Teknor Apex is committed to ensuring that working conditions in Teknor Apex's supply chain are safe, that workers are treated with respect and dignity, and that manufacturing processes are environmentally responsible. Teknor Apex's suppliers (“Suppliers”) commit, in all of their activities, to operate in full compliance with the laws, rules, and regulations of the countries in which they operate. This Supplier Code of Conduct (“Code”) goes further, drawing upon internationally recognized standards, in order to advance social and environmental responsibility.
Teknor Apex requires that Suppliers implement this Code using the management systems described below. Teknor Apex may visit (and/or have external monitors visit) Supplier facilities to assess compliance with this Code.
The Teknor Apex Supplier Code of Conduct is modeled on and contains language from the Electronic Industry Code of Conduct. Recognized standards such as the Universal Declaration of Human Rights (UDHR), and standards issued by organizations such as the International Labor Organization (ILO), Social Accountability International (SAI), and the Ethical Trading Initiative (ETI), were used as references in preparing this Code and may be useful sources of additional information.
Labor and Human Rights
Suppliers must uphold the human rights of workers, and treat them with dignity and respect as understood by the international community.
Suppliers shall not discriminate against any worker based on race, color, age, gender, sexual orientation, ethnicity, disability, religion, political affiliation, union membership, national origin, or marital status in hiring and employment practices such as applications for employment, promotions, rewards, access to training, job assignments, wages, benefits, discipline, and termination. Suppliers shall not require a pregnancy test or discriminate against pregnant workers except where required by applicable laws or regulations or prudent for workplace safety. In addition, Suppliers shall not require workers or potential workers to undergo medical tests that could be used in a discriminatory way except where required by applicable laws or regulations or prudent for workplace safety.
Suppliers shall commit to a workplace free of harassment. Suppliers shall not threaten workers with or subject them to harsh or inhumane treatment, including sexual harassment, sexual abuse, corporal punishment, mental coercion, physical coercion, verbal abuse, or unreasonable restrictions on entering or exiting company-provided facilities. Suppliers shall prohibit harassment and unlawful discrimination in the workplace.
Prevention of Involuntary Labor and Human Trafficking
Suppliers shall not traffic in persons or use any form of slave, forced, bonded, indentured, or prison labor. This includes the transportation, harboring, recruitment, transfer, or receipt of persons by means of threat, force, coercion, abduction, fraud, or payments to any person having control over another person for the purpose of exploitation. All work must be voluntary and workers shall be free to leave work or terminate their employment with reasonable notice. Workers must not be required to surrender any government-issued identification, passports, or work permits as a condition of employment. Suppliers shall ensure that third-party agencies providing workers are compliant with the provisions of the Code. Suppliers shall ensure that contracts for both direct and contract workers clearly convey the conditions of employment in a language understood by the worker.
Where workers are required to pay a fee in connection with obtaining employment, Suppliers shall be responsible for payment of all fees and expenses in accordance with applicable laws. Such fees and expenses include, but are not limited to; expenses associated with recruitment, processing, or placement of both direct and contract workers.
Prevention of Underage (Child) Labor
Child labor is strictly prohibited. Supplier shall employ only workers who are at least fifteen (15) years of age or the applicable minimum legal age of the country in which they operate, in which the higher age will apply; if however, the local minimum working age is set at fourteen (14) years of age in accordance with exceptions for developing countries, then the lower age of fourteen (14) will apply.
Except in emergency or unusual situations, a reasonable effort will be made for a work week to not exceed 60 hours, including overtime, and workers shall take at least one day off every seven days. Working overtime should be voluntary by employees who willingly bid to work it. On the less frequent occurrences when Management has the need to require overtime work in general, individual employees must be free to request consideration of any conflicting priorities. Management must then demonstrate genuine openness to being reasonable and flexible to legitimate exception requests. Under no circumstances shall work weeks exceed the maximum permitted under applicable laws and regulations.
Wages and Benefits
Suppliers shall pay all workers at least the minimum wage required by applicable laws and regulations and provide all legally mandated benefits. In addition to their compensation for regular hours of work, workers shall be compensated for overtime hours at the premium rate required by applicable laws and regulations. Suppliers shall not use deductions from wages as a disciplinary measure. Suppliers shall offer vacation time, leave periods, and holidays consistent with applicable laws and regulations. Suppliers shall pay workers in a timely manner and clearly convey the basis on which workers are being paid.
Freedom of Association
Suppliers must respect the right of workers to associate freely with, form, and join workers’ organizations of their own choosing, seek representation, and bargain collectively, as permitted by and in accordance with applicable laws and regulations. Suppliers shall not discriminate with respect to employment based on union membership and, in particular, shall not make employment subject to the condition that the workers relinquish union membership or agree not to join a union; or cause the dismissal of or otherwise prejudice a worker by reason of union membership or participation in union activities outside working hours (or within working hours if the Supplier has consented to such activities or if required by applicable laws or regulations). Suppliers shall protect against acts of interference with the establishment, functioning, or administration of workers’ organizations in accordance with applicable laws and regulations.
Health and Safety
Teknor Apex recognizes that integrating sound health and safety management practices into all aspects of business is essential to maintain high morale and produce innovative products. Suppliers shall commit to creating safe working conditions and a healthy work environment for all of their workers.
Occupational Injury Prevention
Suppliers shall eliminate physical hazards where practicable. Where physical hazards cannot be eliminated, Suppliers shall provide appropriate engineering controls such as physical guards, interlocks, and barriers. Where appropriate engineering controls are not feasible Suppliers shall establish appropriate administrative controls such as safe work procedures. In all cases, Suppliers shall provide workers with appropriate personal protective equipment. Workers shall not be disciplined or need to fear reprisal of management for raising safety concerns and management will adequately address all legitimate concerns.
Occupational Safety Procedures and Systems
Suppliers shall establish procedures and systems to manage, track and report occupational injury and illness. Such procedures and systems shall encourage worker reporting, classify and record injury and illness cases, investigate cases and implement corrective actions to eliminate their causes, provide necessary medical treatment, and facilitate the workers’ return to work.
Prevention of Chemical Exposure
Suppliers shall identify, evaluate, and control worker exposure to hazardous chemical, biological, and physical agents. Suppliers must eliminate chemical hazards where feasible. Where chemical hazards cannot be eliminated, Suppliers shall provide appropriate engineering controls such as closed systems and ventilation. Where appropriate engineering controls are not feasible, Suppliers shall establish appropriate administrative controls such as safe work procedures. In all cases, Suppliers shall provide workers with appropriate personal protective equipment.
Emergency Prevention, Preparedness, and Response
Suppliers shall anticipate, identify, and assess emergency situations and events and minimize their impact by implementing emergency plans and response procedures, including emergency reporting, worker notification and evacuation procedures, worker training and drills, appropriate first-aid supplies, appropriate fire detection and suppression equipment, adequate exit facilities, and recovery plans.
Suppliers shall identify, evaluate, and control worker exposure to physically demanding tasks, including manual material handling, heavy lifting, prolonged standing, and highly repetitive or forceful assembly tasks.
Dormitory and Dining
Suppliers shall provide workers with clean toilet facilities, access to potable water, and sanitary food preparation and storage facilities. Worker dormitories provided by the Supplier or a third-party agency shall be clean and safe and provide adequate emergency egress, adequate heat and ventilation, reasonable personal space, and reasonable entry and exit privileges.
Health and Safety Communication
In order to foster a safe work environment, Suppliers shall provide workers with appropriate workplace health and safety information and training, including written health and safety information and warnings, in the primary language of the workers. Suppliers shall post that Safety Data Sheets are available in the primary language of its workers and properly train workers who will come into contact with such substances in the workplace.
Worker Health and Safety Committees
Suppliers are encouraged to initiate and support worker health and safety committees to enhance ongoing health and safety education and to encourage worker input regarding health and safety issues in the workplace.
At Teknor Apex, environmental considerations are an integral part of our business practices. Suppliers shall commit to reducing the environmental impact of their designs, manufacturing processes, and waste emissions.
Suppliers must comply with any applicable laws and regulations prohibiting or restricting the use or handling of specific substances. To ensure safe handling, movement, storage, recycling, reuse, and disposal, Suppliers shall identify and manage substances that pose a hazard if released to the environment and comply with applicable labeling laws and regulations for recycling and disposal.
Solid Waste Management
Suppliers shall manage and dispose of non-hazardous solid waste generated from operations as required by applicable laws and regulations.
Wastewater and Stormwater Management
Suppliers shall monitor, control, and treat wastewater generated from operations before discharge as required by applicable laws and regulations. Suppliers shall take appropriate precautions to prevent contamination of stormwater runoff from their facilities.
Air Emissions Management
Suppliers shall characterize, monitor, control, and treat air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone-depleting chemicals, and combustion by-products generated from operations, as required by applicable laws and regulations, before discharge.
Environmental Permits and Reporting
Suppliers must obtain, maintain, and keep current all required environmental permits (for example, discharge monitoring) and registrations and follow the operational and reporting requirements of such permits.
Pollution Prevention and Resource Reduction
Suppliers must endeavor to reduce or eliminate solid waste, wastewater, and air emissions, including energy-related indirect air emissions, by implementing appropriate conservation measures in their production, maintenance, and facilities processes, and by recycling, reusing, or substituting materials.
Suppliers must be committed to high standards of ethical conduct when dealing with workers, suppliers, and customers.
This applies to all Teknor personnel as integrity and ethics are core values to our organization. If anyone observes a Teknor employee exhibiting or has exhibited any of the following behaviors, please report these observations by logging on to The EthicsPoint Resolution Line at www.teknorapex.ethicspoint.com
- Dishonest or Unethical Behavior on Business Transaction
- Harassment or Discrimination
- Threats or Violence
- Conflicts of Interest
- Safety or Environmental Violations
- Theft, Fraud, or Accounting Irregularities
- Any Other Serious Legal or Ethical Offenses
Corruption, extortion, and embezzlement, in any form, are strictly prohibited. Suppliers shall not violate the Foreign Corrupt Practices Act (FCPA), any international anti-corruption conventions, and applicable anti-corruption laws and regulations of the countries in which they operate, and shall not engage in corruption, extortion, or embezzlement in any form. Suppliers shall not offer or accept bribes or other means to obtain an undue or improper advantage. Suppliers must uphold fair business standards in advertising, sales, and competition.
Disclosure of Information
Suppliers must accurately record and disclose information regarding their business activities, structure, financial situation, and performance in accordance with applicable laws and regulations and prevailing industry practices.
Complaints and Grievances
Suppliers shall provide a complaint mechanism for workers to report workplace grievances in accordance with local laws and regulations.
Suppliers are encouraged to engage the community to help foster social and economic development and to contribute to the sustainability of the communities in which they operate.
Protection of Intellectual Property
Suppliers must respect intellectual property rights and safeguard customer information; transfer of technology and know-how must be done in a manner that protects intellectual property rights.
A corporate social and environmental responsibility statement affirming the Supplier’s commitment to compliance and continual improvement is to be posted in the primary local language at all of the Supplier’s worksites.
Documentation and Records
Supplier shall have processes to identify, monitor, and understand applicable laws and regulations and the additional requirements imposed by this Code. Supplier shall obtain, maintain, and keep current a valid business license as required by applicable laws and regulations.
Supplier shall have processes for creation of documents and records to ensure regulatory compliance and conformity to this Code, with appropriate confidentiality measures to protect privacy.
Training and Communication
Suppliers shall have programs in place for training managers and workers to implement their policies and procedures and to fulfill improvement objectives.
Suppliers shall have a process for communicating clear and accurate information about their performance, practices, and expectations to its workers, suppliers and customers.
Suppliers shall have an ongoing process to obtain feedback on processes and practices related to this Code and to foster continuous improvement.
Corrective Action Process
Supplier shall have a process for timely correction of any deficiencies identified by an internal or external audit, assessment, inspection, investigation, or review.
The following references were consulted preparing this Code:
Eco-Management and Audit Scheme
Electronic Industry Code of Conduct
Ethical Trading Initiative
ILO Code of Practice in Safety and Health
ILO International Labor Standards
National Fire Protection Association
OECD Guidelines for Multinational Enterprises
United Nations Convention Against Corruption
United Nations Global Compact
Universal Declaration of Human Rights
UN Norms on the Responsibilities of Transnational Corporations and Other Business Enterprises with Regard to Human Rights