Aim

Through this Corporate Social Responsibility (CSR) policy, the goal of this document is to educate all supplier of SCS Concept Group about the importance of business ethics and the company’s commitment to ensuring same. Compliance with this document is mandatory and exceptions are not permitted.

Scope

The policy and implementation specified in this document are addressed to:

  • All business partners of SCS Concept Group, in particular suppliers of products, parts, logistics and services.

Everyone must apply this policy and notify the group in case of any situation in which this policy would be not applied.

All business partners must be committed to ensuring that all its international activities are conducted in accordance with all applicable legal and regulatory requirements and the highest standards of ethical business conduct.

Ethics Policy

Working Conditions and human rights

The business partners must be committed to uncompromisingly comply with the legal requirements regarding working conditions at all times and thus to ensure the unrestricted protection of all their employees in the respective workplace.

Child labour and young workers

The business partners must be committed to uncompromisingly comply with the legal requirements regarding child labor and young workers at all times and thus to ensure the unrestricted protection of children and adolescents.

Wages and benefits

The business partners must be committed to uncompromisingly comply with the legal requirements regarding wages and benefits at all times and to secure a financially satisfactory income for their employees and partners in the long term.

 Working hours

The business partners must be committed to comply with all applicable local laws regulating working and resting hours and maximum consecutive days of work.

 Forced and compulsory labour and human trafficking

The business partners must be committed to take all possible measures at all times to combat forced and compulsory labor and human trafficking, and to fight the first signs without compromise.

Ethical recruiting

Recruitment is free from discrimination on factors not relating to job performance, such as gender, race, age and beliefs.  Workers should sign contracts and understand their terms of employment before starting work, or leaving their location of origin. Appropriate due diligence is performed on agents and third parties. Sites should aim to employ all workers on permanent contracts.

Women’s Rights and Gender Equality

The business partners must be committed to not discriminate in any way woman and any gender identity. All employees must have same rights and career opportunity.

Inclusion of any gender and ethnicity must be ensured.

 Diversity, Equity, and Inclusion

The business partners must be committed to ensure an equitable, diverse and inclusive workplace. This is applicable, but not limited, to our practices and policies on recruitment, compensation and benefits, professional development, training, promotions, transfers, terminations.

Rights of minorities and indigenous peoples

The business partners must be committed to not discriminate in any way woman and any minorities and indigenous people. All employees must have same rights and career opportunity.

Freedom of association and collective bargaining

The business partners must be committed to safeguarding freedom of association and bargaining rights of their employees at all times, so that management and employees can jointly develop and maintain the appropriate framework for long-term employment.

Non-discrimination and anti-harassment

The business partners must be committed to take all possible measures at any time against any discrimination (such as race, color, age, gender, sexual orientation, gender identity, ethnicity or national origin, disability, pregnancy, religion, political affiliation, union association, covered veteran status, genetic information or marital status) and to fight uncompromisingly even the first signs of it.

The business partners must be committed to provide a work place free of harassment against workers in any form.

 Corruption, extortion and bribery

The business partners must be committed to take all possible measures at any time to combat any corruption, extortion and bribery and to fight the first signs without compromise.

Financial responsibility (accurate records)

The business partners must be committed to meet their financial responsibility at all times and to comply with all legal requirements and general statutes of an international company regarding investment management and financial documents and records.

 Disclosure of information

The business partners must be committed at all times to responsibility to provide a legitimate and factually correct disclosure of information inside and outside of the company.

Fair competition and anti-trust

The business partners must be committed to live up to their responsibility for fair, free competition at all times, and to always promote the trust between their employees, suppliers, partners and customers.

Conflicts of interest

The business partners must be committed to avoiding conflicts of interest at all times in all hierarchical levels and areas of the SCS Group in order to be able to make neutral decisions and obtain objective product results.

 Counterfeit parts

The business partners must be committed to renounce counterfeit parts at any time in all developed and produced products and to run the risk of being confused with a competitor product, either consciously or unconsciously, towards customers. Plagiarism must not be allowed in the processes and products.

Intellectual property

The business partners must be committed to protecting the intellectual property of employees, partners and suppliers at all times and not unlawfully using them for own purposes.

Export controls and economic sanctions

The business partners must be committed to uncompromisingly comply with all legal requirements in relation to export controls and economic sanctions at all times, and to align business processes accordingly and to fight against them at an early stage.

Protection of identity and non-retaliation

The business partners must be committed to raising awareness at all times in relation to protection of identity and non-retaliation all employees and partners and to maintain the relevant ethical principles.

Whistleblowing and protection against retaliation

A whistle-blower is a person who passes on information about an individual’s and/or a company’s wrongdoing to the company, an individual, and/or a third party. The act of passing on that information is known as “blowing the whistle” or “making a disclosure.”

Grounds for whistleblowing normally fall into one of the following categories:

  • Criminal offences
  • Failure to comply with legal obligations
  • Miscarriages of justice
  • The endangering of someone’s health and safety
  • Damage to the environment
  • Covering up wrongdoing in one of those categories

The business partners employees must have the right to “blow the whistle” either where the company or an individual has demonstrated past or present wrongdoing or there are grounds to believe this will happen in the future.

The business partners must investigate all claims of wrongdoing vigorously and fairly and will seek to protect the whistle-blower, including the whistle-blower’s anonymity where appropriate.

Biodiversity, Land use and Deforestation

The business partners must be committed to protect biodiversity, to minimize land use for worldwide sites and prevent deforestation related to our activities.

 

Use of Private or Public Security Forces

The business partners must be committed to maintaining the highest ethical standards in our business operations, including the responsible utilization of public or private security forces. Our policy outlines our dedication to upholding human rights, promoting safety, and ensuring compliance with legal and ethical guidelines. The business partners must categorically reject the hiring or use of private or public security forces that engage in actions violating human rights. The business partners must not tolerate any form of torture, cruel, inhuman, or degrading treatment. The business partners must be committed to extends to preventing security forces from causing harm to individuals’ lives or physical well-being. Furthermore, The business partners must refuse to engage with security forces that interfere with the freedom of association and labor.

Health and Safety policy

The business partners have set ourselves the following objectives:

  • Meet all legal requirements regarding health, safety at work and the environment, in all operative countries 
  • Provide an injury-free and incident-free workplace
  • Prevent all work-related disabilities or health problems
  • Control and minimize the risks associated with products for their total life cycle and to choose production processes and products such that the use of raw materials and energy is minimized;
  • Evaluate and improve practices, processes and products continuously in order to make these safe and acceptable to employees, the customers, the public and the environment.

Handling of chemicals – The business partners must consider that handling, transporting, and using chemicals is a risk for the health and safety of personnel and it is important to reduce the hazards and the exposure of personnel to these. The business partner policy must define actions for seeking substitute chemicals for safer alternatives where possible and ensure measures are implemented to minimize exposure as far as possible. The latest Material Safety Data Sheets (MSDS) for all chemicals in use must be kept in accessible to all employees. The supplier MSDS information must be periodically checked to ensure that the latest versions are available. Training for risks, hazards and for safe use, wastes management should be handled.

Privacy policy

The business partners must be committed to respects the privacy of their employees and business partners. Individual’s right to data privacy must be protected. Everyone has the right to determine whether their personal information is disclosed and how it is processed. Use of personal information must be transparent.

Employees and business partners can decide if and how their personal data is used or processed, unless it is otherwise required by law or its use is necessary for a business process. Personal information must be only collected, processed, and used to the extent that applicable laws and internal policies permit.

Responsible sourcing of raw materials

Suppliers must take the following requirements in their policy and also with their sub-tiers suppliers:

Suppliers must adhere to the guidelines established by the Organization for Economic Co-operation and Development (OECD) when it comes to conflict minerals. It is imperative that suppliers take action to ensure that their smelters and refiners participate in the Responsible Mineral Assurance Program (RMAP) or a similar smelter validation program that aligns with the OECD Five Step Due Diligence guidelines (such as the Conflict-free Gold Program of London Bullion Market Association and Tungsten Industry-Conflict Mineral Council).

To meet our minimum requirements for Responsible Sourcing of Raw Materials, suppliers must implement the following:

  1. Establish a clear policy.
  2. Develop an management system.
  3. Identify and evaluate the risks in the raw material supply chain.
  4. Conduct supplier evaluation and/or supplier audits.

Suppliers must communicate a company policy for raw material sourcing that commits to conducting due diligence in sourcing raw materials from responsible sources. The policy should cover a broader range of raw materials than just the regulated “conflict minerals” (Tantalum, Tin, Tungsten, and Gold) based on their own raw materials risk assessment. 

Suppliers are responsible for ensuring that they and their sub-tier suppliers comply with all requirements. 

A good policy management system should comprise at least four key components:

• Accountability: Supplier representative(s) should be clearly identified to oversee the implementation of the management systems and associated programs, including regular senior management reviews of the system’s status.

• Documentation: A documented management system should be in place to ensure effective planning, operation, and control of raw material supply chain risks, as well as compliance with regulatory requirements and conformity to the policy minimum requirements.

• Supplier engagement: A supply chain policy that aligns with the SCS Concept requirements must be incorporated into contracts and/or agreements with suppliers.

Risk assessment:

Suppliers must establish a robust system to collect, examine, and verify traceability information of the raw materials. Suppliers must identify the location of extraction activities or recycling sources in the raw material supply chain.

To identify potential warning signs in the supply chain, suppliers should engage with their sub-tier suppliers. They should conduct a thorough risk assessment by reviewing pertinent information, publicly available policies and reports. The findings of the risk assessment should be reported to the designated senior management of the company.

If any risk arises, suppliers must inform SCS Concept and plan corrective actions to avoid the risk.

 

Environmental policy

INFRASTRUCTURES

  • Development and production sites should have a environmental management in system in place, possibly certified according to ISO 14001: settings targets for environmental continuous improvements

ENERGY and RESOURCES

  • Efficient use and conservation of natural resources and prevention of pollution must be considered
  • Renewable energy must be used as much as possible: for example installing solar panels on the plants. Energy suppliers must be monitored for the percentage of renewable energy provided.
  • Recover energy from the production processes must be also considered (for example, recovering heat from compressors).
  • Water is considered as a valuable natural resource, which will suffer shortages in several parts of the world. Because of this public interest and social importance SCS Concept Group focuses on efficient water use.
  • Keep water use as efficient as possible by preventing increase of specific water use and search for reduction opportunities in our processes.
  • Monitor and improve energy consumption (electrical and gas)
  • Monitor and improve greenhouse gas emission
  • Monitor and improve water consumption
  • Monitor and improve air quality and air pollution created by production processes
  • Monitor and improve natural resources usage

 DECARBONIZATION

  • A process for decarbonization should be consider. This must include the reduction or elimination of carbon dioxide from energy sources by using available technologies and methods (for example Environmental Product Declaration – EPD and Life Cycle Assessment – LCA)

REUSE and RECYCLING

  • Reuse and recycling must be taken into account during product development to improve the product life cycle.

WASTE and MATERIALS

  • Monitor and improve waste (especially plastic, hazardous materials and substances)
  • Chemical and hazardous substances must be used the less possible. When essential, they must be treated according to their material safety data sheets (MSDS), and employees must be trained about safe use and disposal.

BIODIVERSITY, LAND USE and DEFORESTATION

  • Suppliers must be committed to protect BIODIVERSITY, to minimize LAND USE for worldwide sites and prevent DEFORESTATION related to our activities.

ANINAL WELFARE

  • Supplier must be committed to ensure animal welfare in case of any activities involving animals.

SOIL QUALITY

  • Impact on soil of our activities must be assessed and action to prevent any possible impact of the soil quality must be taken.

NOISE and LIGHT EMISSIONS

  • Activities must be analyzed to reduce and minimize the effect on the environment, also taken in consideration the local applicable laws.

TRAINING

  • Each employee must be trained for environmental policy and environmental rules to be followed at the site (for example, waste disposal, environmental targets,..)

 SUPPLIERS

  • Suppliers evaluation must consider also their environmental policy and environmental impact
  • Most critical suppliers should be audited for environmental management

 

COMMUNICATION

  • Environmental policy must be communicated to suppliers
  • Environmental policy and targets must be available on the company portal

 

Policy Implementation

SCS Concept Group suppliers must implement the policy by the following management actions:

  • Sensibilization of employees
  • Systematic training of the employee
  • Provision of the policy to external interested parties
  • Define binding requirements towards tier-1 suppliers to pass on standards along the supply chain.
  • Communicate the requirements to your suppliers and verify that they have been received.
  • Verify that suppliers implement the necessary actions to satisfy them

Audit

SCS Concept group will perform periodical audits to suppliers to verify the policy implementation.

Corrective actions

In case of evidence of not correct implementation, the following actions must be taken:

  • Define the plan to correct the policy implementation
  • The results must be communicate to SCS Concept