Eagle Elastomer Inc. – Supplier Code of Conduct

INTRODUCTION

At Eagle Elastomer Inc. we always seek to operate to the highest ethical standards. We call this “doing the right thing” and we apply this principle to everything that we do.

As a supplier to Eagle Elastomer Inc., you are integral to our success. We aim to develop and maintain relationships with our suppliers and in return expect our suppliers to also do the same. This means that in addition to providing the highest quality products or services, it is essential that you also operate your business in a way that supports our commitment to the highest ethical standards.

To help you understand what we expect of you in practice, we have prepared this Supplier Code of Conduct which applies globally to all suppliers to Eagle Elastomer Inc. We require that you and all our other suppliers comply with this policy, regardless of any conflicting local business practices or social customs.

If you have any questions about this Supplier Code of Conduct or about what is expected of you as an Eagle Elastomer supplier, please speak to your Eagle Elastomer contact.

What We Expect From You

As a supplier to Eagle Elastomer Inc., you will always:

ETHICAL STANDARDS

  • Maintain high standards of integrity, honesty, professionalism, and fairness.
    Not commit any act which may adversely impact Eagle Elastomer’s interests, reputation, or good standing.
  • Conduct your business in an open and ethical manner, with respect for human dignity and rights.
  • Always have high standards of social responsibility.
  • Respect the integrity of any information we provide to you and only use it for the purposes for which it is provided

BRIBERY & CORRUPTION

  • Comply with all applicable anti bribery and corruption legislation. You must never engage in in any practice which is, or might be perceived to be, corrupt or fraudulent.
  • Neither pay nor accept (nor tolerate anyone else paying or accepting) any bribes, kickbacks or other similar payments or inducements. This includes payments made to facilitate or speed up official or governmental procedures.

YOUR EMPLOYEES & WORKERS

  • Not use child labor or any form of forced, bonded or involuntary labor.
  • Comply with all applicable labor laws and regulations and internationally accepted standards of workers’ rights.
  • Within the laws, customs, and practices of the countries in which you operate, not unreasonably or unlawfully discriminate against any employee or worker, nor engage in actual or threatened physical abuse or discipline, sexual or other harassment, or verbal abuse or intimidation.
  • Comply with your obligations to your employees and workers relating to wages and benefits, working hours, freedom of association and collective bargaining.
  • Operate your business in a way which encourages your employees and workers to raise any concerns about ethical or legal conduct, without fear of retaliation.

OUR EMPLOYEES & WORKERS

  • Avoid engaging with Eagle Elastomer employees in a way which results in, or may be perceived to result in, an inappropriate conflict of interest for them. A conflict of interest can arise when the personal interests of an Eagle Elastomer employee are inconsistent with the responsibilities of his or her position.
  • Respect Eagle Elastomer’s position on gifts and hospitality. We prefer that you do not give our employees gifts or gratuities. Eagle Elastomer operates a corporate hospitality policy, and our employees may be required to decline gifts, gratuities or offers of hospitality which may be perceived as a bribe or inducement. Eagle Elastomer employees are never allowed to request gifts and under no circumstances should you feel obliged to offer gifts or gratuities to an Eagle Elastomer employee.

HEALTH & SAFETY

  • Comply with all applicable health and safety laws and regulations. Provide a safe, clean, and hygienic workplace for your employees and visitors (including Eagle Elastomer employees). Where your employees are at our facilities, ensure they operate and behave in an acceptable and safe manner, without presenting an undue risk to themselves, Eagle Elastomer’s employees or representatives, or others.
  • Properly identify and assess all hazards and risks associated with the use of your products or services and ensure that adequate safeguards and working practices are in place to reduce or eliminate them.

ENVIRONMENTAL COMPLIANCE & SUSTAINABILITY

  • Conduct your business in a way which safeguards the natural environment. You will comply with all applicable environmental laws and regulations, including those relating to regulated chemicals and substances, obtain and comply with all necessary environmental permits and properly dispose of all hazardous and regulated substances.
  • Proactively work to improve your environmental performance and operate in a more sustainable manner, including taking steps to improve energy efficiency; reducing water consumption; utilizing renewable energy; and reducing or eliminating greenhouse gas emissions, air and water pollution and waste.
  • Engage in sustainable and ethical sourcing practices, including only purchasing from ethically responsible sub-suppliers, sourcing raw materials from conflict-free regions, and conducting the due diligence necessary to ensure you meet these requirements.

LEGAL COMPLIANCE

  • Conduct your business in accordance with all laws and regulations of the countries in which you operate and to which you are subject, including those relating to data privacy and data protection.
  • Comply with all applicable trade compliance regimes such as export and import controls, embargoes, and sanctions.
  • Comply with all applicable anti-trust and competition laws. You must not fix prices or rig bids with your competitors, allocate customers or markets, or exchange current, recent, or future pricing information with or between them.

OBSERVING THIS CODE

  • Have appropriate policies and procedures in place to enable you to fully comply with this Code. These need not be identical to this Code, but as a minimum they must be consistent with its principles.
  • Provide Eagle Elastomer with any information we reasonably request to demonstrate your compliance with this Code and certify your compliance on request.
  • Inform Eagle Elastomer if you become aware of any actual or potential breach of this Code, whether by you or any other person or company.
  • Have appropriate terms and conditions in your supply contracts to cascade these requirements down your supply chain.
  • Allow Eagle Elastomer employees and third-party representatives to visit your premises and/or access your records and/or personnel on reasonable notice to audit and ensure compliance with the above requirements.

DOING THE RIGHT THING – WHAT WE EXPECT FROM OURSELVES…

We recognize that doing the right thing is a two-way process. Please tell us, if you ever believe that we may not be complying with our own policies.
  
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