This SYMS Supplier Code of Conduct (“Code”) articulates SYMS Engineering Inc.’s (“SYMS”) expectations of the conduct of business partners and suppliers doing business with SYMS (“Suppliers”). SYMS expects suppliers to implement and adhere to their own written code of conduct, consistent with the expectations of this SYMS Supplier Code of Conduct, and to flow down these principles and similar expectations through their own supply chains they work with in providing products and/or services.

HUMAN RIGHTS AND LABOR STANDARD

SYMS expects Suppliers to have processes in place to prevent, mitigate, and take effective measures to remediate adverse human rights impacts and to create and sustain a working environment where its personnel is treated with dignity and respect. Suppliers should adhere to internationally recognized human rights and labor standards as defined in the principles of the United Nations Global Compact. Where local laws dictate any additional requirements, those shall be honored along with the requirements mentioned below. Suppliers should:
- Comply with all applicable laws, regulations and international standards related to labor practices and protection of human rights;
- Ensure equal treatment and refrain from discrimination of any form, including on grounds that are prohibited in national laws and international standards;
- Commit to a workplace free of harassment and abuse, and not use, or permit the use of, corporal punishment or other forms of mental or physical coercion, sexual harassment or abuse, nor execute threats of such treatment;
- Establish fair disciplinary, grievance, and termination procedures;
- Prohibit Child Labor and comply with minimum working age requirements prescribed by national laws and international conventions;
- Prohibit any form of forced or compulsory labor including, but not limited to, forced prison labor, indentured labor, bonded labor, slave labor or any form of human trafficking;
- Promote a safe environment, including zero tolerance for any unacceptable treatment of individuals such as mental cruelty, sexual harassment or discrimination including gestures, language, and physical contact, that is sexual, coercive, threatening, abusive or exploitative;
- Comply with appropriate working hour requirements including overtime, breaks, and rest periods as established by national law, relevant collective agreements and international standards;
- Recognize, as far as legally permitted, the right of free association and collective bargaining of employees;
- Ensure employment terms are clearly understood by their personnel and are explained verbally or provided in a written contract in a language they understand, as per local regulations and aligned to the provisions of this Code as a minimum;
- Adhere to relevant national laws, industry standards and international standards relating to minimum wages; overtime wages, and legally mandated benefits; and
- Ensure collection and processing of employees’ personal data are done in compliance with the applicable laws and subject to an adequate system to ensure appropriate protection against unauthorized or unlawful processing, loss, alteration, misuse, disclosure, or other transmission.

BUSINESS INTEGRITY

SYMS expects Suppliers to conduct their business by adopting the highest standards of ethical behavior. Suppliers should:

Comply with all applicable laws and regulations;
Adhere to applicable anti-corruption and anti-bribery laws, directives and regulations that govern operations in the countries in which they operate;
Prohibit and reject bribery or corruption in any form, including bribes, facilitation payments, kickbacks, grease payments and other improper influence of decision makers, whether directed to government officials or otherwise;
Adhere to anti-trust and other competition laws;
Ensure their financial books and records conform to generally accepted accounting principles and that business records are complete, legible, transparent and reflect actual transactions and payments;
Adhere to all applicable trade control laws and trade compliance regulations pertaining to business transactions with countries, companies and persons (sanctions), and the transfer of goods and services, software or technology between countries (export controls);
Perform due diligence on the source and chain of custody of materials in their supply chain and ensure that no prohibited materials are present or used in its products or supply chain;
Adhere to data privacy laws and comply to contractual requirements on confidentiality; and information security; and
Disclose any potential or actual conflict of interest to SYMS.

HEALTH AND SAFETY

SYMS expects Suppliers to provide a safe, secure and healthy working environment for all of their personnel that meet or exceed legal standards. Suppliers should:

Comply with applicable health, safety and environmental laws, regulations, and customer requirements;
Develop and implement effective occupational health, safety, and environmental management system, which includes regular employee training on such standards;
Ensure that safety management systems support identifying risks, measuring and monitoring performance, and driving continual improvements to mitigate or minimize health and safety risks emanating from their operations;
Ensure protection of their personnel by providing basic personal protective equipment appropriate to the nature of work and relevant training on health and safety systems;
Empower their personnel to report unsafe practices without fear of reprisal and to stop a job if it cannot be performed safely; and
Commit to proactively undertake safety initiatives to protect people and assets from harm and damage.

ENVIRONMENT

SYMS expects Suppliers to integrate environmental considerations in their operations and strive for continuous improvements to mitigate or minimize any adverse impacts on the environment. Suppliers should:

Continually strive to protect the communities and environment that surround them;
Comply with all relevant local, national, and international environmental laws and standards;
Adhere to all applicable local, national, and international air pollution control laws and standards;
Obtain and maintain all the necessary environmental permits, approvals and registrations;
Develop and implement effective environmental management systems that support identifying risks, measuring and monitoring performance, and driving continual improvements to mitigate or minimize environmental impacts emanating from their operations;
Define and implement metrics, set objectives, and provide regular progress updates on the results of their company’s activities that have the potential to impact the environment;
Develop a precautionary principle approach and promote environmentally friendly technologies and processes in their own operations and across the supply chain;
Commit to proactively undertake initiatives to protect the environment from harm and degradation in relation to their operations; and
Identify, label, store, and manage chemicals, waste, and other materials posing a hazard to human health or the environment and use safe handling, movement, storage, use, recycling or reuse, and disposal in compliance with local, national, and international laws.