that could expose to liability or penalties under U.S. Anti-boycott laws. 

Management Accountability and Responsibility: To adopt or establish a management system that (i) is consistent with this Guide and applicable laws and regulations; (ii) includes processes to identify and control HSE, business ethics, labor, human rights and legal compliance risks associated with your operations; and (iii) requires periodic self-assessments of your operations and/or audits of your supply chain to ensure compliance with this Guide. 

Controllership: To ensure that all invoices and any customs or similar documentation submitted to or governmental authorities or audited by third parties in connection with transactions involving accurately describe the goods and services provided or delivered and the price thereof and ensure that all documents, communications and accounting are accurate and honest, to the best of one’s ability.

How to Raise a Question or Concern 

Subject to local laws and any legal restrictions applicable to such reporting, each Supplier is expected to inform promptly of any concern related to this Guide affecting, whether or not the concern involves the Supplier, as soon as the Supplier has knowledge of such an occurrence. Suppliers also must take such steps as may reasonably request to assist in the investigation of any such occurrence involving and the Supplier. If Supplier’s work is related to a U.S. government contract, Supplier must notify of any alleged non-conformance with this Supplier Integrity Guide. 

Define your question/concern: Who or what is the concern? When did it arise? What are the relevant facts? 

Prompt reporting is crucial — a question or concern may be raised by a Supplier as follows: • By discussing with a cognizant Manager; or By calling the Integrity Helpline: 800-886-4926; or By emailing, Policy forbids retaliation against any person reporting such a concern.