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Code of Ethics and Compliance Policies

Code of Ethics and Compliance Policies

MEKEM’s Supplier Code of Conduct (“Code”) defines the minimum non-negotiable rules that we expect our suppliers and sub-suppliers to comply with during their business relations with MEKEM in accordance with the Supplier Management Policy. The standards defined in the Code set out MEKEM’s expectations from its suppliers. In the context of the Code, the term “Supplier” refers to the main supplier, its affiliates and subsidiaries, employees, sub-suppliers and subcontractors.

MEKEM expects its suppliers to comply with all applicable laws and regulations and to make serious efforts to adopt international standards and best practices.

The Supplier Code of Conduct contains general principles applicable to each and all Suppliers and nothing contained herein shall be overridden by any specific provisions contained in any written agreement on the same subject matter.

Acceptance of the Code is a prerequisite for all MEKEM supply contracts and orders. As such, suppliers guarantee that their entire activities comply with the principles provided in this document. Therefore, our suppliers are expected to unconditionally follow the Code in all their activities, inform their employees of the Code, ensure that their employees attach the necessary importance to the Code, and make the Code easily accessible for employees. The standards set forth in the Code do not constitute a legal agreement between MEKEM and its suppliers; however, the Code is an essential part of such an agreement.

The supplier agrees to comply with the following stipulations and principles:

1. Compliance with laws: Suppliers shall comply fully with all laws and regulations applicable to them.

2. Environmental sustainability: MEKEM expects its suppliers to demonstrate a clear understanding of the environmental risks, impacts and responsibilities associated with the products and services they provide:

    • Observance of environmental protection with regard to legal norms and international standards;
    • Avoidance of negative effects on people and the environment during the development, manufacture, useful life and all subsequent processes;
    • Attention to material reduction and substitution, maintenance and recycling;
    • Continuous reduction of greenhouse gas emissions through use of renewable energies and energy efficiency improvements;
    • Protection and improvement of air and water quality through organisational measures in order to reduce emission of pollutants, water pollution, level of water consumption;
    • Avoidance of substances that are harmful to the environment and to health.

Suppliers should have processes in place to ensure that their operations conform to all applicable environmental legislation. All required environmental permits, approvals and registrations are to be obtained, maintained and complied with in accordance with the conditions and requirements defined therein.

Suppliers shall make practical efforts to eliminate or reduce levels of generated waste and should reuse and recycle waste materials wherever possible. The handling, storage, movement, treatment and disposal of all waste must be carried out in accordance with applicable regulations and in an environmentally responsible manner. 

3. Human rights and social sustainability: Policies should be in place to confirm the supplier’s commitment to points 3.1—3.9, and improvement programs should be in place where relevant:

3.1 Prevention of forced labor, bonded labor and human trafficking: 

    • All employment shall be freely chosen by the worker. Workers shall be free to leave their employment at any time (subject to reasonable and paid notice periods) and shall not be subject to any coercion or restriction through, for example, the holding of original copies of employee passports, identity documents or monetary deposits.
    • There shall not be any use of bonded labor. Work must be undertaken for fair compensation and must not be undertaken to repay a debt incurred.
    • The supplier must prevent all forms of modern slavery. Examples include forced overtime, withholding identity documents and human trafficking

3.2 Child labor: The Supplier is committed to refrain from employing children younger than the legal minimum age (as per ILO Convention 138). The Supplier is also expected to ensure that employees under 18 years of age do not work nights or overtime and are protected against working conditions that are detrimental to their health, safety or development. The Supplier shall ensure that the work of young workers does not prevent them from attending school.

3.3 Wages and benefits: As a minimum, the legally guaranteed minimum wage standard for the entire workforce must be respected, employees must receive clear information about their wages, and unjustified deductions from wages as a disciplinary measure must not be allowed.

3.4 Working hours: Working hours must be limited according to national or local law, including breaks. Overtime is subject to the relevant legal framework, should be voluntary and must be fairly compensated.  Employees must have at least one day off every seven days. The supplier shall respect local laws and regulations governing maximum working hours and leave entitlements.

3.5 Freedom of association, collective bargaining: Employees have the right to join or form a trade union without facing discrimination or intimidation. We expect our suppliers to allow their employees to organize peacefully, especially to deal with worker representation and civil matters. This includes the right to bargain collectively where required by law to protect their interests.

3.6 Health, safety and working conditions: Suppliers must provide fair, hygienic, healthy and safe working conditions for all employees, being aware of industry-specific hazards and in compliance with occupational health and safety standards. Relevant trainings must be provided to employees.

3.7 Regular employment: All employees should be provided with a written employment contract setting out their terms and conditions in accordance with the local relevant legal jurisdiction. We expect all employment and the termination of employment to be carried out in a fair manner. 

3.8 No harsh or inhumane treatment: There must be no harsh or inhumane treatment. Suppliers shall take all necessary steps to prevent all forms of harassment, including sexual harassment, sexual abuse, corporal punishment, psychological or physical coercion, or verbal abuse or intimidation.  Suppliers shall provide all workers in their operations and supply chains with a mechanism through which complaints about labor practices can be raised anonymously without fear of retribution. Suppliers shall investigate all complaints raised and take appropriate action to address them.

All individuals and groups must be treated equally regardless of their personal characteristics, including gender, skin color, ethnic or social origin, genetic characteristics, language, religion or ideology, political or other opinion, membership of a national minority, net worth, birth status, disability, age or sexual orientation.

3.9 Diversity and Inclusion: Suppliers must promote non-discrimination and equal opportunity and foster a diverse and inclusive workplace.

4. Business Integrity and Corporate Ethics

Anti-Corruption: Suppliers must not engage in bribery or corruption under any circumstances.

Anti-Trust Law and other competition laws: Suppliers must comply with national and international competition laws and must not participate in any agreements regarding prices, markets or offers.

Avoidance of conflicts of interests: Suppliers should avoid conflicts of interest that may have a negative impact on business relationships.

Intellectual Property: Suppliers should respect intellectual property rights.

Transparency: Suppliers must be transparent and accurate in reporting their business activities.

Data Privacy and Security: Suppliers must protect confidential information and ensure data privacy. The Supplier undertakes to meet the reasonable expectations of its customers, suppliers and employees regarding the protection of private information. It must comply with laws on data protection and information security as well as governmental regulations on the collection, storage, processing, transmission, backup and deletion of personal information.

5. Supply chain: Suppliers must ensure that their products meet all required quality and safety standards. For a healthy supply chain, MEKEM also expects its suppliers to encourage their own suppliers to comply with the content of the Code of Conduct set forth herein.

6. Monitoring and Compliance

Suppliers accept audits and assessments related to the Code of Conduct and are held responsible for taking corrective measures for any nonconformities identified. In case of doubts about compliance with this Code of Conduct, the supplier will be asked to take appropriate countermeasures and report the process to the responsible person at MEKEM.

7. Legal Consequences of Violations: It is stated that the requirements set forth herein are important for MEKEM. Any violation of this Code of Conduct may result in MEKEM initiating appropriate legal proceedings. In particular, MEKEM reserves the right to terminate the business relationship in case of serious or repeated violations of this Code of Conduct. The Supplier is expected to reliably guarantee and be able to prove that it has initiated immediate countermeasures to prevent detected violations.