This Code sets forth minimum requirements of any entity providing goods or services to Alabama Specialty Products, Inc. (hereafter referred to as "Supplier"). These requirements are consistent with Alabama Specialty Products, Inc. (ALSPI) values and apply to all Suppliers and their respective affiliates and subsidiaries globally.
1. Compliance with Laws
Suppliers shall always operate in full compliance with all applicable laws, rules, and regulations (collectively "Laws").
2. Labor
Suppliers shall uphold the human rights of workers and treat them with dignity and respect.
Suppliers shall only employ or engage workers who meet the applicable minimum legal age requirement in their country but in no event shall a Supplier employ any person under the age of 16, even if local laws permit otherwise. Notwithstanding the preceding, Suppliers 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. Suppliers shall not use or engage in any form of indentured or forced labor, slavery or servitude, human trafficking, or compulsory labor.
Suppliers shall set working hours, wages, and overtime pay in compliance with all applicable laws. Workers shall be paid at least the minimum legal wage or a wage that meets local industry standards, whichever is greater.
Suppliers shall employ workers based on their ability to do the job and treat them with dignity and respect. They shall not engage in or permit corporal punishment or threatened or actual violence.
Suppliers shall 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.
Suppliers shall respect an employee's right to join or not join any lawful organization, including but not limited to trade unions and works councils, and shall comply with all applicable laws about freedom of association and collective bargaining.
3. Health & Safety
ALSPI is committed to physically safeguarding its employees, officers, agents, and contractors ("Personnel").
Suppliers shall take responsibility for the health and safety of their personnel and ensure a safe work environment and minimize 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, suppliers shall provide workers with appropriate personal protective equipment.
Suppliers shall provide and properly maintain physical guards, interlocks, and barriers where machinery presents a potential injury hazard to workers.
Suppliers shall minimize the impact of emergencies through the implementation of emergency plans and response procedures with appropriate training that ensures their personnel are educated in regards to health and safety matters.
4. Environment
At ALSPI, environmental considerations are an integral part of our business practices.
Suppliers shall maintain all required environmental permits and registrations and follow the operational and reporting requirements of such permits.
Suppliers shall comply with regulated substance and product content specifications and any applicable laws prohibiting or restricting the use, content, or handling of specific substances. Suppliers shall provide ALSPI any information relative to the preceding, including, but not limited to, "Material Declarations," as applicable.
Suppliers shall minimize environmental pollution and make continuous improvements to reduce or eliminate solid waste, wastewater, and air emissions by implementing appropriate conservation measures in their production, maintenance, and facility processes.
Supplier shall manage, control, treat and dispose of non-hazardous solid waste, wastewater, and air emissions generated from operations as required by applicable laws before discharge.
5. Ethics and Compliance
Suppliers shall conduct their affairs to the highest standards of ethical conduct when dealing with their personnel, suppliers, customers, and other relevant stakeholders.
Suppliers shall accurately record and disclose information regarding their business activities, structure, financial situation, and performance following applicable laws and prevailing industry business practices.
Suppliers shall not participate in and shall prohibit all forms of money laundering, fraud, extortion, theft, or embezzlement by its personnel.
Suppliers shall respect ALSPI intellectual property rights and safeguard related information. Suppliers shall use such safeguards as required in the transfer of technology and related information that fully protects ALSPI's intellectual property rights in the same manner as though it were their own intellectual property being safeguarded.
Suppliers shall implement processes and procedures and exercise due diligence to detect and avoid counterfeit parts.
ALSPI is committed to ensuring that the products it sells do 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.
Suppliers shall perform sufficient due diligence into Supplier's 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. Suppliers shall report to ALSPI the results of such due diligence 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. Suppliers shall 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 ALSPI, government agencies or officials, companies, or personnel of those companies.
Gifts and Entertainment. When doing business with or conducting business on behalf of ALSPI, Suppliers 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 the gift giver is entitled to preferential treatment, an award of business, better prices, or improved terms of sale.
7. Compliance Monitoring
The Supplier shall allow ALSPI or any of its representatives or agents access to Supplier's facilities and all relevant records associated with the products and services provided to ALSPI. Where needed, Supplier and ALSPI shall establish a mutually agreeable date and time for access. However, risks to ALSPI's business may require immediate access to the products, services, and associated records. Suppliers shall accommodate ALSPI's reasonable need for access in such times where expediency is needed. The Supplier agrees to cooperate with ALSPI to investigate any allegations of wrongdoing, misconduct, or corruption. ALSPI reserves the right to hold a Supplier responsible for reasonable costs of investigating non-compliance with this Code.
8. Application
Suppliers shall contractually require their suppliers or subcontractors to conform to standards of conduct equivalent to the provisions of this Code. ALSPI reserves the right to audit Supplier's suppliers or subcontractors for compliance with this Code, and Supplier shall accommodate ALSPI's audit as required. Supplier shall also ensure that its personnel comply with this Code when providing goods or services to ALSPI.
9. Breach
Suppliers shall promptly report to ALSPI notice of a known breach of this Code and furnish in writing a corrective action plan 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 Supplier, including but not limited to suspending placement of future orders and potentially terminating current production. |
