Klinge Corporation
SUPPLIER CODE OF CONDUCT
Klinge’s Commitment
Klinge Corporation is committed to conducting business in an ethical and honest manner, and in a way that promotes corporate social and environmental responsibility, human rights, health, and safety. As part of the process, Klinge requires its suppliers, their employees, and agents to operate in accordance with the principles set forth in this Supplier Code of Conduct. The Klinge Supplier Code of Conduct outlines Klinge’s understanding of corporate responsibility as well as the standards that are to be met by our suppliers.
The Code establishes the expectations for each supplier related to labor standards, business practices, and health, quality, safety, and environmental practices.
We strive to work with suppliers whose business activities fully comply with the principles of the Klinge Supplier Code of Conduct.
Suppliers are asked to communicate the principles within their company and to their suppliers and subcontractors, and support the respective sustainability processes of Klinge.
Klinge reserves the right to evaluate the supplier’s compliance with Klinge’s Supplier Code of Conduct. If a violation of the Klinge Supplier Code of Conduct occurs, Klinge will support our suppliers in conducting corrective actions, if and when possible. In the event of a serious or repeated violation of the Supplier Code of Conduct, Klinge reserves the right to terminate any existing contracts with the supplier.
Klinge very much desires to work together with its suppliers to promote ethical business practices which look out for employees, customers, and the world in general. We are excited about our supply chain partnerships and look forward to continuing to grow and develop these partnerships for the improvement of our own company and the benefit of the global community in which we live and work.
Labor Standards
Labor and Applicable Law
Klinge does not tolerate child labor, forced labor or involuntary prison labor in the supply chain. Working hours for suppliers’ employees must comply with applicable national law and Suppliers are expected to provide their employees with fair compensation and benefits which comply with the respective national wage laws.
Freedom to Associate
Suppliers shall treat each worker with dignity and respect. In accordance with local laws, suppliers will respect the rights of their employees to associate freely and bargain collectively.
Harassment
Suppliers shall commit to a workplace free of harassment and abuse, and will not engage in, or threaten workers with, harsh or inhumane treatment, including sexual harassment, psychological harassment, sexual abuse, corporal punishment, mental or physical coercion or verbal abuse.
Discrimination
Suppliers must be committed to a workforce free of unlawful discrimination. Suppliers shall employ workers on the basis of their ability to do the job and shall not engage in discrimination against any worker on the basis of race, sexual orientation, gender identity, color, age, gender, maternity, national origin, disability, religion, ethnicity, marital status, political affiliation, or union membership, in hiring and other employment practices such as promotions, rewards and access to training.
Business Practices
Business and Applicable Law:
Klinge Suppliers shall conduct their business activities in full compliance with the applicable laws and regulations of all countries in which Suppliers are operating, and any other applicable laws. Suppliers shall ensure that products, services and shipments adhere to all applicable international trade compliance laws, rules and regulations.
Sanctions:
Klinge is committed to compliance with sanctions. “Sanctions” are legally enforceable economic sanctions, embargoes, or restrictive measures by competent authorities against jurisdictions or persons. Klinge expects that our suppliers are not a subject of any sanction, and that the supplier and its group companies comply in all respects with sanctions if, and to the extent that, sanctions are applicable to them.
Business Integrity:
Our suppliers are expected to operate within the national and international laws and regulations on corruption and money laundering. They are expected to avoid conflicts of interest that might lead to the risk of corruption. Bribery, extortion, and any other forms of unethical business practice are not accepted.
Suppliers shall conduct their business in full compliance with antitrust and fair competition laws that govern the jurisdictions in which they conduct business. Further, suppliers shall uphold standards of fair business, advertising and competition.
Confidentiality and Intellectual Property:
Klinge expects all suppliers to respect all contractual obligations, including obligations of confidentiality. This includes, but is not limited to, terms of agreements with Klinge and all information they may acquire in relation to the business of Klinge. Suppliers should safeguard Klinge’s confidential information and not use it for any purpose other than to perform obligations under the agreements or contracts with Klinge or to comply with the law.
Suppliers shall respect intellectual property rights and safeguard customer information. Transfer of technology and know-how is to be done in a manner that protects intellectual property rights and in accordance with the most stringent information protection requirements under applicable agreements. Suppliers shall implement processes as well as procedures and exercise due diligence to detect and avoid counterfeit parts and avoid violating others’ intellectual property rights.
Quality:
Klinge expects all suppliers to meet generally recognized and/or contractually agreed quality requirements. Product and service quality must meet Klinge’s needs as per the contract, perform as warranted, and be safe for the intended use.
Corrective Action Process:
Suppliers shall have a process for timely correction of any deficiencies or violations identified by an audit, assessment, inspection, investigation, or review.
Recognizing and Reporting Potential Non-Compliance:
Suppliers should provide adequate reporting procedures to allow employees to recognize and report potential non-compliances with the Code of Conduct.
Health, Quality, Safety, and Environment
Safe Work Environment:
Suppliers must be committed to the safety and health of their employees and shall provide and maintain a safe work environment by minimizing physical and chemical hazards through proper design, engineering and administrative controls, preventative maintenance, safe work procedures (including lockout/tag out) and ongoing safety training. Suppliers are responsible for assuring that all workers are qualified to perform their work functions safely. Suppliers shall provide workers with appropriate workplace health and safety training in their primary language and health and safety related information shall be clearly posted in the facility. Employees and visitors must be provided with safety equipment at the workplace, if applicable. All health and safety incidents should be monitored and analyzed.
Applicable Regulations:
Klinge expects all suppliers to abide by generally recognized, contractually agreed, and applicable regulations for the provided products and services. All required permits, licenses, certifications, and registrations must be obtained, maintained and kept up to date by the supplier.
Responsible Sourcing of Minerals:
Suppliers shall exercise due diligence, in accordance with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, on its entire supply chain with respect to the source and chain of custody of all “conflict minerals” (minerals which are smelted into tin, tantalum, tungsten, and gold) contained in products they supply or manufacture, to determine whether those metals are from the Democratic Republic of the Congo (“DRC”) or any adjoining country as defined in, and according to, Section 1502 of the Dodd-Frank Act; and, if so, to determine whether those metals directly or indirectly financed or benefited armed groups that are perpetrators of serious human rights abuses in the DRC, Angola, Burundi, Central African Republic, Rwanda, South Sudan, Tanzania, Uganda, Zambia or the Republic of the Congo.
Environmental Impact:
Klinge expects that suppliers protect the environment by preventing or minimizing the environmental impact of services and products; this covers the phases of development, manufacture, transport, use and disposal. Suppliers should have an appropriate environmental management policy in place and comply with all applicable environmental regulations.
Emissions and Waste:
Suppliers that are handling emissions and waste must have proper handling procedures in place to reduce these, to prevent accidental spills and releases into the environment, and have related emergency response programs in place.
Sustainability and Continuous Improvement:
Suppliers are expected to use natural resources (water, sources of energy, raw materials etc.) in a responsible manner and undertake their best efforts to reduce unnecessary consumption.