INTERPLEX
SUPPLIER CODE OF CONDUCT
This Supplier Code of Conduct (“Code”) defines the minimum standards Interplex Group of Companies (“Interplex”) require our suppliers to uphold when providing products and/or services to Interplex.
We also expect our suppliers to implement these standards within their own supply chains, and to ensure that none of their downstream partners are in breach of the principles outlined 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.
Requirements for Suppliers
Our requirements for Suppliers are set out in the standards below.
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 sanctions 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, the U.S. Foreign Corrupt Practices Act, and the People’s Republic of China Criminal Law and Anti-Unfair Competition Law).
- 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 Conflict-Affected and High-Risk Areas. Please refer to Conflict-Affected and High-Risk Areas (CAHRAs) (responsiblemineralsinitiative.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.
Human Rights and Working Conditions
- Modern Slavery and Forced Labor: 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.
- Freedom of Association and Right to Collective Bargaining: Suppliers shall respect employees’ rights to freedom of association and to enter into collective bargaining as permitted by local laws. Any workers exercising such right shall not be subject to any form of reprisal, harassment, or discrimination. The use of security forces to impede freedom of association is prohibited. Suppliers are encouraged to facilitate open dialogue among employees, representatives, and management to address workplace conflicts and grievances constructively.
- Whistleblowing and Grievance Mechanisms: We encourage our suppliers to provide channels for employees to report concerns and grievances. ‘Concerns’ refer to unethical business practices or serious wrongdoing, while ‘grievances’ are complaints about certain aspects of employment and working conditions. Suppliers must ensure the confidentiality of and non-retaliation against employees who report genuine concerns and grievances to ensure effectiveness. Issues should be handled within a reasonable timeframe.
- Land, Forest and Water Rights and Forced Eviction: Suppliers shall respect the rights of indigenous people and local communities to land, forest and water, in alignment with the UN Declaration on the Rights of Indigenous Peoples. Suppliers shall not contribute to forced eviction, as well as the destruction of land, forests, and water bodies. Suppliers shall safeguard the entitlement of indigenous people and local communities to natural resources essential to their livelihoods and prevent the social and environmental impact caused by its operations towards local communities.
- Private or Public Security Forces: Suppliers must commit to zero tolerance for violence, including prohibiting the use of security forces to control employees’ movements, restrict their workplace freedoms, conduct illegal body searches, and engaging in torture or cruel, inhuman, or degrading treatment of employees or local communities.
- 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 fulfil their operational and reporting requirements.
- Occupational Health and Safety: Suppliers shall implement health and safety prevention and remediation policies and procedures that 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.
Environment
- 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.
- Energy Efficiency: Suppliers are expected to seek ways to optimize and minimize energy use to improve overall efficiency throughout their business operations. This includes adopting energy-efficient equipment and retiring older equipment that consumes excessive energy.
- Renewable Energy Use: Suppliers are expected to prioritize adopting renewable energy sources such as solar, wind, hydroelectric, and biomass in their business operations. Suppliers already using renewable energy sources are encouraged to increase their proportion by expanding capacity and investing in renewable energy infrastructure.
- Greenhouse Gas (GHG) Emissions: Suppliers are expected to monitor greenhouse gas (GHG) emissions, particularly Scope 1 and Scope 2 emissions, throughout their operations. They shall establish reduction targets for all scopes and implement sustainable practices to decrease overall greenhouse gas (GHG) emissions in their operations.
- Decarbonization: Suppliers are expected to establish a time-bound action plan to transition to a low-carbon business model and commit to achieving a net-zero target by 2050 or earlier. They shall reduce reliance on fossil fuels and transition to sustainable energy sources. Interplex expects suppliers to implement decarbonisation strategies, including increasing energy efficiency, adopting renewable energy sources, implementing carbon capture and storage technologies, and utilizing waste heat recovery systems.
- Waste: Suppliers shall have adequate systems in place to ensure the safe handling, movement, storage, recycling, reuse, and management of waste. Any waste with the potential to adversely impact human or environmental health shall be appropriately controlled and treated on-site through a treatment system or disposed properly by qualified third parties. Suppliers shall also reduce waste generation by reuse and recycling, and minimize, even eradicate, the use of single-use materials.
- Responsible Chemical Management: Suppliers shall ensure that chemicals with the potential to adversely impact human or environmental health are appropriately managed, controlled and treated prior to release into the environment. In addition, suppliers shall establish and implement procedures for handling, storing and transporting chemical substances, including without limitation, the provision of appropriate protective gear and specific training to employees responsible for managing chemicals in order to ensure their safety.
- Air Emissions and Noise Pollution: Suppliers shall actively minimize noise pollution arising from their processes and reduce the release of air pollutants, such as dust, particles, Volatile Organic Compounds (VOC) and heavy metals, into the surrounding environment. Suppliers shall conduct periodic air quality and noise monitoring to uphold high standards of air quality and noise levels within operational sites.
- Sustainable Resource Management: Suppliers shall make conscious effort in sourcing, selecting and consuming sustainable resources, in line with their commitments to other environmental aspects.
- Biodiversity, Land Use and Deforestation: Suppliers shall safeguard the natural environment and associated ecosystems by preserving biodiversity, engaging in responsible land use practices, and preventing deforestation. We expect our suppliers to protect natural ecosystems and refrain from contributing to their alteration, deforestation, or degradation. Where relevant, suppliers should adhere to the guidelines outlined by the High Conservation Value Resource Network (HCV) and the High Carbon Stock Approach (HCSA).
- Soil Quality: We expect our suppliers to prevent any detrimental alterations to soil quality, including soil contamination resulting from their operations. Suppliers shall ensure proper waste and water management to prevent indiscriminate discharge, thereby mitigating the risk of soil pollution.
- Animal Welfare: We expect suppliers who are engaged in processing animal products to adhere to industry standards and best practices for ensuring animal welfare throughout the supply chain. Suppliers are encouraged to prioritize non-animal testing methods whenever possible, except where legally mandated. At minimum, suppliers must comply with national and international regulations concerning animal protection and testing.
Effective date: 25 October 2023.
Last updated on: 28 May 2024