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Supplier Liability Policy

Scintilla is committed to working with its suppliers to build and maintain a sustainable supply chain. An essential part of this is the supplier liability policy. Our Code of Ethics, Occupational Health and Safety Policy, Labor Regulations and Environmental Policy ensure that Scintilla complies with all applicable laws and regulations.

Scintilla Supplier Liability Policy sets out standards to ensure that suppliers ’working conditions are safe, that employees are treated with respect and dignity, and that operational processes are environmentally responsible.

The Supplier Liability Policy includes compliance with the following four sections, in accordance with the laws, rules and regulations of the countries and regions in which the Company operates. The policy encourages suppliers to go beyond legal compliance to promote social and environmental responsibility, relying on internationally recognized standards.


I. Labour


Suppliers are committed to respecting the human rights of their employees and treating them with dignity and respect.


I/1. Free choice of employment

Forced or involuntary work must not be used. All work is voluntary and employees must be free to leave after reasonable notice. Employees are not required to hand over their identity documents as a condition of employment.


I/2. Young workers

Child labor must not be used at any stage of production. The term “child” refers to any person under the age of 15, either below the age limit for completion of compulsory education or below the applicable minimum age in the country, whichever is greater. The use of legal and compliant workplace learning programs is encouraged. Workers under the age of 18 (young workers) must not perform work that could endanger their health or safety, including night shifts and overtime.


I/3. Working hours

The working week, including overtime, may not exceed the number of working hours permitted by law. Employees must be granted at least one day off per seven-day week and be offered time off in accordance with applicable laws and regulations.


I/4. Wages and benefits

Compensation paid to employees must comply with all applicable wage laws, including legislation on minimum wages, overtime and statutory benefits. Deduction of disciplinary wages must comply with local laws.


I/5. Humane treatment

There shall be no cruel or inhuman treatment, including sexual harassment, sexual abuse, corporal punishment, mental or physical coercion, verbal abuse of workers or unreasonable restrictions on entering or leaving the facilities provided by the company.


I/6. Non-discrimination

Suppliers must commit to a workforce free from harassment and unlawful discrimination. Companies may not discriminate on the basis of race, color, age, gender, sexual orientation, ethnicity, disability, religion, political affiliation, trade union membership or marital status in recruitment and employment practices, such as promotion, reward and access to training.


I/7. Freedom of association

Open communication and direct contact between employees and management is the most effective way to solve workplace problems. Suppliers must respect the right of workers to freely join, join unions, be represented or join workers’ councils in accordance with local law. They should support the conclusion of a collective agreement with their employees. Employees should be able to communicate openly with management about working conditions without fear of retaliation, intimidation or harassment.


II. Health and safety


Suppliers recognize that integrating sound health and safety management practices into all aspects of business is essential to maintaining product and service quality, production consistency, and employee morale.


II/1. Occupational safety

Workers’ exposure to occupational safety hazards (eg electrical and other energy sources, fire, vehicles, machinery, slipping, falling and falling) must be controlled by appropriate design, technical and administrative checks, preventive maintenance and safe working procedures. Machinery used by workers must be provided with physical guards, latches and handrails and properly maintained. Hazardous energy sources should be monitored during maintenance or commissioning activities to prevent unexpected starting or accidental release of energy that could pose a serious hazard to workers. Where hazards cannot be adequately controlled by these devices, workers must be provided with appropriate personal protective equipment.


II/2. Emergency preparedness

Emergencies and incidents should be identified and assessed and their impact minimized through the implementation of emergency plans and response procedures, including: emergency reporting, employee notification and evacuation procedures, employee training and exercises, appropriate fire detection and response equipment, appropriate exit facilities and recovery. plans.


II/3. Chemical effects

Workers’ exposure to chemicals must be identified, assessed and monitored. If the hazards cannot be adequately controlled by technical and administrative means, workers must be provided with appropriate personal protective equipment.


II/4. Strenuous work

The tasks of workers exposed to physical stress, including manual handling and heavy lifting, prolonged standing and extremely repetitive or heavy assembly tasks, must be identified, assessed and monitored.


II/5. Machine protection

Manufacturing and other machinery must be assessed for safety risks. Physical guards, latches and handrails shall be provided and properly maintained if the machinery presents a risk of injury to workers.


II/6. Hygiene, food and accommodation

Workers must be provided with clean toilets, access to drinking water and facilities for preparing and storing health food. Workers’ accommodation provided by suppliers must be clean, safe, have an emergency exit, adequate heat and ventilation, and reasonable personal space.


III. Environment


Suppliers recognize that environmental responsibility is an integral part of their business practices and that adverse impacts on the environment and natural resources must be minimized while protecting the health and safety of the public.


III/1. Environmental permits and reports

All necessary environmental permits (e.g., emission monitoring) and registration must be obtained, maintained and kept up to date, and their operational and reporting requirements complied with.


III/2. Pollution prevention and resource reduction

Waste from all types and uses of natural resources (including water and energy) must be reduced or eliminated at source or through practices such as modification of production, maintenance and installation processes, exchange, preservation, recycling and recycling of materials.


III/3. Hazardous substances

When released into the environment, hazardous chemicals and other substances must be identified and handled in accordance with applicable laws or regulations to ensure their safe handling, handling, storage, recycling or reuse and disposal.


III/4. Sewage and solid waste

Sewage and solid waste from operations, industrial processes and hygiene facilities must be inspected and treated in accordance with the laws or regulations in force before discharge or disposal.


III/5. Air emissions

Emissions to air of volatile organic chemicals, aerosols, corrosive substances, particles, ozone-depleting chemicals and combustion by-products from operations shall be characterized, controlled, controlled and managed as necessary before release.


III/6. Material Restrictions

Suppliers must comply with all applicable laws and regulations that prohibit or restrict certain substances, including labeling laws and regulations for recycling and disposal.


III/7. Energy consumption and greenhouse gas emissions

Energy consumption and greenhouse gas emissions should be monitored and documented at facility and / or company level. Participants should look for cost-effective ways to improve energy efficiency and minimize energy consumption and greenhouse gas emissions.


IV. Ethics


In order to fulfill their social responsibilities and achieve market success, suppliers must adhere to the highest ethical standards.


IV/1. Business integrity

The highest level of integrity is expected in all business interactions. All forms of corruption, extortion and embezzlement are strictly prohibited, resulting in immediate termination and legal action.


IV/2. Conflicts of interest

A conflict of interest is when there is a family or other private relationship between persons in a business relationship (owners of companies, subcontractors, executives, but also other employees) that may adversely affect their work decisions for one of their companies. Actual or potential conflicts of interest must be reported to the employer..

The company’s management and employees must show loyalty to the company and behave with suppliers, customers, and others in a way that avoids even the appearance of their personal interests conflicting with the company’s interests.


IV/3. Unjustified advantage

Bribes or other means of obtaining an unjustified or inappropriate advantage should not be offered or accepted.


IV/4. Disclosure of information

Confidentiality is extremely important in supplier relationships. Information on business activities, structure, financial condition and performance shall be disclosed in accordance with applicable regulations and prevailing industry practice. Confidentiality agreements (NDAs) must be entered into before conducting any business.


IV/5. Intellectual property

Intellectual property rights must be respected; the transfer of technology and know-how takes place in a way that protects intellectual property rights.


IV/6. Fair business, advertising and competition

The standards of fair trade, advertising and competition must be respected. Devices to protect customer data must be available.


IV/7. Responsible sourcing of minerals

Suppliers must ensure that their products are non-conflicting, ie do not contain metals from “conflict minerals”. It may not, directly or indirectly, fund armed groups through mining or the mineral trade. Suppliers need to establish policies, screening frameworks and management systems designed to achieve this goal. Suppliers should also audit their supply chain at regular intervals to make sure their suppliers are in compliance with the conflict-free program.


IV/8. Whistleblowing and protection against retaliation

Whistleblower is any person who makes a disclosure about improper conduct by an employee or officer of a company. Supplier must ensure the protection of  whistleblower confidentiality are to be maintained.


IV/9. Privacy

Suppliers must comply with data protection and information security laws and regulatory requirements when collecting, storing, processing, transmitting and sharing personal information.


V. Upstream supplier management


In order to maintain a sustainable supply chain, suppliers must forward these requirements towards their suppliers.