Panduit Supplier Code of Conduct

Effective Date: March 24, 2021

Panduit Supplier Code of Conduct

Panduit Corp., its affiliates and subsidiaries (collectively, “Panduit”) is committed to conducting its business in a safe, ethical and socially responsible manner, in compliance with all laws in the countries it operates.  Panduit expects its suppliers to share this commitment.  As such, Panduit requires all persons and entities who sell goods, raw materials, or services of any type to Panduit (each a “Supplier”) to act in accordance with this Supplier Code of Conduct which is based on internationally recognized standards on Labor, Health & Safety, the Environment, and Ethics.  Supplier shall implement appropriate corporate policies and management systems to ensure its compliance with this Supplier Code of Conduct, and to ensure its sub-tier suppliers and subcontractors also comply with this Supplier Code of Conduct.

Compliance with Applicable Laws

Supplier shall comply with all applicable laws and regulations, as well as the principles set out in this Supplier Code of Conduct. The specific areas of compliance highlighted for attention in this document shall not be considered fully definitive. The obligations set forth in this Supplier Code of Conduct are in addition to any other of Supplier’s obligations set forth in any other agreement between the parties or Panduit policy.

Human Rights & Labor

Supplier shall uphold the human rights of workers.  In particular, Supplier must comply with the following standards:

• Freely Chosen Employment. Supplier shall not use or participate in forced labor, slave labor or human trafficking.

• Child Labor. Supplier shall comply with all local minimum working age laws.

• Wages. Supplier shall comply with all applicable wage laws, including those relating to minimum wage, overtime and legally mandated benefits.

• Working Hours. Supplier shall ensure that work weeks do not exceed the maximum set by applicable law.  Workers should be allowed at least one day off every seven days and be given reasonable breaks during work hours.

• Humane Treatment. Supplier shall treat workers with dignity and respect, and not threaten or use physical, sexual, psychological, or verbal abuse.

• Non-Discrimination.  Supplier shall be committed to a workforce free of harassment and unlawful discrimination. Supplier must treat its workers in a fair and non-discriminatory manner, with the guarantee of equal opportunity and the absence of any policy or practice aimed at, or indirectly resulting in, discrimination toward those workers on any basis whatsoever, including, but not limited to, race, color, gender, sexual orientation, social and personal position, health condition, disability, age, nationality, religion or personal belief (in accordance with applicable laws).

• Freedom of Association. Supplier shall respect the rights of its workers to collectively bargain in accordance with applicable labor laws without interference, discrimination, retaliation or harassment.  

• Reporting and No Retaliation. Suppliers shall provide their employees with appropriate means to raise concerns of unethical or illegal activity, without any fear of retaliation. Supplier shall have a strict no retaliation policy and process in place to prevent any retaliation against any person who brings forth a good faith concern.

Health & Safety

Supplier shall provide its employees with a safe and healthy working environment, and where applicable, living environment, in accordance with applicable law and industry best practices.  In particular, Supplier must comply with the following standards:

• Occupational Safety.  Supplier shall control worker exposure to potential safety hazards through design engineering and administrative controls, preventative maintenance and safe work procedures, ongoing training, and protective equipment.

• Emergency Preparation.  Supplier shall take steps to mitigate risk to life, the environment and property caused by emergency situations by identifying and assessing potential risks and implementing appropriate emergency plans and response procedures.

• Occupational Injury and Illness.  Supplier shall implement procedures and systems to prevent, manage, track and report occupational injury and illness.

• Sanitary Conditions.  Supplier’s workers shall have ready access to clean toilet facilities, potable water and sanitary food preparation, storage and eating facilities.  If worker dormitories are provided, such facilities must be clean and safe, and provided with appropriate emergency egress, hot water for bathing and showering, adequate heat and ventilation, and reasonable personal space along with reasonable entry and exit privileges.

Environment

Supplier shall minimize the adverse environmental impacts of their activities, including striving to reduce waste, energy, emissions and pollution to the air, ground and water.  Supplier shall: (1) handle chemicals in an environmentally safe way; (2) handle, store and dispose of hazardous waste in a safe manner; and (3) contribute to the recycling and reuse of materials and products and implement environmentally friendly technologies.  It is recommended that Supplier has an Environmental Management System in conformity with international standards such as ISO 14001.

Facility Security

Supplier shall maintain security at all production and warehousing facilities and will implement supply chain security procedures designed to prevent the introduction of non-manifested cargo into outbound shipments.  Suppliers shall implement agricultural controls to prevent the export of invasive species outside their natural environment.  Supplier’s policies and processes shall satisfy the requirements of the U.S. Customs Trade Partnership Against Terrorism (“C-TPAT”) program or similar guidelines set forth by applicable foreign customs agencies such as Authorized Economic Operator (AEO). 

Ethics

Supplier shall conduct business in an ethical manner and in compliance with all applicable laws and regulations in the countries it conducts business.  In particular, Supplier must comply with the following standards:

• Improper Payments. Supplier shall not promise, offer, authorize, give, or accept 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, to gain an improper advantage when conducting business with Panduit or third parties.  Panduit’s does permit Panduit employees to accept certain legitimate business courtesies, including modest meals in the normal course of business, infrequent entertainment (i.e. no more than twice per calendar year), gifts not to exceed $100 per individual in one calendar year, and unsolicited promotional items with a value less than $50.  In no event may Panduit employees accept cash. All business courtesies must be modest, reasonable and infrequent.  They must have a legitimate business purpose and may never be offered, received or provided with an intent to improperly influence the business judgment of the Panduit employee.  All of Supplier’s business dealings shall be transparently performed and accurately reflected in their business books and records.

• Fair Trade Practice. Supplier shall not engage in collusive bidding, price fixing, price discrimination or other unfair trade practices in violation of antitrust laws or competition laws.

• Intellectual Property/Confidential Information.  Supplier shall respect the intellectual property rights of Panduit and third parties and safeguard all Panduit Confidential Information, including but not limited to, know-how, trade secrets, financial information, new product or service development plans and other sensitive Panduit information or personally identifiable information, and limit access to such information to those of Supplier’s personnel who have a legitimate business need for such information and who are permitted by applicable law.

• Counterfeit Parts.  Suppliers shall maintain an effective process to detect and eliminate counterfeit parts and exclude counterfeit parts and materials from the products delivered.

• Privacy. Supplier shall comply with applicable privacy and information security laws when personal information is collected, stored, processed, transmitted and shared.   

• Conflict of Interest. Supplier understands that business decisions should not be improperly influenced by personal interests or relationships. As such, Supplier avoids all forms of conflicts of interest and situations that could have the appearance of a conflict of interest in the business they conduct with Panduit and Supplier identifies and discloses any actual conflict of interest or the appearance of any conflict of interest.

Auditing

Panduit reserves the right to audit Supplier’s compliance with this Supplier Code of Conduct, including but not limited to use of questionnaires, interviews of Supplier’s personnel and on-site inspections.  In connection with any audit, Supplier shall cooperate with Panduit and provide access to reasonably requested people, information and documents.  Panduit reserves the right to disqualify potential suppliers or terminate current suppliers suspected or found to be in violation of this Supplier Code of Conduct.

Reporting Violations

Supplier is responsible for reporting to Panduit suspected violations of law or this Supplier Code of Conduct.  Among other means, Supplier may report suspected violations via the Panduit Integrity Line: Panduit’s Ethics and Compliance Helpline, available at www.panduit.ethicspoint.com.