November 1, 2022
Panduit is committed to conducting its business in an ethical manner, in compliance with all laws in all of the countries it operates as stated in Panduit’s Code of Conduct and Business Ethics. Panduit’s success is based on having business partners who share the same values and ethical standards. As a valued business partner to Panduit, we ask that you act in accordance with this Panduit Business Partner Code of Ethics.
Compliance with Applicable Laws. Partner complies with all applicable laws and regulations, as well as the principles set out in this Panduit Business Partner Code of Ethics. Panduit reserves the right to audit Partner’s compliance to this Code.
Anti-Competition. Partner does not engage in collusive bidding, price fixing, price discrimination and other unfair trade practices in violation of antitrust or competition laws and does not enter into formal or informal agreements that may limit competition.
Anti-Corruption. Partner complies with all applicable international anti-corruption laws and regulations. Partner prohibits its employees and other persons working on its behalf from promising, offering, authorizing, giving or accepting anything of value (including bribes, kickbacks, or any other improper payment), either directly or indirectly, to any Panduit employee, government official or other third party for the purpose of improperly influencing any business decision.
Business Courtesies. For purposes of this Business Partner Code of Ethics, “Business Courtesies” is defined as anything of value, including without limitation, business gifts, business entertainment, charitable donations, political donations, loans, and any benefits or favors that are given or received in the course of business. Panduit employees may not accept business gifts that exceed $100 in value per calendar year, and acceptance of business entertainment should be limited to no more than twice per year, except for modest meals for legitimate business purposes. Business Partners should make a good faith attempt to comply with these limits when providing Business Courtesies to Panduit employees. Per Panduit’s Gift and Entertainment policy, any business gifts given to Business Partners must not exceed $100 to any one individual in any given year, and giving business gifts of any value to Government Officials is prohibited. Further, Panduit employees are limited to spending no more than $250 per person per event for Business Entertainment when entertaining Business Partners such as distributors and/or end users. Lower limits and pre-approval is required when entertaining Government Officials. When working on Panduit’s behalf, Panduit expects Partner to abide by these guidelines and ensure that Partner does not offer any Business Courtesies in an effort to improperly influence the decisions of anyone. If a Business Courtesy is given, it is made in good faith without any improper intent and it is properly recorded in Partner’s books and records.
Export Control and Trade Compliance. Partner complies with international trade laws and regulations which restrict trade with and restrict export to certain countries, organizations, and individuals. Panduit Products are subject to US and local export control laws and regulations. Partner will not sell, lease, transfer, or re-export (nor enable any third party to do so) Panduit products to any individual or entity designated on a US restricted parties list (or to any entity that is owned or controlled 50% or more in the aggregate by an individual or entity on a US restricted parties list). Partner will not sell, lease, transfer, or re-export (nor enable any third party to do so) Products to a US embargoed country (i.e., Cuba, North Korea, Syria, Crimea) or to a country in violation of US sanctions.
Confidentiality/Intellectual Property. Partner protects confidential information and does not reveal such information to any other person or entity unless properly authorized and legal required to do so. Partner will take all appropriate precautions to safeguard confidential information and intellectual property rights of others. Partner is committed to using best efforts to ensure the Panduit parts it sells are genuine and not counterfeit.
Privacy. Partner complies with applicable privacy and information security laws when personal information is collected, stored, processed, transmitted, and shared.
Conflicts of Interest. Partner understands that business decisions should not be improperly influenced by personal interests or relationships. As such, Partner identifies and discloses any actual conflict of interest or the appearance of any conflict of interest.
Human Rights & Labor. Partner complies with all applicable labor laws, promote human rights wherever applicable, and provide fair and equitable wages. Partner will not engage in or permit threats of violence, harassment, discrimination, forced or child labor or human trafficking. Partner will comply with all applicable laws pertaining to freedom of association and collective bargaining.
Reporting Violations. Panduit encourages Partner to report suspected violations of law or this Panduit Business Partner Code of Ethics. Among other means, Partner may use the Panduit Integrity Line available at www.panduit.ethicspoint.com.