Legal Information
Zafin Supplier Code of Conduct
Last Updated: 2023-08-09
Overview
Zafin and each of its divisions, business units, subsidiaries, and affiliates (collectively Zafin) is committed to the highest standards of integrity, ethics, business conduct, and social responsibility. Zafin expects all suppliers engaged in supplying products and providing services to Zafin to make a similar commitment. Suppliers is an all-inclusive term that may include vendors, sellers, contractors, subcontractors, subconsultants, dealers, fabricators, consultants, manufacturers, distributors, and their lower-tier suppliers.
These Zafin Supplier Standards of Conduct (“Standards”) describe Zafin’s expectations of how its Suppliers conduct business. Zafin expects Suppliers to act in accordance with these Standards, and at a minimum requires that all Suppliers abide by all applicable laws and regulations within the countries where they operate and be open and cooperative with the regulators enforcing such laws and regulations. In instances where expectations outlined in these Standards differ from applicable laws and regulations, Suppliers must follow these expectations within the bounds of applicable laws and regulations.
Suppliers must ensure that their staff (at all levels), representatives, and business partners understand and abide by these Standards with respect to work performed on behalf of Zafin.
Suppliers must not consult with other third parties on behalf of Zafin or represent Zafin to other third parties without the express permission of Zafin.
Non-Discrimination and No Harassment
Suppliers are required to comply with all applicable legislation relating to discrimination and equal opportunity. Suppliers must keep a respectful and safe workplace free from physical, psychological, or verbal harassment or intimidation or any other form of abusive conduct.
Wage and Labour Laws
Suppliers must ensure wages reflect statutory governed wages and labour laws, including those related to minimum wage; overtime pay; benefits; and
temporary, dispatch, and outsourced labour. Zafin expects Suppliers to provide employees with a wage statement that includes enough information to verify correct compensation for work.
Drug Free Workplace
Suppliers must keep a workplace free from illegal use, possession, sale, or distribution of controlled substances. Suppliers must ensure that their employees do not conduct work while under the influence of alcohol or drugs, whether prescription or non-prescription.
Slavery, Forced Labour, Child Labour and Human Trafficking
Zafin does not tolerate slavery, forced labour or human trafficking in any form. Suppliers must abide by all applicable laws relating to slavery, forced labour, bonded labour, indentured labour, involuntary prison labour, and human trafficking.
Zafin does not tolerate child labour in any form. Suppliers must abide by all applicable laws relating to minimum working age, including any laws related to employment, apprenticeships, and internships of youths and students.
Right to Work
Suppliers must verify that employees and prospective employees have the right to work in any country where the Supplier supplies goods and services. Suppliers must keep copies of all associated documentation provided by the individual and ensure it is genuine, unchanged from the original, and that the individual has permission to undertake the offered work.
Bribery, Anticorruption and Business Courtesies
Suppliers must abide by all applicable bribery and anticorruption laws (e.g.,
U.S. Foreign Corrupt Practices Act, UK Bribery Act). Suppliers must not pay a bribe in any amount, to anyone, anywhere, for any reason whatsoever, whether on their behalf, on Zafin ’s behalf, or on behalf of any third party. Suppliers must not offer, promise, authorise, or provide, directly or indirectly, anything of value with the intent or effect of inducing anyone to forego their duties and providing an unfair business advantage to anyone, including facilitating payments.
Suppliers must not offer or accept any business courtesy to obtain improper advantages or influence for the Supplier, Zafin (including Zafin employees and their family members and associates), or any third party. Business courtesies include gifts, benefits, fees, commissions, dividends, cash, gratuities, services, or any inducements. Suppliers must ensure that the offering or receipt of any business courtesy is permitted by law and regulation, and that the exchange does not violate the rules and standards of the recipient’s organisation and is consistent with reasonable marketplace customs and practices.
Reporting and Nonretaliation
Suppliers must provide their employees and business partners with reporting channels to raise legal or ethical issues or concerns. The policy and process must be transparent and understandable and must protect reporting and participating individuals from any retaliation or other adverse action.
Suppliers must let Zafin’s ethics and compliance officer ([email protected]) know of any misconduct related to Zafin business undertaken by any Zafin employee, any Supplier employee, or any Supplier business partner.
Conflicts of Interest
Suppliers must avoid all conflicts of interest or situations giving the appearance of a conflict of interest in their dealings with Zafin. Suppliers must report to Zafin any instances involving actual or perceived conflicts of interest, whether organisational or personal.
Sensitive Information, Data Privacy, and Intellectual Property
Suppliers must use commercially reasonable methods to manage, store, and secure sensitive information such as confidential or proprietary information or personally identifiable information. Suppliers must not use sensitive information for any other purpose than the specific authorised business purpose.
Suppliers must abide by all applicable laws related to data privacy and the protection of personally identifiable information. In all cases, Suppliers must let Zafin know at once of any actual or suspected data breach, including the measures taken to minimise the effect of the breach and likelihood of a reoccurrence. Suppliers must abide by all laws governing use, disclosure, and protection of intellectual property, including patents, copyrights, trademarks, and service marks.
Health and Safety
Suppliers must abide by all applicable health and safety laws and regulations. Zafin expects Suppliers to adopt practices to minimise health and safety risks, support accident prevention, and ensure a safe workspace for all workers. Suppliers must make relevant health and safety training, information, and support available to all employees.
When driving on behalf of Zafin, all local laws must be adhered to and individuals must be licensed and safe to drive the relevant vehicle and be provided with legal, safe, fit-for-purpose vehicles maintained in accordance with the manufacturer’s guidelines.
Suppliers must have in place suitable emergency plans across their operations to minimise the potential effects of any emergency either because of its own operations or that of anyone working on their behalf.
Environment
Suppliers must abide by all applicable environmental laws and regulations and have in place the correct licenses, permits, and registrations for their operations. Zafin expects Suppliers to conduct operations in a manner that actively manages risk; conserves natural resources; prevents pollution; safeguards the environment; and minimises waste, emissions, and energy consumption.
Fair Competition and Antitrust
Zafin expects the activities of Suppliers to be based on sound business values. Suppliers must conduct their business in a fair, consistent, open, and honest manner, allowing competition throughout their suppliers to the same or greater extent that Zafin provides to its suppliers.
Suppliers must avoid any anti-competitive conduct for any reason whatsoever. Suppliers must neither participate in price fixing, bid rigging, or cartel activity, nor exchange current, recent, or projected pricing information or other sensitive or non-public information with any other party, except as authorised by the owner of the information. Suppliers must refrain from abusing their market power by refusing to deal, engaging in predatory or discriminatory pricing practices, conditioning the sale or provision of a particular product or service with that of another product or service, or undertaking similar abusive tactics. Suppliers must not engage in other deceptive or unfair market practices. Suppliers must never make misrepresentations about Zafin’s products or services, their products or services, or the products or services of others. Similarly, Suppliers must never denigrate Zafin’s competitors or their competitors, or their products or services.
Registrations and Certifications
Suppliers must obtain any registrations, certifications, insurances, or other formal documentation that formed a material requirement of their appointment. If these requirements lapse or change, Suppliers must inform Zafin as soon as practicably possible.
Quality and Counterfeit Parts
Suppliers must design, produce, and deliver products and services with the paramount consideration being the safety and health of their employees and clients. Suppliers must have quality assurance processes to detect, communicate, and correct defects to ensure delivery of products and services that meet or exceed contractual quality, legal, and regulatory requirements. Suppliers must complete all required inspection and testing operations by appropriately authorised and qualified individuals.
Suppliers must ensure the existence of methods and processes to minimise the risk of introduction of counterfeit parts into final products; detect and avoid counterfeit parts and materials; provide notification to recipients of counterfeit products; and remove any counterfeit parts from the final products. Supplier must hold those in its supply chain accountable for the same obligations with respect to work performed on behalf of Zafin.
Supply Chain Security
Suppliers must implement practices and procedures to ensure the security of their supply chain. Suppliers who either ship directly or package goods for shipment must abide by all SAFE Framework of Standards to Secure and Facilitate Global Trade requirements of the destination country.
Records
Suppliers must keep complete and accurate records relating to their transactions with Zafin. Suppliers must never make any entry in their records or alter, conceal, or destroy any document to misrepresent any fact, circumstance, or transaction related to Zafin business.
Money Laundering
Suppliers must not use their business relationship with Zafin to disguise the sources of illegally obtained funds.
Insider Trading
Suppliers and their staff (at all levels) representatives, and business partners must not use material, non-public information obtained during their business relationship with Zafin as the basis for trading or enabling others to trade in the stock or securities of any company.
