Table of Contents
I. Introduction
II. Sapona Core Values
III. Labor and Human Rights
A. Providing Opportunity for All
B. Human Rights
1. Freely Chosen Employment
2. Child Labor
3. Working Hours
4. Wages and Benefits
5. Human Treatment
6. Non-Discrimination
7. Freedom of Association
8. Environmental Impact on Local People
9. Unlawful Eviction of Land
10. Prohibition of Violent Security Forces
IV. Health and Safety
A. Making Workplace Safety and Security a Priority
1. Occupational Safety
2. Emergency Preparedness
3. Occupational Injury and Illness Reporting and Investigation
4. Industrial Hygiene
5. Physically Demanding Work
6. Machine Safeguarding
7. Dormitory and Canteen
B. Substance-Free Workplace for The Well-Being of Employees and Visitors
V. Environmental Concerns
1. Environmental Permits and Reporting
2. Pollution Prevention and Resources Reduction
3. Hazardous Substances
4. Wastewater and Solid Waste
5. Air Emissions
6. No Unauthorized Discharges or Disposals
7. Energy Consumption and Greenhouse Gas Emissions
8. Product Content Restrictions
VI. Ethics
VII. Responsibility and Compliant Business Practices
A. Export/Import Controls
B. Supply Chain Security
C. Supply Chain Mapping
VIII. Proprietary and Confidential Information
IX. E-Mail, The Internet, and The Use of Company Property
X. Management Systems
1. Company Commitment
2. Management Accountability and Responsibility
3. Legal and Customer Requirements
4. Risk Assessment and Risk Management
5. Performance Objectives with Implementation Plan and Measures
6. Training
7. Communication
8. Worker Feedback and Participation
9. Audits and Assessments
10. Corrective Action Process
11. Documentation and Records
XI. Record-Keeping and Financial Controls
A. The Information by Which We are Measured
B. Communicating Accurate, Timely Information
XII. Supplier Concerns
A. Reporting a Concern
B. Sapona Corporate Office
I. Introduction
Welcome to the SAPONA Guide to Supplier Social Responsibility (“Guide”). In this document, we clarify the values and principles under which SAPONA operates as they relate to our operations, our suppliers, and our business partners. Our goal is for our suppliers to embrace and comply with these same important values, principles, and guidelines. At a minimum, Sapona suppliers must operate in full compliance with the applicable laws, rules, regulations, codes, and ethical standards of the countries, states, and localities in which they operate or where they provide services, products, or people to or for Sapona. This includes, but is not limited to, laws and regulations relating to environmental, occupational health and safety, ethics, and labor practices. This Guide is meant to provide our suppliers with an understanding of SAPONA’s expectations for business conduct, decision-making, and business interaction. It outlines key principles and behaviors, based on our core values, and emphasizes the principles and behaviors that we require of our suppliers. We require our suppliers to embrace these principles and behaviors and to adhere to the principles of this Guide and their own respective code of conduct (applicable to their employees, external business associates, customers, and suppliers). SAPONA also reserves the right to audit our suppliers on issues of Social Responsibility.
This Guide applies to all suppliers of SAPONA globally, which includes all integrated suppliers, temporary personnel, and third-party consultants. The values, principles, and guidelines stated in this Guide are demonstrated by SAPONA in its day-to-day business operations.
SAPONA’s Core Values are at the center of our Supplier Social Responsibility Program (“SSR Program”), which we seek to promote throughout our supply chain. Our SSR Program is based on international standards of human rights, sustainability, and social responsibility.
SAPONA believes that building a great company requires a deep understanding of the needs of our customers, our markets, and their commitments to social responsibility.
II. SAPONA’s Core Values
SAPONA’s commitment to the highest standards begins with ensuring that everyone across the SAPONA organization and our supply chain understands and demonstrates our Core Values and adheres to our social responsibility platform. Core Values are the concepts that define how we conduct ourselves as SAPONA employees and decision-makers at the individual, team, and company levels. We believe it is critical that our suppliers understand, share, and apply our Core Values in their own operations and business interactions. The following Core Values are the foundation of SAPONA operations and, as such, are also the foundation for our SAPONA Guide to Supplier Social Responsibility.
Honesty & Integrity
We must demand of ourselves, our partners, and each other the highest standards of ethics and integrity. We are dedicated to diversity, fair treatment, mutual respect, and trust.
Leadership & Teamwork
We foster an environment that encourages winning through creativity, excellence, and collaboration. We practice leadership that inspires and promotes full participation and career development. We expect transparent communications and interaction.
Innovation & Ingenuity
We recognize that innovation for our customers is the foundation of our business, and we stay continually customer focused. We challenge ourselves to develop new and improved ideas for our customers and in all that we do. We encourage, expect and value creativity, thoughtful risk-taking, openness to change and diverse perspectives.
III. Labor and Human Rights
A. Providing Opportunity for All
SAPONA extends equal opportunity and fair treatment to all its employees. SAPONA specifically prohibits discrimination on various dimensions, including, but not limited to, gender, age, race, ethnicity, orientation, physical or mental abilities, nationality, religion, veteran status, background, culture, and experience, or any other characteristic protected by law. SAPONA is committed to providing a culture that values diversity and teamwork with a conscious desire to achieve understanding, respect, inclusion, and continuous learning. We expect that all employees will treat one another with respect and dignity.
We extend these same principles to the relationships throughout our supply chain with our suppliers and customers. One of the included principles is the promotion and encouragement of Supplier Diversity within our supply base. Supplier Diversity is a business strategy that ensures a diverse supplier base in the procurement of goods and services in any business. It emphasizes the creation of a diverse supply chain that works to secure the inclusion of diverse groups in its procurement plans.
B. Human Rights
SAPONA is a good corporate citizen and strives to comply with all other applicable civil rights, human rights, environmental and labor laws in every company location. We require our suppliers to do the same. We require SAPONA business units and suppliers to provide clean and safe working environments and conditions for employees, forbid child labor and all forms of forced labor at our facilities or at the facilities of our supplier subcontractors and require that employees receive all benefits mandated by applicable laws. Regardless of location, SAPONA prohibits our business units or supplier associates from engaging in activities that do not maintain individual dignity and respect, even if permissible under applicable law. Our core values show commitment to being good global citizens and acting in a socially responsible manner in the communities where we live and work. SAPONA condemns any act or omission which is capable of impairing labor and human rights and expects its suppliers to respect the rights outlined in the Guide.
SAPONA supports the following specific Labor and Human Rights principles at SAPONA and for our suppliers:
1. Freely Chosen Employment
All employment will be voluntary, and workers should be free to leave upon reasonable notice. Workers shall not be required to surrender government-issued identification, passports or work permits as a condition of employment, except for the purpose of legal status verification, in which case the documents must be promptly returned to the worker. All forms of forced labor and slavery by our suppliers are forbidden. The use of forced, bonded (including debt bondage), indentured labor, involuntary or exploitive prison labor, any of which may be identified by indications such as labor obtained under the threat of punishment, withholding identity papers, requiring workers to deposit a bond or any other constraint, whether directly or indirectly is strictly prohibited. This includes transporting, harboring, recruiting, transferring, or receiving persons by means of threat, force, coercion, abduction, or fraud for labor or services. Compliance is mandatory, and materials may not be sourced from regions prohibited by US or International Law. Suppliers must ensure their supply chain does not utilize forced labor or child labor in the manufacturing of their raw materials or finished products.
2. Child Labor
Child labor is not to be used in any stage of manufacturing. The term “child” refers to any person employed under the age of 15 (or 14 where the law of the country permits), or under the age for completing compulsory education, or under the minimum age for employment in the country, whichever is greatest. The use of legitimate workplace apprenticeship programs, which comply with all laws and regulations, is supported. Workers under the age of 18 should not perform hazardous work and may be restricted from night work with consideration given to educational needs.
3. Working Hours
Studies of business practices clearly link worker strain to reduced productivity, increased turnover and increased injury and illness. Work weeks should not exceed the maximum allowable hours set by local law.
4. Wages and Benefits
Compensation paid to workers shall comply with all appropriate wage laws, including those relating to minimum wages, and legally mandated benefits. In compliance with local laws, workers shall be compensated for overtime at pay rates greater than regular hourly rates. The basis on which workers are being paid is to be provided in a timely manner via pay stub or similar documentation.
5. Humane Treatment
There is to be no harsh and inhumane treatment, including any sexual harassment, sexual abuse, corporal punishment, mental or physical coercion, or verbal abuse of workers, nor is there to be the threat of any such treatment.
6. Non-Discrimination
Our suppliers must be committed to a workforce free of harassment and unlawful discrimination. Suppliers shall not engage in discrimination based on various dimensions, including, but not limited to, gender, age, race, ethnicity, orientation, physical or mental abilities, nationality, social status, religion, veteran status, background, culture, and experience in hiring and employment practices such as promotions, rewards, and access to training. In addition, workers or potential workers should not be subjected to medical tests that could be used in a discriminatory way as a condition of employment.
7. Freedom of Association
Open communication and direct engagement between workers and management are the most effective ways to resolve workplace and compensation issues. Our suppliers must respect the rights of workers to associate freely and bargain collectively, to join or not join labor unions, to seek representation, and to join workers’ councils in accordance with local laws. Workers shall be able to communicate openly with management regarding working conditions without fear of reprisal, intimidation, or harassment.
8. Environmental Impact on Local People
Our suppliers must ensure that local people are not impaired by its business activity, e.g., through harmful soil contamination, water pollution, air pollution, harmful noise emission or excessive water consumption which impact the natural resource basis for the preservation and production of food, access to safe drinking water and sanitary facilities.
9. Unlawful Eviction of Land
Our suppliers must respect the rights of residents, people and communities affected by its business activities and will not unlawfully evict or deprive people of their homes, lands, and water.
10. Prohibition of Violent Security Forces
Hiring or using violent private or public security forces is prohibited. Suppliers must not use any security forces for the protection of their entrepreneurial activities if the security forces torture people or treat them in a cruel, inhumane, or degrading way, using excessive force leading to injuries of life or body or if they impair the freedom of assembly and association.
IV. Health and Safety
A. Making Workplace Safety and Security a Priority
Having a safe workplace is one of the most important benefits we offer to our employees. We are committed to providing a safe working environment for all employees. We do this by following strict safety and security rules and practices, which we also require our suppliers to follow, including the ones listed below:
• Identifying workplace hazards and implementing effective controls to reduce, or eliminate where possible, risks of injury and illness.
• Requiring employees to take an active role in working safely by adhering to safety procedures.
• Prohibiting the possession of weapons and other dangerous devices by employees, contractors, suppliers, and visitors on the company’s, customers’, or suppliers’ property, including parking lots and company-owned vehicles.
While compliance with all applicable laws, regulations, and record-keeping requirements is mandatory, SAPONA seeks to exceed the minimum legal standards. SAPONA supports the following Health and Safety principles and practices internally and by our suppliers:
1. Occupational Safety
Worker exposure to potential safety hazards (e.g., electrical, and other energy sources, chemical, machine, fire, vehicle, and fall hazards) is to be controlled through proper design, engineering and administrative controls, preventative maintenance, and safe work procedures (including lockout/tag out). Where hazards cannot be adequately controlled by these means, workers are to be provided with appropriate personal protective equipment. Workers shall not be disciplined for raising safety concerns.
2. Emergency Preparedness
Emergency situations and events are to be identified and assessed, and their impact minimized by implementing emergency plans and response procedures, including, emergency reporting, employee notification and evacuation procedures, worker training and drills, appropriate fire detection and suppression equipment, adequate exit facilities and recovery plans.
3. Occupational Injury and Illness Reporting and Investigation
Procedures and systems are to be in place to manage, track and report occupational injury and illness. Incidents of injury and illness must be fully investigated to determine the true root cause(s) and corrective actions that will be effective in preventing recurrence must be implemented.
4. Industrial Hygiene
Worker exposure to chemical, biological, and physical agents is to be identified, evaluated, and controlled. When hazards cannot be adequately controlled by engineering and administrative means, workers are to be provided with appropriate personal protective equipment.
5. Physically Demanding Work
Worker exposure to physically demanding tasks, including manual material handling and heavy lifting, prolonged standing and highly repetitive or forceful assembly tasks is to be identified, evaluated, and controlled.
6. Machine Safeguarding
Physical guards, interlocks, and barriers are to be provided and properly maintained for machinery used by workers. Regular employee training and machine inspections must occur to ensure safeguarding protections remain in place and are effective.
7. Dormitory and Canteen
Workers are to be provided with clean toilet facilities, access to potable water and sanitary food preparation and storage facilities. Worker dormitories provided by suppliers, or a labor agent, are to be clean, safe, and provide emergency egress, adequate heat and ventilation and reasonable personal space.
B. Substance-Free Workplace for The Well-Being of Employees and Visitors
Substance abuse, whether alcohol or drug abuse, poses a serious threat to the safety, health, and productivity of our organization, employees, and customers. SAPONA has a substance-free workplace policy that extends to all locations, and applies to our employees, suppliers, customers, and visitors.
Our substance-free workplace policy prohibits:
• Using, selling, or possessing illegal drugs or other controlled substances in the workplace. Possession of prescription medication for personal medical treatment in accordance with a physician’s orders is permitted.
• Using or possessing alcohol in the workplace.
• Being under the influence of alcohol, illegal drugs, or any other controlled substance on the job.
Our suppliers must adopt policies comparable to the above for their own locations.
V. Environmental Concerns
Environmental responsibility is critical to being a world-class organization and producing world-class products. SAPONA supports the following environmental principles internally and for our suppliers:
1. Environmental Permits and Reporting
All required environmental permits (e.g., discharge monitoring) and registrations (including, but not limited to, general, air, water, and waste) are to be obtained, maintained, and kept current and their operational, monitoring and reporting requirements are to be followed.
2. Pollution Prevention and Resources Reduction
Waste of all types, including water and energy, is to be reduced or eliminated at the source or by practices such as modifying production, maintenance and facility processes, materials substitution, conservation, recycling and re-using materials.
3. Hazardous Substances
Chemicals and other materials posing a hazard if released to the environment are to be identified and managed to ensure their safe handling, movement, storage, recycling or reuse and disposal.
4. Wastewater and Solid Waste
Wastewater, e-waste, and solid waste generated from operations, industrial processes and sanitation facilities are to be monitored, controlled, and treated as required prior to discharge or disposal.
5. Air Emissions
Air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting chemicals and combustion by-products generated from operations are to be characterized, monitored, controlled, and treated as required prior to discharge.
6. No Unauthorized Discharges or Disposals
Suppliers shall not directly or indirectly dispose of liquid or solid waste onto or into the ground, into any body of water or into a wastewater disposal system except in compliance with a permit or other express regulatory authorization.
7. Energy Consumption and Greenhouse Gas Emissions
SAPONA recognizes its social responsibility to protect the environment. We expect suppliers to share our commitment by responding to changes posed by climate change and working toward protecting the environment. Supplier disclosure is a first step in understanding our suppliers’ maturity on our carbon reduction journey to net zero and to help us better manage the environmental footprint of our supply chain while encouraging suppliers on their own journey toward a low-carbon economy. As part of this commitment, suppliers are to establish greenhouse gas (“GHG”) data for all products and related services supplied to SAPONA upon request. Energy consumption and all relevant Scope 1 and 2 greenhouse gas emissions (using the GHG protocol) are to be tracked and documented. Where such tracking is not currently available suppliers should establish plans to implement the collection of data and tracking required to calculate GHG emissions. Suppliers are to look for methods to improve energy efficiency and to minimize their energy consumption and GHG emissions.
8. Product Content Restrictions
SAPONA suppliers must adhere to all applicable laws and regulations regarding prohibition or restriction of specific substances including labeling laws and regulations for recycling and disposal. Suppliers must also adhere to all regulations concerning radioactive substances in metals. Promptly upon request from SAPONA, the supplier shall provide the composition of their products to support statement of compliance and provide verifications detailing their ongoing testing and auditing of supply base to ensure compliance with all regulations and customer-specific requirements.
VI. Ethics
Suppliers shall conduct their business in accordance with the highest standard of ethical behavior and in accordance with applicable laws and regulations. Suppliers are expected to conform to the requirements in the below areas.
1. Business Integrity, Anti-bribery, and Anti-corruption
Supplier shall uphold the highest standards of integrity in all business interactions. Suppliers shall have a zero-tolerance policy to prohibit all forms of bribery, corruption, extortion, and embezzlement. Bribes or other means of obtaining undue or improper advantage shall not be promised, offered, authorized, given, or accepted. No funds or assets of the supplier shall be paid, loaned, or otherwise disbursed as bribes, "kickbacks", or other payments designed to influence or compromise the conduct of Sapona, its employees or representatives. Suppliers must comply with applicable anti-bribery and anti-corruption laws including but not limited to the United States (U.S.) Foreign Corrupt Practices Act and must have adequate policies and procedures in place to enforce and monitor compliance with such laws.
2. Conflict of Interest
Suppliers must avoid actual, potential, or perceived conflicts of interest with Sapona employees. If these occur, the supplier must disclose such a conflict, so that appropriate steps are taken to manage the situation.
3. Disclosure of Information
All business dealings should be transparently performed and accurately reflected in the supplier’s business books and records. Falsification of records or misrepresentation of conditions or practices in the supply chain are unacceptable.
Intellectual Property. Suppliers shall respect the intellectual property rights of others, including
Sapona, its affiliates and business partners. Suppliers must take appropriate steps to safeguard and maintain confidential and proprietary information of Sapona and shall use such information only for the purposes specified for use by Sapona. Suppliers shall observe and respect all Sapona patents, trademarks and copyrights and comply with all requirements as to their use as established by Sapona. Suppliers shall not transmit confidential or proprietary information of Sapona via the internet without an established security set up.
Fair Business, Advertising, and Competition. Suppliers shall conduct their business in full compliance with anti-trust and fair competition laws, and disclose information regarding business activities, structure, financial situation, and performance in accordance with applicable laws. Standards of fair business, advertising and competition shall be upheld.
Protection of Identity and Non-Retaliation. Supplier shall implement and maintain programs that ensure the confidentiality, anonymity and protection of supplier and employee whistleblowers. Supplier should have a communicated process for their personnel to be able to raise any concerns without fear of retaliation.
Privacy. Supplier shall commit to protecting the reasonable privacy expectations of personal information of everyone they do business with, including suppliers, customers, consumers, and employees. Supplier shall comply with privacy and information security laws and regulatory requirements when personal information is collected, stored, processed, transmitted, and shared.
Responsible Sourcing of Minerals. Suppliers are expected to have a policy and exercise due diligence to reasonably assure that the tin, tantalum, tungsten, and gold in the products they manufacture does not directly or indirectly finance or benefit armed groups that are perpetrators of serious human rights abuses in the Democratic Republic of the Congo or an adjoining country. Suppliers shall provide information to Sapona upon request.
VII. Responsibility and Compliant Business Practices
A. Export/Import Controls
Growing our global business in a complex world of regulations
Most countries, including the United States, have export/import control laws in place to protect strategically necessary goods (these include, but are not limited to, production materials, finished goods, capital equipment, molds and tooling, samples, and prototypes, repaired or returned products), software, services, and technologies (including technical information for use, development, and production of relevant products). SAPONA complies with applicable U.S. and other national laws, regulations, and restrictions worldwide.
It is important to understand that the export, re-export, or in-country transfer of goods, software, and technical information may be subject to multiple jurisdictions. U.S. export control laws, particularly have extraterritorial reach to transactions outside of the U.S. and goods, software, or technology manufactured outside the U.S.
As our supplier, you are required to implement appropriate import and export policies and procedures to ensure compliance with all applicable trade laws. Failure to do so could result in potential violation of applicable laws and agreements with SAPONA and other customers. Further, non-compliance activities could expose SAPONA, along with our customers and other suppliers, to liability and increased scrutiny from government agencies and associated negative publicity. SAPONA’s due diligence in our supply chain is intended to protect SAPONA’s and our customers’ ability to conduct business on a global basis.
To ensure compliance with applicable laws, SAPONA requires suppliers to implement proper import and export controls, including but not limited to the following controls in particular:
• Obtaining proper export and import authorization.
• Disclosing or transferring technical data to foreign nationals either in the U.S. or abroad.
• Establishing eligibility of export/import recipients.
• Executing, controlling, and delivering required documentation.
• Retaining records for the above.
To ensure business continuity and meet compliance requirements, SAPONA may request evidence of compliance with applicable export or import requirements, and Supplier shall provide such evidence within a reasonable time frame.
B. Supply Chain Security
Suppliers must also comply with the Minimum Security Criteria of the U.S. Bureau of Customs and Border Protection’s Customs-Trade Partnership Against Terrorism (C-TPAT) program and/or other applicable global supply chain security programs, to the extent that these criteria are relevant for supplier’s operations. Further information about the C-TPAT program may be found on the U.S. Customs website at: http://www.cbp.gov.
To ensure business continuity and meet compliance requirements, SAPONA may request evidence of applicable global supply chain security programs, and Supplier shall provide such evidence within a reasonable time frame.
C. Supply Chain Mapping
Due to increasing business continuity, sustainability, and compliance requirements, SAPONA requires its suppliers to conduct and support necessary supply chain mapping initiatives, including but not limited to efforts sufficient to meet 'clear and convincing' documentation standards.
Supplier shall be required to provide clear and convincing evidence that demonstrates (i) the identity and location of supplier’s subcontractors and suppliers and (ii) the origin of its products and any component and raw materials in its products (collectively “Supply Chain Mapping Evidence”). Supply Chain Mapping Evidence must meet the standards set by the United States Department of Homeland Security. Supply Chain Mapping Evidence may be requested by SAPONA in the following two (2) situations:
1) As part of a supply chain mapping audit, supplier shall, promptly, following a request from SAPONA, provide to SAPONA or to a related third-party the Supply Chain Mapping Evidence; or
2) If United States Customs and Border Protection (“CBP”) detains supplier products or SAPONA products which contain supplier products at the United States border and SAPONA must provide Supply Chain Mapping Evidence to CBP, Supplier has seventy-two (72) hours following a request from SAPONA to provide the Supply Chain Mapping Evidence to SAPONA and/or CBP. Supplier will also reimburse SAPONA for any holding, transfer, or additional fees that SAPONA incurs related to Supplier products being detained at the United States border under this Section 1(B) (“Detention Costs”). Additionally, in case a SAPONA product is being detained at the United States border under this Section (B) and it can be verified that the underlying reason for such detention is the supplier product, supplier will reimburse SAPONA for any incurred Detention Costs related to such supplier product.
Supply Chain Mapping Evidence may include, but is not limited to, the following:
1) Detailed description of the supply chain for supplier products and components, including all stages of mining, production, or manufacture, including any step of the sourcing, manufacturing, or processing of goods in countries outside of the United States.
2) Records that indicate the provenance of each component of supplier products.
3) Any additional information requested by CBP or SAPONA.
VIII. Proprietary and Confidential Information
Protecting the Company’s Knowledge
SAPONA’s Proprietary and Confidential Information (defined as business and technical information that is not generally or publicly known by others) is very valuable because it provides SAPONA, and our supply chain, with a competitive market advantage.
SAPONA suppliers must protect and respect SAPONA’s Proprietary and Confidential Information by maintaining strict confidentiality of information provided to them by SAPONA, or to which they are circumstantially exposed as part of their business interactions with SAPONA, and by not sharing that information outside of their company or inside their company with those who do not need to know about it as part of their jobs. Such information is the sole property of SAPONA. Examples of Proprietary and Confidential Information include, but are not limited to:
• SAPONA or Sapona customer specifications and drawings such as engineering/production specifications and drawings for potential new products as well as non-public specifications and drawings for current products.
• SAPONA technical information such as trade secrets, invention disclosures, un-filed or non-published patent applications, and any other non-public technical information.
• Agreements between SAPONA and its suppliers, agents, strategic partners and/or other third parties.
• SAPONA company financial information including all non-public sales information.
• SAPONA proprietary software or company-owned software modifications, templates, worksheets, or other programs.
• SAPONA financial, business, technical and other information about potential acquisitions and/or divestitures.
• SAPONA business information such as plant layouts, financial forecasts, organizational charts, organizational announcements, staffing changes, business updates or product news and product roadmaps that are not publicly available.
• SAPONA customer lists and agreements, market share data, supplier agreements, purchase order data to suppliers, and other similar confidential information.
IX. E-Mail, The Internet, and The Use of Company Property
Limiting Use to Business Purposes
All communications data and information sent or received using SAPONA equipment or assets are SAPONA property and are not private communications. SAPONA owns and/or controls access to all communications equipment, including computers, telephones, software, e-mail, instant messaging, text messaging, voice mail, conferencing equipment, company cell phones, handheld devices, and office supplies. SAPONA reserves the right to monitor all communications, including internet usage, to the extent permissible by law.
SAPONA’s tangible property, including but not limited to, its buildings, parking lots, vehicles, equipment, production scrap materials and supplies, exists to enable employees to perform their business-related duties, including interacting and transacting business with our supplier base. SAPONA’s intangible property, including but not limited to, know-how, processes, and intellectual property such as patents and copyrights. The use of company property (tangible or intangible) is for the sole purpose of conducting business-related tasks.
This policy extends to our suppliers in the use of such communications devices as listed above and including all communications methods with SAPONA, such as e-mail, the internet, or any SAPONA-owned software or SAPONA-owned property that our suppliers use, for example:
• Communications between SAPONA and our suppliers via e-mail and internet, as well as any other forms of communication, must not violate this Guide or any other SAPONA policy, particularly the sections related to conflicts of interest and/or disclosure of SAPONA confidential information.
• Communications between SAPONA and our suppliers must never include forwarding of chain letters, mass e-mails for non-business purposes, or selling items or services for personal gain.
• Communications between SAPONA and our suppliers must never contain pornographic or offensive material, discriminatory or harassing language or derogatory references to age, disability, ethnicity, marital or family status, national origin, color, religion, sex, sexual orientation, veteran status, or any other characteristic protected by law.
X. Management Systems
At SAPONA supply chain sustainability is an evolving vision, which means that it is critical to have an approach that defines and incentivizes continuous improvement. This approach at SAPONA includes both the remediation of instances of non-compliance as well as investment in suppliers’ management capabilities.
Remediation can include several activities:
• SAPONA and suppliers working together to create a corrective action plan for achieving compliance in a clearly defined and reasonable time frame.
• Encouragement and support for improvement through regular communications with non- compliant suppliers.
• Defining a roadmap for gradually increasing standards and expectations.
• Termination of a supplier relationship when serious compliance issues are not remedied despite repeated notifications.
SAPONA’s supplier selection includes consideration of a supplier’s performance in these areas:
• SAPONA recommends that suppliers begin their own sustainability journey. As an important step in that journey, SAPONA encourages suppliers to undertake initiatives to promote greater environmental responsibility, make long term plans and initiatives and create specific implementation plans for a long-term sustainability program.
• SAPONA suppliers shall adopt or establish a management system designed to track: (a) compliance with applicable laws, regulations, and customer (including SAPONA) requirements related to the supplier’s operations and products; (b) conformance with the principles stated in this document; and (c) identification and mitigation of operational risks. The management system embraced by suppliers must also facilitate continual improvement.
The management system as implemented by our suppliers should contain the following elements:
1. Company Commitment
Corporate social and environmental responsibility statements affirm commitment to compliance and continual improvement.
2. Management Accountability and Responsibility
Clearly identified company representatives/employees responsible for tracking implementation and conducting periodic review of the status of the management systems.
3. Legal and Customer Requirements
Identification, monitoring, and understanding of applicable laws, regulations, and customer requirements.
4. Risk Assessment and Risk Management
A process to identify the environmental, health and safety and labor practice risks associated with company operations. Determination of the relative significance for each risk and implementation of appropriate procedural and physical controls to ensure regulatory compliance to control the identified risks. Areas to be included in a risk assessment for health and safety are warehouse and storage facilities, plant/facilities support equipment, laboratories and test areas, sanitation facilities/ bathrooms, kitchen/cafeteria, and worker housing /dormitories.
5. Performance Objectives with Implementation Plan and Measures
Written standards, performance objectives, targets and implementation plans including a periodic assessment of company performance against those standards, objectives, and plans.
6. Training
Programs for training managers and workers to implement policies, procedures, and improvement objectives.
7. Communication
Process for communicating clear and accurate information about SAPONA performance, practices, and expectations to workers, suppliers, and customers.
8. Worker Feedback and Participation
Ongoing processes to assess employees’ understanding of and obtain feedback on practices and conditions covered by this Guide and to foster continuous improvement.
9. Audits and Assessments
Periodic self-evaluations to ensure conformity to legal and regulatory requirements, the principles and guidelines outlined in this Guide, and contractual requirements related to social and environmental responsibility.
10. Corrective Action Process
Process for timely correction of deficiencies identified by internal or external assessments, inspections, investigations, and reviews.
11. Documentation and Records
Creation of documents and records to ensure regulatory compliance and conformity to SAPONA requirements along with appropriate confidentiality to protect privacy.
XI. Record-Keeping and Financial Controls
A. The Information by Which We are Measured:
Accurate, timely, complete financial records provide the key information necessary to manage our business. These records and financial controls are essential to fulfilling obligations to shareholders, governments, and the public at large. We require our suppliers to follow appropriate procedures and commitment to financial responsibility including creating and retaining adequate records. In general, our suppliers must:
• Have effective internal financial controls, including procedures to protect assets.
• Comply with all applicable laws and supplier’s own records retention policies so that all necessary archival records can be accessed.
B. Communicating Accurate, Timely Information
In all interactions and communications – between SAPONA and our suppliers, customers, distributors, governmental agencies, or others inside or outside of the company -- SAPONA employees are expected to be truthful and forthright, and we require the same of our external suppliers. This includes:
• Making accurate statements without misrepresentation, omissions or statements intended to mislead or misinform.
• Responding promptly, accurately and with full disclosure to requests from governmental agencies for information or documents
XII. Supplier Concerns
As a SAPONA supplier, your role includes understanding SAPONA’s values and principles, including all regulations that apply equally to your company and its interaction with SAPONA. Our core values of Integrity, Honesty, Teamwork, Leadership, Ingenuity, and Innovation are so important to us that we believe it is the responsibility of every one of us to speak up if we become aware of any situation that violates these values.
A. Reporting a Concern
We encourage our employees, as well as suppliers, investors, customers, and other third parties, to promptly report any concerns of potential violation of laws, regulations, and SAPONA policies. We enforce a strict policy prohibiting retaliation for reporting a concern or suspected misconduct in good faith.
To report your concern, please choose one of the following options:
Website: www.saponaplastics.com via our website contact form
B. SAPONA Office Of Ombudsman
All reports of potential violations are taken seriously and appropriately reviewed and handled by the SAPONA Board of Directors. The SAPONA Board of Directors operates independently from the business functions and ensures that all reported concerns are investigated and resolved timely, confidentially, and appropriately at the proper level. The CEO reports to the Sapona Board of Directors any concerns for review.
C. Supplier Acknowledgement
We have received and read the Sapona Plastics Supplier Code of Conduct.
We agree to comply with the requirements detailed in the Code.
We will cascade the Code requirements down our entire supply chain as relating to Sapona.
We will report any case of violation of the Code to Sapona.