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Supplier Code of Conduct Kevin Dunlap 2018-08-02T11:37:58-04:00

Supplier Code of Conduct

CSP’s Code of Ethics and Anti-Corruption, Environmental Policy and Working Conditions Policy reflect our commitment to our employees and to the communities in which we live and work. CSP expects our suppliers to have similar programs in place, and to operate in a manner consistent with these standards.

Please review this “Supplier Code of Conduct.” CSP may end its relationship to any supplier who materially breaches these requirements.

Compliance
A supplier must, in all areas of its business operations, comply with all applicable laws, regulations and directives of the countries and regions in which it operates. Additionally, each supplier must ensure that its employees receive adequate information and training in relation to all relevant legal, regulatory and internal requirements that apply to their jobs.

Labor
Supplier will not engage in any form of forced labor. All work will be voluntary and all employees must be free to leave upon reasonable notice. Employees will not be required to surrender government-issued identification or documents to the supplier as a condition of employment.

Child labor is not to be used in any stage of manufacturing. The term “child” refers to any person employed under the age of 17 (or 16 where the law of the country permits), under the age for completing compulsory education, or under the minimum age for employment in the country, whichever is greatest. The use of workplace apprenticeship programs, which comply will all legal regulations, is supported.

Hours of work in workweeks and workdays are not to exceed the maximum set by local law. Compensation and benefits are to be provided in accordance with all applicable wage and benefit laws. The basis of an employee’s wages shall be communicated, paid timely and accurately documented.

The work environment must be free from harassment and unlawful discrimination and harsh and inhumane treatment of employees is prohibited.

Employees must have the right to join associations of their own choosing or to refrain from joining them, in accordance with local law. Suppliers must prohibit retaliation against any employee for communicating openly with management regarding conditions of employment.

Health and Safety
Employee exposure to potential safety hazards is to be eliminated wherever possible. Employees are to be provided with appropriate personal protective equipment. Employees must not be disciplined for raising health or safety concerns. Possible emergency events are to be identified and their impact minimized by contingency planning.

Physical guards, interlocks and barriers are to be provided and properly maintained for machinery used by employees in accordance with local legal and regulatory requirements.

Employees are to be provided with clean toilet facilities, access to potable water and sanitary food preparation and storage facilities.

Environmental
All required environmental permits and registrations are to be obtained, maintained and kept current and their operational and reporting requirements are to be followed.

Chemical and other materials posing a hazard if released to the environment are to be identified and managed to ensure their safe handling, movement, storage, recycling or reuse and disposal in accordance with applicable law.

Wastewater and solid waste generated from operations, industrial processes and sanitation facilities are to be monitored, controlled and treated as required prior to discharge in accordance with applicable law.

Air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting chemicals and combustion by-products generated from operations are to be characterized, monitored, controlled and treated as required by applicable law prior to discharge.

Products and materials sold or delivered to CSP are to be in compliance with laws and regulations regarding substance prohibition or restriction.

Quality
CSP is committed to providing best-in-class quality by delivering defect-free products to our customers. To meet our product quality requirements in all of our markets, we need the assistance of our suppliers. Specifically, CSP now requires its direct material suppliers to have a minimum of ISO9001:2015 registration. IATF-16949 registration is preferred.

Supply Chain Security and Business Continuity Plan
A comprehensive security and business continuity plan will be in place to preserve the safety of employees, protect physical property from loss and damage, safeguard intellectual property, protect the integrity of shipments at point of origin and prevent interruptions in the manufacturing process. Additionally, suppliers of tangible goods will have policies and processes in place that satisfy the requirements of the U.S. Customs Trade Partnership Against Terrorism (C-TPAT) program or similar guidelines set forth by foreign customs agencies. CSP may monitor adherence to these requirements through completion of an assessment.

Ethics
The highest standards of integrity are expected in all business interactions with a strict prohibition against all forms of corruption, extortion and embezzlement. Suppliers will comply fully with all applicable laws, including but not limited to the U.S. Foreign Corrupt Practices Act and other anti-corruption laws.

Suppliers will never pay, offer, promise, or authorize the payment, directly or indirectly, of any bribe or corrupt payment (in the form of money or anything of value) to anyone for the purpose of inducing or rewarding any favorable action or obtaining any improper advantage. Suppliers obtain and retain CSP’s business by providing the best product or service at the best price. An occasional business dinner is acceptable, but frequent or lavish entertainment must be avoided. We put the primary responsibility on our employees for ensuring adherence to these standards. However, we also expect you as a business partner to honor these standards by refraining from offering inappropriate entertainment to our employees.

Suppliers must protect all CSP Confidential Information entrusted to it by labeling it, keeping it secure and limiting access in accordance with applicable regulations and to those who have a need to know in order to do their jobs.

Intellectual property rights must be respected; transfer of technology is to be done in a manner consistent with applicable law and contractual property rights.

Standards of fair business, advertising and competition are to be upheld. CSP is committed to Supplier Diversity and we encourage our major suppliers to actively participate in our initiative by seeking Tier II relationships with qualified diverse businesses.

Supplier must maintain a process for employees to raise issues of concern in a confidential manner. Suppliers must ensure that the employee’s confidence is maintained and must protect the employee from retaliation.

Community engagement is encouraged to help create improved social and economic development.

Monitoring
A supplier shall provide to CSP reasonable access to information and facilities for purposes of assessing and monitoring the supplier’s performance to this Code. A supplier will immediately notify CSP of any known material breach of this Code and its proposed corrective action plan.

Revised 8/1/2018

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