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Kurt J. Lesker Company® Supplier Code of Conduct


Introduction:

This Supplier Code of Conduct (the “Code”) contains principles on how Kurt J. Lesker Company and its affiliates (hereinafter “KJLC”) expect its suppliers, vendors and other service providers (hereinafter, collectively “Supplier” or “Suppliers”) to do business.

KJLC expects its Suppliers to obey all laws and regulations applicable in the jurisdictions in which the Supplier conducts its business. Additionally, KJLC expects its Suppliers to conduct themselves in an ethical and professional manner in all of their business dealings. These expectations extend not only to the Supplier and all of its employees, but also, if applicable, to its parent company, affiliates, and subsidiaries. Further, the Supplier should implement its own code of conduct within its supply chain, based upon principles of a substantially similar nature as those contained herein.

KJLC expects its Suppliers to commit to the following principles:

Labor & Employment

  • Freely Chosen Employment
    • Forced, bonded or indentured labor or involuntary prison labor shall not be used.
  • Child Labor Avoidance
    • Child labor is not to be used.
  • Human Trafficking
    • Suppliers will adopt measures to identify and prevent human trafficking within their facilities and will monitor their supply chain for such practices.
  • Working Hours
    • Hours worked in any given week must not exceed the applicable legal requirements of the jurisdiction in which the work is being performed.
  • Wages & Benefits
    • Compensation paid to workers shall comply with all applicable wage laws.
  • Humane Treatment
    • Workers shall not be subject to harsh or inhumane treatment, including sexual harassment, sexual abuse, corporal punishment, mental or physical coercion or verbal abuse; nor is there to be the threat of any such treatment.
  • Non-Discrimination
    • In carrying out hiring and promotion practices, there shall be no form of discrimination based on race, color, age, gender, gender identity, sexual orientation, ethnicity, disability, pregnancy, religion, political affiliation, union membership or marital status.

Health, Safety & the Environment

  • Occupational Safety
    • Worker exposure to potential safety hazards are to be controlled through proper design, engineering and administrative controls, preventative maintenance, safe work procedures and ongoing safety training. If and when appropriate, workers are to be provided with well-maintained, properly-fitted personal protective equipment (“PPE”). Workers shall not be disciplined for raising safety concerns.
  • Environmental Permits & Reporting
    • All required environmental permits, approvals and registrations are to be obtained, maintained and kept current. Operational and reporting requirements contained therein are to be strictly followed.
  • Pollution Prevention & Resource Reduction
    • Measures should be taken to reduce waste, including of water and energy. Local laws concerning the disposal and/or recycling of plastics, glass, aluminum, batteries, electronics or other materials must be followed. Pollution prevention measures will be implemented by Supplier, including adherence to applicable emissions control regulations.
  • Hazardous Substances
    • Chemicals and other materials posing a hazard if released into the environment are to be identified and managed to ensure their safe handling, movement, storage, use, recycling or reuse, and disposal.

Ethical Business Practices

  • Business Integrity
    • Compliance with the highest standards of integrity in all business transactions is expected. Suppliers shall not engage in nor shall they permit their agents or subcontractors to engage in any form of corruption, bribery, extortion or embezzlement. Suppliers must comply with all applicable anti-corruption and anti-bribery laws and regulations in place in each and every jurisdiction in which they conduct business. Such compliance may include, but is not necessarily limited to, the anti-corruption and anti-bribery laws and regulations of the United States of America including, without limitation, the Foreign Corrupt Practices Act; and the anti-corruption and anti-bribery laws and regulations of the United Kingdom including, without limitation, the Bribery Act 2010.
  • Intellectual Property
    • Intellectual property (“IP”) rights belonging to a party with whom Supplier conducts business are to be respected. Any use by Supplier of technology and know-how owned by another party must be carried out in a manner that protects the IP rights of that party and only in accordance with and to the extent permitted by a non-disclosure and/or IP agreement in place between Supplier and that party.

Government Contracting, Export Control, & OFAC

  • U.S. Government Contracts
    • To the extent that a Supplier supplies goods or services to KJLC in support of government contracts, KJLC expects the Supplier to fully comply with all applicable government contracting rules and regulations, including but not limited to the applicable Federal Acquisition Regulations (“FAR”) and the Department of Defense FAR Supplements (“DFARS”).
    • KJLC is a federal contractor obligated to take affirmative action to employ women, minorities, disabled individuals, and veterans. KJLC is also required to inform those with whom it conducts business that they, too, may have such obligations. Supplier should know that, by operation of law, as well as by this notification, the Equal Employment Opportunity Clause required under Executive Order 11246, (41 C.F.R. 60-1.4), the affirmative action commitment for special disabled veterans and veterans of the Vietnam Era set forth in 41 [C.F.R. 60-300.44(f)(1)(ii)], the Affirmative Action Clause for Section 503 of The Rehabilitation Act of 1973 set forth in 41 [C.F.R. 60-741.44(f)(1)(ii)], and the related regulations of Secretary of Labor, (41 C.F.R)., Chapter 60, are incorporated in all of KJLC’s contractual relationships with Supplier and others. This notification does not necessarily mean that Supplier’s business has any or all of the affirmative action obligations referenced above. This will depend upon a number of factors, including the dollar amount of the relevant transaction(s) and the size of Supplier’s workforce. This provides that if the laws' jurisdictional requirements are met, Supplier will abide by any and all of its affirmative action responsibilities. The governing agency on affirmative action requires that KJLC maintain documentation to show that KJLC is in compliance with the law itself. Therefore, Supplier will provide KJLC with documentation as to Supplier’s compliance with these federal requirements upon KJLC’s reasonable request.
  • Export Control
    • To the extent applicable to the business in which a Supplier is engaged, KJLC expects the Supplier to comply with all applicable export controls laws and regulations, including but not limited to the United States’ International Traffic in Arms Regulations and Export Administration Regulations.
  • Certification Relating to OFAC Sanctions
    • Supplier certifies to KJLC that it is not a U.S. government restricted or sanctioned party, including but not limited to a party restricted or sanctioned by the United States Department of Treasury’s Office of Foreign Assets Control (“OFAC”). Further, Supplier certifies that it is not owned in the aggregate 50% or more by persons or entities restricted or sanctioned by OFAC.
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