Supplier Code of Conduct
COMPANY COMMITMENT
At the Cyncly Group including all affiliates (the "Company" or "we"), we are dedicated to uphold and maintain the highest standards of ethical conduct, respect for fundamental human rights, and the promotion of decent working conditions within our global supply chain. We extend this commitment to our suppliers and business partners (hereinafter collectively referred to as "suppliers") through this Supplier Code of Conduct along with the Cyncly Global Code of Conduct and the Global Whistleblowing Policy. The Supplier Code of Conduct outlines our expectations for responsible business behaviour, adherence to fundamental human rights and adherence to decent working conditions. It is our firm belief that through collaborative efforts, we can – together with our suppliers – create a positive impact on communities, workers and the environment.
STANDARDS
1. RESPECT FOR FUNDAMENTAL HUMAN RIGHTS AND DECENT WORKING CONDITIONS
1.1 Introduction
The supplier must respect and uphold decent working conditions of their employees and must respect internationally recognized fundamental human rights, as outlined in the Cyncly Global Code of Conduct, the United Nations Universal Declaration of Human Rights and the International Labour Organization (“ILO”) Convention. This includes i.a. ensuring the elimination of child labour, forced labour, discrimination, and any form of harassment or abuse within the workplace.
1.2 Prohibition of child labour
The Company strongly opposes all forms of child labour. The supplier must maintain a strict zero tolerance policy for child labour within their own operations and throughout their supply chain. The supplier's commitment to access to employment should adhere to the following stipulations:
- The absolute prohibition of the worst forms of child labour.
- Compliance with the minimum age for employment, as defined by the relevant national law, which must be at least 18 years.
- Special protection for individuals under the age of 18, considering them as minors and safeguarding them from work that could jeopardize their health, safety, or morals, including overtime and night shifts.
We prefer suppliers who actively work to eradicate child labour from their sphere of influence, for example, through collaboration with other suppliers and NGOs or support for educational initiatives.
1.3 Prohibition of forced labour
The Company categorically rejects all forms of forced labour. The supplier must not condone forced or compulsory labour, modern slavery, bonded labour, human trafficking, domination, or oppression within their own operations and within their supplier network. This encompasses:
- The prohibition of work or services obtained under the threat of punishment or without voluntary consent.
- A commitment to avoiding the use of force, deception, intimidation, excessive fees, or forced labour as a disciplinary measure in the recruitment, hiring, and employment of workers.
- Ensuring third parties involved in employee recruitment or protection adhere to this prohibition.
We prefer suppliers who actively strive to eliminate forced labour in their sphere of influence, possibly through collaboration with other suppliers and NGOs. Suppliers should pay close attention to indicators of forced labour, including non-payment of wages, restrictions on freedom of movement, withholding of passports, intimidation, unacceptable working and living conditions and excessive overtime.
1.4 Freedom of association and the right to collective bargaining
Workers shall, without exception, have the right to join or establish trade unions at their own request, and to bargain collectively. The employer shall not interfere in, hinder or oppose trade unions or collective bargaining.
Workers' representatives shall not be discriminated and shall have access to carry out their representative functions in the workplace.
Where the right to freedom of association and/or collective bargaining is restricted under law, the employer shall facilitate, and not hinder, the development of alternative forms of independent and free workers representation and negotiations.
1.5 Discrimination
There shall be no discrimination in respect of treatment, exclusion or preference based on, including not making any employment-related decisions based upon a person’s race, culture, colour, gender, national origin, age, religion, citizenship status, disability, medical condition, sexual orientation, pregnancy, leave in connection with childbirth or adoption, care responsibilities, marital status, trade unionism, political affiliation or any other basis protected by law.
Protection shall be established against sexually intrusive, threatening, abusive or exploitative behaviour, and against discrimination or termination on unjustified grounds, e.g. marriage, pregnancy, parenthood or status as HIV-infected.
1.6 Health and Safety
The supplier is expected to provide safe, healthy, and dignified working conditions for their employees. This encompasses fair wages, reasonable working hours, access to healthcare, and adherence to occupational health and safety standards. Workers should be treated with respect and dignity at all times.
The working environment shall be safe and hygienic, bearing in mind the prevailing knowledge of the industry and of any specific hazards. Hazardous chemicals and other substances shall be carefully managed. Adequate steps shall be taken to prevent accidents and injury to health arising out of, associated with, or occurring in, the course of work, by minimizing, so far as is reasonably practicable, the causes of hazards inherent in the working environment.
The supplier commits to the following protective measures:
- Proper labelling, safe storage, and responsible handling of hazardous or toxic substances.
- Maintenance of safe workplace conditions, work equipment, tools, machines, and devices.
- Provision of necessary personal protective equipment and machine safety devices, ensuring their readiness for use.
- Implementation of adequate measures to protect against building collapse, fire, adverse environmental conditions, or unauthorized access.
- Availability and accessibility of escape and rescue routes, along with emergency equipment, including first aid and emergency treatment.
- Maintenance of a hygienic working environment with a minimum level of order and cleanliness.
- Adequate training and instruction for employees.
The supplier shall respect the human rights of their employees, and shall comply with laws and regulations regarding decent working conditions. With regard to general working conditions such as working hours, remuneration and other fundamental working conditions, the supplier must comply with the applicable national regulations and promote a constructive exchange with employee representatives.
We expect that our suppliers will maintain an active view on the inherent risks of modern slavery in their supply chain and will conduct necessary due diligence.
2. ENVIRONMENTAL PROTECTION
The supplier shall operate in an environmentally responsible and efficient manner throughout our operations. The supplier shall comply with all applicable environmental regulations and engage in activities aimed at reducing water usage, energy consumption and greenhouse gas emissions. The supplier shall be committed to having systems in place to ensure the safe handling, movement, storage, recycling, reuse or management of waste, air emissions and wastewater discharges during our operations.
3. CORPORATE GOVERNANCE
3.1 Business ethics and competition
The supplier shall act honestly in all their business affairs and ensure that their employees and suppliers conduct themselves accordingly. The supplier shall truthfully market and promote their products, services, and solutions, and make only fair, fact-based comparisons between their products, services, and solutions and those of their competitors. The supplier shall not mislead, misrepresent, or misstate the facts. The suppliers shall deal fairly with their own suppliers and competitors at all times.
No employee or representative of the supplier should engage in any sort of illegal or unethical conduct. In particular, the supplier must follow antitrust and competition laws when doing business. The objective of these laws is to ensure effective protection of competition by prohibiting (i) formal and informal agreements and/or concerted practices, including information exchange, and (ii) unilateral conduct by dominant undertakings that prevent, restrict or distort competition. Accordingly, the supplier shall not discuss or reveal any commercially sensitive information with competitors, even casually: especially not (i) the division or allocation of markets, territories, clients or products and services; (ii) price or price-related information; (iii) limitation of output or sales; or (iv) the boycotting of a supplier, customer or another third-party. Any kind of agreement or understanding with competitors to restrict competition is strictly prohibited.
Whenever the supplier is involved in trade association activities or in other situations where there is communication among competitors, customers or suppliers, they must be especially alert to ethical and legal requirements and will not conduct themselves in a manner that is unfair or anti competitive.
3.2 Anti-bribery and corruption
The supplier shall have a zero-tolerance policy towards any form of corruption or bribery. It shall not be obtained any business advantage through bribery, improper payments or any other illegal means. The supplier shall not accept, offer or give, directly or indirectly (e.g. through third parties), anything of value to any person or organisation, whether public officials or not, to obtain or retain any undue advantage. The supplier shall at all times comply with all applicable international and national laws, regulations and codes that prohibit any form of corruption. We expect all our suppliers to uphold the above-mentioned standards and immediately report any dealings which could be viewed as corruption and bribery of which they may become aware, through the following channels:
(i) to make an oral report visit: https://whistleblowersoftware.com/secure/9a45e341-d9c3-414d-846c-cfb727417b67;
(ii) to make a written report visit: https://whistleblowersoftware.com/secure/9a45e341-d9c3-414d-846c-cfb727417b67;
(iii) to make a report in person visit: https://whistleblowersoftware.com/secure/9a45e341-d9c3-414d-846c-cfb727417b67.
Please refer to the Global Whistleblowing Policy for more information.
3.3 Whistleblowing/reporting
We are committed to conducting all of our business activities ethically, in accordance with applicable laws and regulations, and to the highest professional standards. We recognise that effective and honest communication is essential if concerns about breaches or failures of law are to be effectively dealt with and the Company’s success ensured.
Any activity violating this Supplier Code of Conduct or applicable laws may negatively affect the Company’s brand and stakeholders’ trust in the Company and may cause significant business, personal and social risks. It is the duty of each supplier to immediately report any concerns or detected violations.
We prohibit any form of retaliation for good faith reporting of a potential or actual violation of this Supplier Code of Conduct, our Company’s requirements or applicable laws. There will be no discrimination or repercussions against anyone for making a report in good faith of actual or suspected non-compliance. Reports will be treated confidentially and anonymously to the extent permissible by law and if requested.
Reference is made to the Global Whistleblowing Policy which provides further guidance on how to report any concerns or detected violations.
4. MISCELLANEOUS
4.1 Data protection and privacy
We expect each supplier to prevent disclosure of confidential information and to protect access to Company data.
A supplier that processes personal data on our behalf shall not disclose personal information they have accessed without lawful justification. These suppliers must also ensure that personal data is not transferred outside of the applicable territory to other countries without an adequate level of protection or our consent. The supplier have an obligation to take all reasonable precautions to protect personal data against loss, theft, misuse, unauthorised access, disclosure, alteration or destruction.
4.2 Social media communications
We encourage all our suppliers to support our business strategies by becoming ambassadors of our organisation while remembering that social media refers to any communication in the public eye, written, photographed, or recorded, that enables users to create and share content or to participate in social networking.
We require suppliers using social media sites to refrain from making any comments or engage in discussions which could adversely affect the Company or the Company’s reputation, or that of our customers and suppliers.
Please refer to the Cyncly Global Code of Conduct for additional details on how to handle social media communications.
4.3 Responsible procurement
For the Company, sustainable procurement means paying attention to their impact on the environment and society when selecting products, services and suppliers. We expect our suppliers to align their own procurement activities with these principles. The supplier must ensure that they comply with all applicable laws and regulations in their procurement activities.
The supplier must have appropriate measures to pass on the requirements of this Supplier Code of Conduct to his or her own suppliers. We prefer suppliers who promote responsible sourcing within their sphere of influence by identifying and assessing potential human rights and environmental risks in the supply chain and, if necessary, taking measures to avoid or mitigate them.
4.4 Sanctions
We are committed to strict compliance with all applicable U.S. and non-U.S sanction laws. We are prohibited from selling any Company products or services to or procuring products or services from a country or region that is subject to a comprehensive embargo under the trade control laws of the U.S, Canada, UK and Europe.
In order to comply with U.S. Department of the Treasury Office of Foreign Assets Control’s (“OFAC”) sanctions, the Company is prohibited from engaging in transactions with the following foreign countries and regions: Cuba; Iran; North Korea; Syria; Russia; Crimea, Donetsk and Luhansk regions of Ukraine; and Venezuela (limited to the Government of Venezuela).
OFAC maintains additional lists, collectively known as the Consolidated Sanctions List, which combines a number of other OFAC lists that impose prohibitions different than those imposed by the SDN list. A combined, searchable list including all OFAC-restricted parties can be found at https://sanctionssearch.ofac.treas.gov/.
In general, the supplier shall not assist or otherwise participate in transactions with another entity that involves an OFAC-restricted party or country. The supplier must be vigilant in ensuring, as far as possible, that no dealing with any persons or entities on the above-mentioned lists is conducted. If you have concerns regarding any transaction you are involved in or are aware of, please immediately report these through the following channels:
(i) to make an oral report visit: https://whistleblowersoftware.com/secure/9a45e341-d9c3-414d-846c-cfb727417b67;
(ii) to make a written report visit: https://whistleblowersoftware.com/secure/9a45e341-d9c3-414d-846c-cfb727417b67;
(iii) to make a report in person visit: https://whistleblowersoftware.com/secure/9a45e341-d9c3-414d-846c-cfb727417b67.
Please refer to the Global Whistleblowing Policy for more information.