ICT Supplier Code of Conduct

Introduction

Integrated Control Technology (ICT) is committed to the highest standards of social and environmental responsibility and ethical conduct and recognizes the importance of minimizing the impact of our operations on our surroundings by operating in a sustainable manner.

We seek to engage and collaborate with suppliers who share our commitment and approach to conducting business.

Scope

This Supplier Code of Conduct (“code”) outlines the minimum standards and expectations applicable to all suppliers, including their parent, subsidiaries, affiliates and subcontractors (“suppliers”) providing goods or services to ICT.

Suppliers will be responsible for all activities associated with disseminating and educating their employees, agents and subcontractors on this code, verifying compliance with the code and acting in response to non-compliance.

Standards

Labor and Human Rights

ICT is committed to human rights and equal opportunity in the workplace, which includes the expectation that suppliers will ensure their employees are treated fairly and with dignity and respect.

We encourage our suppliers to embrace international standards relating to human rights. Suppliers must respect the labor rights of their employees in the workplace and monitor human rights within their supply chain. As a minimum, suppliers must ensure:

Employees are not subjected to discrimination based on race, national origin, ethnicity, religion, gender, age, marital status, sexual orientation, disability or any other reason
All products and services supplied to ICT are manufactured or provided under safe and healthy conditions
Only employees who are legally authorized to work in their facilities are employed. Suppliers shall be responsible for validating their employees’ eligibility to work through appropriate documentation
All employees meet the local legal minimum labor age permitted by the law of the country or countries where the performance, in whole or in part of the contract, takes place. Child labor is strictly prohibited
Employees engaged in the manufacture and supply of products and services are voluntarily employed, and under no circumstances is any form of forced, coerced, bonded, indentured or involuntary labor or otherwise
All employees are paid a proper and competitive wage which meets their basic needs and provides discretionary income, and is no less than the standards specified by local laws, where applicable
Employee working hours, including voluntary overtime work, and the granting of leave of any form, are in accordance with applicable local and/or national laws. Workers shall not work more hours in one week than allowable under local laws. Overtime is to be voluntary, compensated at a legal rate and must be provided under safe and healthy work conditions
Employees are not exploited or subjected to abuse of any kind, including psychological, physical, sexual or verbal abuse. Intimidation, threat or harassment is not tolerated
Employees’ right to freedom of association and collective bargaining is acknowledged. Where these rights are restricted by law, Suppliers will not hinder the development of alternative means of independent and free association and bargaining the privacy rights of all employees will be respected whenever private information is gathered or employee monitoring practices are in place.

Environmental Sustainability

ICT will continuously improve processes to minimize the negative impacts of its business operations on the global environment.

We will work with suppliers that integrate environmental responsibility into their operations and minimize adverse effects on the community, environment and natural resources, while safeguarding the health and safety of employees and the public. Suppliers shall also comply with all applicable health, safety and environmental laws and regulations when conducting business.

We expect our suppliers to demonstrate the following commitments in their operations:

Use low emission sources of energy where available and feasible.
Optimize responsible and efficient use of energy, materials, and resources, as much as is practicably possible.
Reduce waste by applying circular economy practices and optimizing reuse or recycling of materials.
Reduce, control and/or eliminate wastewater, waste and pollution at the source
Reduce hazardous waste production and where it has occurred, ensure its safe and responsible treatment.
Maintain biodiversity by minimizing impact through the application of the mitigation hierarchy (avoid, minimize, restore, and offset).
Ensure no net deforestation.

Health and Safety

Suppliers must ensure the health and safety of all persons within their organization and ensure compliance with all regulatory and statutory health and safety requirements.

Suppliers must integrate sound health and safety management policies, practices and management systems into their businesses. These must be designed to promote the general health of employees, and identify, assess, and evaluate potential risks to prevent, mitigate and reduce employees exposure to hazards such as occupational injury and illness, emergency situations and events, physically demanding and repetitive tasks, and hazardous materials.

The supplier’s employees shall not be under the influence of alcohol or illegal drugs while working for ICT.

Business Ethics and Integrity

All suppliers must adhere to high standards of moral and ethical conduct, comply with all applicable laws and regulations and refrain from engaging in any form of corrupt practices, including anti-competitive activity. Business dealings must be handled with integrity, transparency and honesty. As a minimum, suppliers must:

Conduct their business in full compliance with all applicable competition and fair-trading laws at all times
Comply with ‘insider trading’ laws when in possession of information about ICT or another company that is not available to the investing public and that could influence an investor’s decision to buy or sell stock
Comply with all applicable environmental laws and regulations, including those relating to hazardous materials, air emissions, waste and wastewater discharges
Comply with anti-corruption and anti-bribery laws of the countries in which it does business, and not make any direct or indirect payments, including bribes, kickbacks or other promises of payments to foreign government officials or other third parties for the purpose of inducing the individual to misuse their position to obtain or retain business, receive improper benefits or other unfair or improper advantage
Disclose any actual, perceived or potential conflict of interest to ICT, including any employee or contractor of ICT who may have an interest or economic tie of any kind in the supplier’s business
Maintain transparent and accurate financial and business records to demonstrate compliance with applicable laws and regulations, as well as generally accepted accounting principles. Such information must be disclosed without falsification or misrepresentation to appropriate parties as required

Information and Cyber Security

All suppliers shall commit to protecting the reasonable privacy expectations of personal information of everyone they do business with, including suppliers, customers, consumers and employees.

At a minimum, suppliers are required to:

Protect confidential and proprietary information from unauthorized access, destruction, use, modification and disclosure, through appropriate physical and electronics security procedures.
Comply with applicable privacy and information security laws and regulatory requirements when any personal information is collected, stored, processed, transmitted, and shared.
Notify us immediately if they identify any security vulnerabilities, potential weaknesses, or incidents that might affect ICT or the quality of their services to us.

Commercial Sustainability

We expect suppliers to be transparent about their social, environmental and economic sustainability practices, and value those that contribute to our development of a sustainably aware supply chain.

Suppliers should actively pursue opportunities for continuous improvement and development of process efficiencies in product and service delivery. This may include minimization of waste, collaboration, ongoing innovation and market developments and total cost reduction.

Corporate Social Responsibility

We encourage our suppliers to be good corporate citizens and contribute positively to our communities. This could include:

Paying their subcontractors promptly
Engaging subcontractors or businesses from their local region as part of the supply chain
Consciously seeking to support or provide meaningful benefit to socially disadvantaged groups and/or local communities as a normal part of their day-to-day business approach.

Application of the Code

We expect our suppliers to meet, or work towards meeting, this code. We recognize that we have a broad range of suppliers in terms of size, capability, capacity, and maturity. We also recognize that aspects of the code may not be relevant to all our suppliers, depending on their products and services, or the sector in which they operate.

Where any part of this code is not able to be met, the supplier must notify us promptly.
Appropriate documentation which supports a supplier’s conformity with this code should be available on request.
We expect suppliers to work collaboratively with ICT to address any corrective action and/or build the capability to meet the expectations outlined in this code.
Suppliers who – given reasonable time and support – do not meet our expectations, may not be considered for future contracts.
We expect our suppliers to complete due diligence on their own suppliers, consistent with expectations outlined in this code.