This Supplier Code of Conduct (“Code”) defines the minimum standards of practice the Interplex Group of Companies (“Interplex”) requires from our current and future suppliers and their employees, personnel, agents, and subcontractors (collectively referred to as “Suppliers”) to adhere to when providing any products or services to Interplex.
We also expect our Suppliers to replicate these standards further down the supply chain and ensure that their extended supply chain are not in breach of the principles contained in this Code.
Whilst our Suppliers are expected to self-monitor and demonstrate their compliance with this Code, our Suppliers may also be required to complete a self-assessment questionnaire, provide proof of statements made and demonstrate that this Code is adhered to. Interplex also reserves the right to audit our Suppliers or inspect their facilities to verify compliance with this Code. We expect our Suppliers to respond in full and be open and honest in response to any requests for information and to complete an agreed corrective action plan until a satisfactory level of improvement is reached should any breaches or shortcomings regarding the Code be identified.
Compliance with our Code is an important component of our Supplier selection and evaluation. Suppliers that behave in a manner that is unlawful or inconsistent with our Code, risk suspension or termination of their business relationship with Interplex. Interplex may also disclose to the appropriate authorities if there is a violation of law.
Interplex may, at appropriate intervals, review the applicability of this Code and make revisions when deemed necessary. Substantive changes to the Code will be communicated to Suppliers.
Our Expectations of Suppliers to Interplex
GOVERNANCE AND ETHICS
- Compliance with Laws. Suppliers shall comply with all local and national laws and regulations pertinent to their operations regarding all products and services they provide to Interplex including but not limited to antitrust, trade controls, and sanction regimes. Where the provision of law and this Code address the same topic, Suppliers are encouraged to follow the requirements that promote higher standards.
- Business Integrity. Suppliers shall prohibit all types of bribery, corruption, extortion and money laundering and shall implement procedures for their employees to comply with applicable anti-bribery and anti-corruption laws (including but not limited to the Singapore Prevention of Corruption Act, the U.K. Bribery Act and the U.S. Foreign Corrupt Practices Act).
- Financial Responsibility/Accurate Records. Suppliers shall accurately reflect on Supplier’s business books and records all business dealings. Falsification of records or misrepresentation of conditions or practices in the supply chain are unacceptable.
- Conflict of Interest. Suppliers shall avoid all conflicts of interest or situations giving the appearance of a potential conflict of interest in Suppliers’ dealings with Interplex.
- Intellectual Property. Suppliers shall ensure all intellectual property rights are respected.
- Privacy. Suppliers shall protect the reasonable privacy expectations of personal information of everyone they do business with, including suppliers, customers, consumers and employees. Suppliers are to comply with privacy and information security laws and regulatory requirements when personal information is collected, stored, processed, transmitted and shared.
- Confidential/Proprietary Information. Suppliers shall take proper care to protect all sensitive information, including confidential and proprietary information. Information should not be used for any purposes beyond the scope of the business arrangement with Interplex, without prior authorization.
- Responsible Sourcing of Minerals. Suppliers shall ensure that where conflict minerals (tantalum, tin, tungsten and gold) are used in their products, such minerals are not purchased from conflict sources that directly or indirectly finance or benefit armed groups in the Democratic Republic of Congo or adjoining countries. Please refer to http://conflictfreesmelter.org for more details. Suppliers shall exercise due diligence on the source and chain of custody of these minerals and make their due diligence measures available to Interplex upon request.
- Risk Assessment and Risk Management. Suppliers shall actively manage performance and risk and proactively bring anything of concern to our notice in a timely manner.
LABOR AND HUMAN RIGHTS
- Modern Slavery. Suppliers shall prevent all forms of modern slavery from taking place in their operations, including forced or bonded labor, involuntary labor, slavery or human trafficking.
- Child Labor. Suppliers shall ensure that child labor is not used in any stage of Suppliers’ operations. Child labor, as defined by the International Labor Organization refers to work that is mentally, physically, socially or morally harmful to children; or work that interferes with their schooling.
- Diversity and Inclusion. Suppliers shall provide equal employment opportunity to employees and applicants for employment without regard to race, gender, ethnicity, religion, sexual orientation, gender identity or expression, mental or physical disability (so long as the essential functions of the job can be performed with or without reasonable accommodation) and/or any other characteristic protected by applicable local law. Suppliers shall commit to a workforce free of harassment and unlawful discrimination.
- Working Hours, Wages and Benefits. Suppliers shall comply with working hours set by the applicable local laws. Suppliers shall also comply with all applicable wage laws, including those relating to minimum wages, overtime hours and legally mandated benefits.
WORKPLACE HEALTH, SAFETY AND QUALITY
- Quality Requirements. Suppliers shall meet generally recognized or contractually agreed quality requirements in order to provide products and services that consistently meet Interplex’s needs, perform as warranted and are safe for their intended use.
- Product Safety. Suppliers shall make available to Interplex and other parties, when requested, material safety data sheets containing all necessary safety-relevant information for all hazardous substances.
- Health, Safety, Environmental and Quality Regulations. Suppliers shall comply with all applicable quality, health, safety and environmental regulations. Supplier shall obtain and maintain all required permits, licenses and registrations and shall make available such documentation when requested. Suppliers shall fulfill their operational and reporting requirements.
- Occupational Health and Safety. Suppliers shall implement health and safety prevention and remediation policies and procedures which comply with industry, national and international standards. Where hazards cannot be adequately controlled by these means, Suppliers shall provide employees with appropriate, well-maintained, personal protective equipment and education materials about risks to them associated with these hazards. Health and safety related information shall be clearly posted in the facility or placed in a location identifiable and accessible by workers. Workers shall be encouraged to raise safety concerns.
- Process Safety. Suppliers shall implement safety programs to manage and maintain all their production processes in accordance with applicable safety standards.
- Environmental Permits and Reporting. Suppliers shall obtain and maintain all required environmental permits, licenses, information registrations and restrictions that are applicable to their operations and ensure that their operational and reporting requirements are followed.
- Waste and Emissions. Suppliers shall have systems in place to ensure the safe handling, movement, storage, recycling, reuse and management of waste, air emissions and wastewater discharges. Any waste, wastewater or emissions with the potential to adversely impact human or environmental health shall be appropriately managed, controlled and treated prior to release into the environment.
Effective Date: 1 October 2019