Aim

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

Company policy and Business ethics code of conduct

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 thier employees and partners in the long term.

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

Freedom of association and collective bargaining

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

Non-discrimination

The business partners must be committed to take all possible measures at any time against any discrimination as in terms of gender, origin, color, religion, and to fight uncompromisingly even the first signs of it.

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 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.

Health and Safety policy

The business partners have set ourselves the following objectives:

  • 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.

Environmental policy

The business partners must be committed to monitor and improve the environmental aspects:

  • Development and production sites must be analyzed from the environmental prospective
  • Efficient use and conservation of natural resources and the prevention of pollution must be considered.
  • 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 there must be a focus on efficient water use.
  • Keep water use as efficient as possible by preventing increase of specific water use and search for reduction opportunities in the processes.
  • Monitor and improve energy consumption (electrical and gas)
  • Monitor and improve greenhouse gas emission
  • Monitor and improve all type of waste  
  • Monitor and improve water consumption
  • Monitor and improve air quality and air pollution created by production processes
  • Monitor and improve natural resources usage
  • 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.
  • Environmental policy and objectives must be available for the employees.
  • Environmental policy should be communicated to business partners
  • Each employee must be trained for environmental policy and environmental rules.

Sustainable resources management

Business partners must consider evaluate procurement of raw materials. Raw materials should come, when possible, from recycled sources. Materials where wastes can be directly recycled during manufacture and at end of life should be used.

Business partners are requested to meet their due diligence obligations along the supply chain. This includes the implementation of measures that ensure that the minerals used by suppliers – particularly tin, tantalum, tungsten, gold and cobalt – do not contribute to the direct or indirect support of armed conflicts or are in connection with violations of human rights.

Policy Implementation

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

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