Supplier Code of Conduct

Supplier Code of Conduct

Scope

This Policy establishes a Code of Conduct for current and potential Gianetti Suppliers. Gianetti Suppliers include vendors, manufacturers, contractors and sub-contractors registered with Gianetti  and seeking to provide goods, services or personnel (including consultants) to Gianetti or all other parties with whom Gianetti Suppliers may contract on Gianetti’s behalf.  The term Gianetti herein includes Gianetti and its Subsidiaries.

Intent

Gianetti is committed to conducting its business in an ethical, legal, safe, environmentally and socially responsible manner. Gianetti requires its Suppliers to share this commitment and therefore, has established this Supplier Code of Conduct. Gianetti requires its Suppliers to consistently meet the following requirements in order to do or continue to do business with Gianetti.

Code of Conduct

Compliance with Laws, Codes and Regulations

Gianetti Suppliers must comply with all applicable laws, codes and regulations as set forth in applicable procurement documents and agreements (including, but not limited to, proposals, invitations to bid, solicitations and resulting contractual and purchasing agreements).

Environmental, Health and Safety Practices

It is the responsibility of the Supplier to ensure that its facilities are designed and safely operated in compliance with applicable law and that they do not present unnecessary risks to the environment or to the public. Gianetti Suppliers shall maintain safe, sanitary and healthy environments for all their employees at all job sites.

Such compliance shall include, among other things:

    • Obtaining and maintaining environmental permits.
    • Proper handling and disposition of hazardous materials.
    • Monitoring, controlling, and responsibility treating discharges generated from operations.
    • Conducting appropriate employee safety training and providing adequate safety equipment.
    • Maintaining records of safety training and monitoring safety performance.
    • Ensuring Suppliers’ employees comply with applicable health and safety rules and regulations and perform their duties and work in a manner which will not endanger themselves or others.

Ethical Business Practices

Gianetti and its Suppliers shall conduct their businesses in accordance with the highest standards of ethical behavior.  Suppliers are expected to conform to these requirements in each of the following areas:

Fair Trade Practices

Suppliers shall not engage in collusive bidding, price discrimination anti-competitive or other unfair trade practices.

Ethical Sourcing

Suppliers shall source goods or services from others that meet, as a minimum, country or origin standards for health and safety, working hours, pay, employment conditions and environmental protection.

Human Rights

Within its sphere of influence, Gianetti supports and respects protection of internationally proclaimed human rights and ensures it is not complicit in human rights abuses.  Neither any form of forced, compulsory or child labor nor any form of human trafficking or procurement of commercial sex acts is tolerated within Gianetti or Gianetti’s supply chain.

Conflict Minerals Statement

Gianetti supports the Dodd-Frank Wall Street Reform and Consumer Protection Act and the intended purpose of Section 1502 to ensure that Gianetti’s products do not contain conflict minerals that directly or indirectly contribute to the armed conflict in the Democratic Republic of Congo (DRC) and its nine surrounding countries.   Gianetti intends to fully comply with all the requirements of this Act.  We expect our suppliers to fully comply as well.

Please direct all inquiries to:  conflictmaterials@accuridecorp.com

Accuride is registered on the I Point Conflict Minerals Platform under the registration ID# 7457.    Accuride collects and reports conflict mineral information using the EICC-GeSi template.

Relationships and Communications

Gianetti Business Ethics Policy is that all transactions are to be conducted fairly, honestly and with integrity, according to the highest ethical standards.  Abuse or violation of this ethics policy is considered dishonesty.

Suppliers and their personnel shall avoid even the appearance of unethical or compromising practices in relationships, actions or communications with regard to existing or proposed business relationships with Gianetti.

Suppliers shall not encourage or utilize current or former Gianetti employees to disclose or provide any confidential, proprietary, or other restricted business information obtained while in Gianetti’s service to influence Gianetti’s existing or proposed commercial transactions for the purpose of gaining a commercial advantage or to otherwise damage Gianetti’s interests. Gianetti will take the necessary measures to detect any such improper business practices and will take appropriate action against current or former employees and Suppliers who violate these restrictions.  Suppliers shall be expected to cooperate with Gianetti investigations and provide reasonable assistance as requested.

Bribery, Kickbacks and Fraud

No funds, assets or services shall be paid, rendered, loaned or promised for payment or otherwise dispersed by Suppliers or their representatives as bribes, “kickbacks” or other payments designed to influence or compromise the conduct of Gianetti or its representatives.

Gifts, Gratuities and Hospitality

Suppliers and their personnel shall not offer or provide Gianetti or its personnel with gifts, gratuities or hospitality unless it involves nominal value and is in line with customary business practices.  Nominal gifts are described as gifts of a general nature having a low value, including such items as logo inscribed pens, caps, shirts and coffee mugs.  Customary business practice in terms of hospitality would include the acceptance or reasonable business entertainment and business meals.  Gifts, gratuities and hospitality offered or extended by Suppliers to Gianetti personnel which exceed nominal value or reasonable hospitality are reportable under internal Gianetti policies and regulations.

For the avoidance of any doubt, Gianetti pays for its employees business expenses, Suppliers are not required or requested to incur or reimburse business expenses for Gianetti employees.

Monitoring and Compliance

Suppliers shall conduct periodic internal reviews and inspections to ensure their compliance with this Supplier Code of Conduct and its applicable requirements.  If a Supplier identifies areas of non-compliance, the Supplier is expected to notify Gianetti Procurement & Logistics Department as to its plans to remedy any such non-compliance.

Gianetti or its designated representatives may engage in periodic monitoring activities to confirm Suppliers’ compliance with this Supplier Code of Conduct, including on-site inspections of facilities, use of questionnaires, review of publicly available information, or other measures necessary to assess Supplier performance and compliance.  The Supplier performance assessment will be used as a factor in the selection of bidders, or restrict Supplier access to new Gianetti business opportunities.

Suppliers are responsible for ensuring that the standards and requirements of this Code are communicated and understood by their personnel working on or in support of Gianetti projects, jobs, contracts, agreements and orders.  Suppliers will be held responsible for the conduct and actions of their employees.

The implementation of this Policy is a shared responsibility between Gianetti and its Suppliers.

Suppliers are to promptly disclose to Gianetti, on a confidential basis, all current and potential incidents which give rise to the appearance of conflicts of interest and instances of illegal, unethical or fraudulent behavior by any party, including Supplier employees or Gianetti employees, related to any of Gianetti’s procurement and contracts business.  Suppliers are to cooperate with Gianetti in any inquiries or investigations pertaining to past, current or potential instances of apparent unethical or fraudulent behavior or conflicts of interest related to any Gianetti business activity.

Gianetti Supplier employees that become aware of violations of this Policy are obligated to notify Gianetti.  Supplier employees are to report violations and irregularities directly to their internal Supply Chain Management.  Based on the assessment of information made available to Gianetti, Gianetti reserves the right (in addition to all other legal and contractual rights) to disqualify any potential Supplier or terminate any relationship with a current Supplier found to be in violation of this Supplier Code of Conduct, without liability.

Application

This Supplier code of Conduct is a general statement of Gianetti’s expectations and requirements with respect to its Suppliers.  This Policy should not be read in lieu of, but in addition to, any Supplier obligations set forth in a) requests for proposals, invitations to bid or other solicitation documents, or b) agreement by and between Gianetti and the Supplier.  In the event of a conflict between this Policy and any Gianetti solicitation documents or applicable agreements, the terms of Gianetti’s applicable solicitation documents or agreements shall prevail.  The requirements of this policy are not subject to waiver.  Neither Gianetti, its Suppliers nor their personnel or representatives are authorized to propose or approve conduct inconsistent with this Code of Conduct.