Alabama Specialty Products, Inc., (“ALSPI”) requires that all officers and employees of ALSPI, its subsidiaries and affiliates abide by the fundamental principles of ethical behavior listed here in performing their duties.
1. Compliance with Laws
ALSPI will always operate in full compliance with all applicable laws, rules, and regulations (collectively "Laws").
2. Labor
ALSPI upholds the human rights of workers and treats them with dignity and respect.
ALSPI only employs or engages workers who meet the applicable minimum legal age requirement in their country but in no event employs any person under the age of 16, even if local laws permit otherwise. Notwithstanding the preceding, ALSPI may allow individuals aged 15 or older to work as part of a bona fide apprentice program. Such apprentice programs must be approved under local laws and intended to provide instruction in one or more industrial disciplines as part of enrollment in an educational institution. ALSPI will not use or engage in any form of indentured or forced labor, slavery or servitude, human trafficking, or compulsory labor.
ALSPI sets working hours, wages, and overtime pay in compliance with all applicable laws. Workers are paid at least the minimum legal wage or a wage that meets local industry standards, whichever is greater.
ALSPI employs workers based on their ability to do the job and treats them with dignity and respect. ALSPI will not engage in or permit corporal punishment or threatened or actual violence to its workers.
ALSPI will not engage in any form of discrimination or harassment, whether based on gender, race, color, religion, ethnicity, social background, age, sexual orientation, national origin, disability, political conviction, or any additional legally protected characteristics.
ALSPI respects an employee's right to join or not join any lawful organization, including but not limited to trade unions and works councils, and it complies with all applicable laws regarding freedom of association and collective bargaining.
3. Health & Safety
ALSPI is committed to physically safeguarding its employees, officers, agents, and contractors ("Personnel").
ALSPI takes responsibility for the health and safety of its personnel and ensures a safe work environment that minimizes physical and chemical hazards through proper design, engineering, and administrative controls, preventative maintenance, and safe work procedures, as well as ongoing safety training.
Where hazards cannot be adequately prevented by other means, ALSPI provides workers with appropriate personal protective equipment.
ALSPI at all times provides and properly maintains physical guards, interlocks, and barriers where machinery presents a potential injury hazard to workers.
ALSPI minimizes the impact of emergencies through the implementation of emergency plans and response procedures with appropriate training that ensures its personnel are educated in regard to health and safety matters.
4. Environment
At ALSPI, environmental considerations are an integral part of our business practices.
ALSPI maintains all required environmental permits and registrations and follow the operational and reporting requirements of such permits.
ALSPI complies with regulated substance and product content specifications and applicable laws prohibiting or restricting the use, content, or handling of specific substances.
ALSPI minimizes environmental pollution and makes continuous improvements to reduce or eliminate solid waste, wastewater, and air emissions by implementing appropriate conservation measures in its production, maintenance, and facility processes.
ALSPI manages, controls, treats, and disposes of non-hazardous solid waste, wastewater, and air emissions generated from operations as required by applicable laws before discharge.
5. Ethics and Compliance
ALSPI conducts its affairs to the highest standards of ethical conduct when dealing with its personnel, suppliers, customers, and other relevant stakeholders.
ALSPI accurately records and discloses information regarding their business activities, structure, financial situation, and performance by following applicable laws and prevailing industry business practices.
ALSPI will not participate in and prohibits all forms of money laundering, fraud, extortion, theft, or embezzlement by its personnel.
ALSPI respects the intellectual property rights of its customers and others and safeguards related information in the transfer of technology that fully protects intellectual property rights in the same manner as though it was its own being safeguarded.
ALSPI implements processes and procedures and exercises due diligence to detect and avoid counterfeit parts.
ALSPI is committed to ensuring that the products it sells does not incorporate "conflict minerals" sourced from entities that directly or indirectly finance conflict in the Democratic Republic of Congo (DRC) and the Great Lakes Region (GLR) of Central Africa or adjoining countries. "Conflict minerals" are mined and smelted into tin, tantalum, tungsten, and gold, which are the extracts of the minerals cassiterite, columbite-tantalite, and wolframite, respectively. Downstream companies often refer to the extracts of these minerals as 3TG.
ALSPI performs sufficient due diligence into its supply chains to determine whether products sold or provided to ALSPI contain tin, tantalum, tungsten, or gold, and, if so, whether and to what extent those metals are sourced from conflict-free smelters to enable ALSPI to comply with its legal obligations and policy goals.
6. Anti-Corruption
ALSPI is committed to complying with all anti-corruption laws that prohibit bribes, kickbacks, or other corrupt actions to obtain or retain business or obtain any improper advantage.
No Bribes or Kickbacks. ALSPI will not directly or indirectly solicit, receive, or offer any form of bribe, kickback, or other corrupt payment, to or from any person or organization, including but not limited to its customers, government agencies or officials, companies, or personnel of those companies.
Gifts and Entertainment. When doing business with or conducting business on behalf of ALSPI, it may, for legitimate business purposes: offer gifts or entertainment to suppliers, customers, or other business associates; or accept gifts or entertainment offered by suppliers, customers, or other business associates; provided, however, that in each instance the gift or entertainment,
- is unsolicited,
- is not illegal or in violation of this Code,
- is not a bribe, kickback, or other illicit payment,
- is not given in exchange for any consideration,
- would not embarrass ALSPI if disclosed publicly, and
- does not create the appearance (or an actual or implied obligation) that ALSPI is entitled to preferential treatment, an award of business, better prices, or improved terms of sale.
7. Compliance Monitoring
ALSPI will allow customers, its representatives or agents access to ALSPI's facilities, and all relevant records associated with the products and services provided by ALSPI. Where needed, the customer and ALSPI will establish a mutually agreeable date and time for access. ALSPI reserves the right to hold a customer responsible for reasonable costs of investigating non-compliance with this Code.
8. Application
ALSPI contractually requires its customers or subcontractors to conform to standards of conduct equivalent to the provisions of this Code. ALSPI reserves the right to audit customer's or subcontractors for compliance with this Code
9. Breach
Should ALSPI be notified or come into knowledge that a customer is in breach of this Code a corrective action plan will be implemented within a specified time to cure all non-compliance. In case of a violation, ALSPI reserves the right to terminate the business relationship with the customer, including but not limited to suspending placement of future orders and potentially terminating current production.
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