Supplier Code of Conduct
ADC’s suppliers play an important role in our success and the success of our customers worldwide. As such, we place a high value on all our supplier relationships.
We and our suppliers operate in diverse locations around the world. As global citizens, we each have an obligation to act responsibly, lawfully and with the outmost integrity wherever we do business. ADC recognizes that operating in environments with a multitude of different legal, cultural and business practices and requirements can be challenging. To avoid any misunderstandings and to provide our suppliers with clear guidance on our expectations for their behavior and business practices, all ADC suppliers are required to become familiar with and comply to ADC’s Supplier Code of Conduct as a condition to doing business with ADC. To ensure compliance, suppliers may periodically be required by ADC to certify or provide information relevant to compliance with the Supplier Code of Conduct.
A. ETHICS
* Integrity
Suppliers shall uphold the highest standards of ethics and integrity in the conduct of all business activities. Suppliers shall not take unfair advantage of ADC or other parties through misrepresentation of facts or any dishonest practices.
* Compliance with Law
Suppliers shall maintain compliance with all applicable laws, including without limitation, all applicable import/export laws, anti-corruption laws, antitrust and fair competition laws and all other applicable laws. All forms of illegal activity, corruption, fraud, money laundering, extortion, unfair competition, embezzlement and or unethical behavior are strictly prohibited.
* Conflicts of Interest
ADC employees may not serve as officers, directors, employees, agents or consultants of any ADC supplier, except with the consent of the applicable ADC business manager and ADC’s Business Conduct Committee. If such a relationship exists that has not been disclosed to ADC, suppliers shall report such relationship to ADC immediately under Section E of this policy.
* Bribes, Gifts, Entertainment, Favors and Payments
Suppliers shall not offer any ADC employee gifts, payments, services, or other favors where these would, or might appear to improperly influence the employee in performing his or her duties for ADC. ADC employees may not encourage or solicit gifts, entertainment or services from a supplier. From time to time, employees may accept gifts, entertainment or services, but only if the same are of nominal value, appropriate to a specific occasion, occur infrequently and nothing is expected in return. Gifts of cash or cash equivalents (e.g. gift cards) are prohibited. Consistent with ADC’s requirement that all business conducted with ADC adheres to applicable laws and regulations, the use of bribes, secret compensation or kickbacks is strictly prohibited.
* Fair Competition
Suppliers shall comply with all applicable antitrust and/or fair competition laws. Accordingly, among other things, supplier shall not: (i) enter into any agreement, plan or understanding (written or oral), with regard to ADC business, with any of the supplier’s competitors relating to price, terms or conditions of sale, production, distribution, territories or customers; or (ii) exchange or discuss with any of its competitors pricing, marketing plans, manufacturing costs or other competitive information. Suppliers that violate these laws face immediate termination.
* Charitable Contributions
ADC makes business decisions with its suppliers based solely upon price, quality, ability and availability to do the work. These choices are not influenced by a supplier’s contribution to any particular charity. ADC employees are prohibited from soliciting charitable donations from suppliers to influence their current or future business with ADC. Suppliers should submit any questions or report inappropriate requests for donations to ADC under Section E of this policy.
* Confidentiality
Information regarding business activities, structure, financial situation, performance and employees shall only be disclosed in accordance with local laws and any confidentiality agreement(s) between the parties. Intellectual property rights shall not be violated. Suppliers shall maintain procedures that reasonably ensure that all confidential information will not be improperly used or disclosed.
B. LABOR
* Human Rights and Labor Conditions
All work shall be conducted in a lawful manner and workers treated humanely. Suppliers shall respect internationally proclaimed human rights and avoid complicity in human rights abuses of any kind. Suppliers shall respect the personal dignity, privacy and rights of each individual. Abusive or inhumane treatment or threat of such treatment, including sexual harassment, sexual abuse, corporal punishment, mental or physical coercion or verbal abuse of workers is prohibited. Working hours are to be observed in accordance with applicable law and shall be reported and paid in compliance with applicable law.
* Forced Labor
Forced, bonded or indentured labor or involuntary prison labor shall not be used. Suppliers shall ensure that all workers are free to leave their employment/work after giving reasonable or lawful notice. Workers shall not be required to lodge deposits of money, identity papers or similar personal property in order to get or keep their employment/work.
* Child Labor
Suppliers shall not employ or use child labor in violation of applicable law or the ILO Minimum Age Convention 1973 (C 138) as amended.
* Wages and Benefits
Compensation paid to workers shall comply with all applicable wage laws, including those relating to minimum wages and overtime pay requirements and any legally mandated benefits. Deductions from wages as a form of discipline are generally prohibited unless expressly permitted by applicable law. Workers will be informed of all lawful deductions from pay that are taken in accordance with applicable law.
* Non-Discrimination
Suppliers shall not engage in unlawful labor or employment discrimination based on any status or characteristic protected by applicable law, including: race, color, creed, national origin, ethnicity, age, gender, sexual orientation, gender identity or expression, , disability, pregnancy, religion, political affiliation, or marital status. By way of example only, unlawful labor and employment discrimination is prohibited in areas such as hiring, retention, promotion, pay, training, rewards or other workplace conduct. Suppliers shall support equality of opportunity and treatment in employment and occupation.
* Freedom of Association
Suppliers shall respect the rights of workers as established by local law to associate freely, join Work Councils, labor or other unions and bargain collectively of their own choosing.
C. HEALTH and SAFETY
Suppliers shall provide workers a healthy and safe working environment in accordance with internationally recognised standards. Suppliers shall do their utmost to control hazards and take necessary precautionary measures against accidents and occupational diseases. Whenever necessary workers are to be provided with, and instructed to use, appropriate personal protective equipment. Suppliers shall provide adequate and regular training to ensure that workers are adequately educated on health and safety issues. Suppliers shall ensure that, where it provides accommodation, facilities shall be clean, safe and meet the basic needs of the Workers, and, where appropriate, of their families.
D. ENVIRONMENTAL
* Environmental Permits, Regulations and Standards
Suppliers shall take a precautionary approach towards environmental challenges, undertake initiatives to promote greater environmental responsibility, and encourage the development and diffusion of environmentally friendly technologies. Suppliers shall also act in accordance with relevant local laws, regulations and standards related to the protection of the environment, including the safe handling, movement, storage, recycling or reuse and disposal of goods. Suppliers shall continuously work to minimize their environmental impact.
* Product Compliance and Certification
In transferring any goods to ADC, suppliers shall ensure that such goods comply with all applicable laws and regulations, including but not limited to those related either to identification and communication of substances found in supplier products, restriction of specific substances, or to labeling for recycling and disposal. Suppliers may be asked by ADC to supply material information necessary for ADC or its customers to comply with laws and regulations regarding the composition of and substances used in goods furnished. Suppliers shall reasonably cooperate with ADC to provide such requested information in a timely manner and reasonable format as directed by ADC. Suppliers should review with ADC, specific ADC requirements that may apply. Additional information on environmental requirements for goods transferred to ADC can be found here.
ADC’s suppliers play an important role in our success and the success of our customers worldwide. As such, we place a high value on all our supplier relationships.
We and our suppliers operate in diverse locations around the world. As global citizens, we each have an obligation to act responsibly, lawfully and with the outmost integrity wherever we do business. ADC recognizes that operating in environments with a multitude of different legal, cultural and business practices and requirements can be challenging. To avoid any misunderstandings and to provide our suppliers with clear guidance on our expectations for their behavior and business practices, all ADC suppliers are required to become familiar with and comply to ADC’s Supplier Code of Conduct as a condition to doing business with ADC. To ensure compliance, suppliers may periodically be required by ADC to certify or provide information relevant to compliance with the Supplier Code of Conduct.
A. ETHICS
* Integrity
Suppliers shall uphold the highest standards of ethics and integrity in the conduct of all business activities. Suppliers shall not take unfair advantage of ADC or other parties through misrepresentation of facts or any dishonest practices.
* Compliance with Law
Suppliers shall maintain compliance with all applicable laws, including without limitation, all applicable import/export laws, anti-corruption laws, antitrust and fair competition laws and all other applicable laws. All forms of illegal activity, corruption, fraud, money laundering, extortion, unfair competition, embezzlement and or unethical behavior are strictly prohibited.
* Conflicts of Interest
ADC employees may not serve as officers, directors, employees, agents or consultants of any ADC supplier, except with the consent of the applicable ADC business manager and ADC’s Business Conduct Committee. If such a relationship exists that has not been disclosed to ADC, suppliers shall report such relationship to ADC immediately under Section E of this policy.
* Bribes, Gifts, Entertainment, Favors and Payments
Suppliers shall not offer any ADC employee gifts, payments, services, or other favors where these would, or might appear to improperly influence the employee in performing his or her duties for ADC. ADC employees may not encourage or solicit gifts, entertainment or services from a supplier. From time to time, employees may accept gifts, entertainment or services, but only if the same are of nominal value, appropriate to a specific occasion, occur infrequently and nothing is expected in return. Gifts of cash or cash equivalents (e.g. gift cards) are prohibited. Consistent with ADC’s requirement that all business conducted with ADC adheres to applicable laws and regulations, the use of bribes, secret compensation or kickbacks is strictly prohibited.
* Fair Competition
Suppliers shall comply with all applicable antitrust and/or fair competition laws. Accordingly, among other things, supplier shall not: (i) enter into any agreement, plan or understanding (written or oral), with regard to ADC business, with any of the supplier’s competitors relating to price, terms or conditions of sale, production, distribution, territories or customers; or (ii) exchange or discuss with any of its competitors pricing, marketing plans, manufacturing costs or other competitive information. Suppliers that violate these laws face immediate termination.
* Charitable Contributions
ADC makes business decisions with its suppliers based solely upon price, quality, ability and availability to do the work. These choices are not influenced by a supplier’s contribution to any particular charity. ADC employees are prohibited from soliciting charitable donations from suppliers to influence their current or future business with ADC. Suppliers should submit any questions or report inappropriate requests for donations to ADC under Section E of this policy.
* Confidentiality
Information regarding business activities, structure, financial situation, performance and employees shall only be disclosed in accordance with local laws and any confidentiality agreement(s) between the parties. Intellectual property rights shall not be violated. Suppliers shall maintain procedures that reasonably ensure that all confidential information will not be improperly used or disclosed.
B. LABOR
* Human Rights and Labor Conditions
All work shall be conducted in a lawful manner and workers treated humanely. Suppliers shall respect internationally proclaimed human rights and avoid complicity in human rights abuses of any kind. Suppliers shall respect the personal dignity, privacy and rights of each individual. Abusive or inhumane treatment or threat of such treatment, including sexual harassment, sexual abuse, corporal punishment, mental or physical coercion or verbal abuse of workers is prohibited. Working hours are to be observed in accordance with applicable law and shall be reported and paid in compliance with applicable law.
* Forced Labor
Forced, bonded or indentured labor or involuntary prison labor shall not be used. Suppliers shall ensure that all workers are free to leave their employment/work after giving reasonable or lawful notice. Workers shall not be required to lodge deposits of money, identity papers or similar personal property in order to get or keep their employment/work.
* Child Labor
Suppliers shall not employ or use child labor in violation of applicable law or the ILO Minimum Age Convention 1973 (C 138) as amended.
* Wages and Benefits
Compensation paid to workers shall comply with all applicable wage laws, including those relating to minimum wages and overtime pay requirements and any legally mandated benefits. Deductions from wages as a form of discipline are generally prohibited unless expressly permitted by applicable law. Workers will be informed of all lawful deductions from pay that are taken in accordance with applicable law.
* Non-Discrimination
Suppliers shall not engage in unlawful labor or employment discrimination based on any status or characteristic protected by applicable law, including: race, color, creed, national origin, ethnicity, age, gender, sexual orientation, gender identity or expression, , disability, pregnancy, religion, political affiliation, or marital status. By way of example only, unlawful labor and employment discrimination is prohibited in areas such as hiring, retention, promotion, pay, training, rewards or other workplace conduct. Suppliers shall support equality of opportunity and treatment in employment and occupation.
* Freedom of Association
Suppliers shall respect the rights of workers as established by local law to associate freely, join Work Councils, labor or other unions and bargain collectively of their own choosing.
C. HEALTH and SAFETY
Suppliers shall provide workers a healthy and safe working environment in accordance with internationally recognised standards. Suppliers shall do their utmost to control hazards and take necessary precautionary measures against accidents and occupational diseases. Whenever necessary workers are to be provided with, and instructed to use, appropriate personal protective equipment. Suppliers shall provide adequate and regular training to ensure that workers are adequately educated on health and safety issues. Suppliers shall ensure that, where it provides accommodation, facilities shall be clean, safe and meet the basic needs of the Workers, and, where appropriate, of their families.
D. ENVIRONMENTAL
* Environmental Permits, Regulations and Standards
Suppliers shall take a precautionary approach towards environmental challenges, undertake initiatives to promote greater environmental responsibility, and encourage the development and diffusion of environmentally friendly technologies. Suppliers shall also act in accordance with relevant local laws, regulations and standards related to the protection of the environment, including the safe handling, movement, storage, recycling or reuse and disposal of goods. Suppliers shall continuously work to minimize their environmental impact.
* Product Compliance and Certification
In transferring any goods to ADC, suppliers shall ensure that such goods comply with all applicable laws and regulations, including but not limited to those related either to identification and communication of substances found in supplier products, restriction of specific substances, or to labeling for recycling and disposal. Suppliers may be asked by ADC to supply material information necessary for ADC or its customers to comply with laws and regulations regarding the composition of and substances used in goods furnished. Suppliers shall reasonably cooperate with ADC to provide such requested information in a timely manner and reasonable format as directed by ADC. Suppliers should review with ADC, specific ADC requirements that may apply. Additional information on environmental requirements for goods transferred to ADC can be found here.