Supplier Code of Conduct
Our suppliers are critical to our success and in order to provide superior products and services in a responsible manner we require you to meet our expectations for ethics and compliance.
This Supplier Code of Conduct applies to all LeFiell suppliers. “Supplier” here means any business, company, corporation, person or other entity that sells, or seeks to sell, any kind of goods or services to LeFiell, including the supplier’s employees, agents and other representatives.
This Supplier Code of Conduct expresses the expectations we hold for our suppliers, and mirrors the standards we set for our own employees, board of directors and other business associates. Thank you for your shared commitment to meeting these principles.
Laws, Regulations and Contracts
Our suppliers must, at a minimum, perform all duties and expectations in compliance with all laws and regulations applicable to their business. Suppliers must comply with all flowdown terms, conditions, and other provisions specified in the LeFiell purchase order. When performing international business, or if the primary place of business is outside of the United States, suppliers must comply with local laws and regulations.
Environment
We expect our suppliers to operate in a manner that actively manages risk, conserves natural resources, and protects the environment. We expect our suppliers to apply environmental management system principles in order to establish a systematic approach to the management of risks/hazards and opportunities associated with the environment, including potential risk from regulatory non-compliance, reputational loss, and opportunities for business growth through operational and product stewardship.
Employee, Health & Safety
We expect our suppliers to comply with applicable safety and health laws, regulations, policies, and procedures. Suppliers should provide for the health, safety, and welfare of their people, visitors, and others who may be affected by their activities.
Harassment
We expect our suppliers to ensure that employees may perform their work in an environment free from physical, psychological and verbal harassment, or other abusive conduct.
Drug-Free Workplace
We expect our suppliers to maintain a workplace free from illegal drugs.
Anti-Corruption
We have a zero-tolerance policy for corruption, and prohibit anyone conducting business on our behalf, including suppliers, from offering or making any improper payments of money or anything of value to government officials, political parties, candidates for public office, or other persons. This includes the offer and/or receipt of any bribe or kickback to and/or from any customer, supplier or others. Our policy specifically prohibits facilitating payments (payments made to expedite or secure performance of a routine governmental action like obtaining a visa or customs clearance), but allows personal safety payments where there is an imminent threat to health or safety. Our suppliers must comply with the anticorruption laws that govern operations in the countries in which they do business.
Gifts/Business Courtesies
We compete on the merits of our products and services and do not use the exchange of business courtesies to gain an unfair competitive advantage. We expect the same of our suppliers in the offering or receipt of any gift or business courtesy, including cash and cash equivalents. In particular, note that our employees who are in any way involved in procurement decisions are subject to strict limitations, and may not accept any business courtesies, with the exception of very low value promotional items. In any business relationship, our suppliers must ensure that the offering or receipt of any gift or business courtesy is permitted by law and regulation; does not violate the rules and standards of the recipient’s organization; is consistent with reasonable marketplace customs; and will not adversely impact the reputation of LeFiell.
Fair Competition/Anti-Trust
We expect our suppliers to conduct business in accordance with all applicable anti-trust or anti-competition laws and regulations. This includes avoiding business practices such as entry into arrangements that unlawfully restrain competition; improper exchange of competitive information; price fixing, bid rigging, or improper market allocation.
Conflict Minerals
We expect our suppliers to not violate the conflict minerals policy established by the US Government.
Conflicts of Interest
We expect our suppliers to avoid all conflicts of interest or situations giving the appearance of a potential conflict of interest in their dealings with LeFiell. We expect our suppliers to report to LeFiell, any situations of potential or apparent conflicts between their personal interests and the interests of LeFiell.
Export/Import Control
We expect our suppliers to ensure that their business practices are in accordance with all applicable laws and regulations governing the export and import of domestic and foreign origin parts and components and related technical data.
Counterfeit Parts
We expect our suppliers to develop, implement, and maintain methods and processes appropriate to their products and services to minimize the risk of introducing counterfeit parts and materials into deliverable products. Effective processes should be in place to detect counterfeit parts and materials, and mark parts obsolete as appropriate.
Confidential / Proprietary Information
Our suppliers should take proper care to protect all sensitive information, including confidential, proprietary, and personal information. Information should not be used for any purposes beyond the scope of the business arrangement with our company, without prior authorization.
Accuracy of Records and Submissions
We expect our suppliers to accurately record and maintain business documentation, including but not limited to, accounting, manufacturing and quality reports that pertain to submissions to Lefiell, the customer or regulatory authorities. We also expect you to never make any entry in your books and records or alter, cancel or destroy any document to misrepresent any fact, circumstance or transaction related to Lefiell business.
Non-Discrimination
We expect our suppliers to provide equal employment opportunity to employees and applicants for employment without regard to race, ethnicity, religion, color, sex, national origin, age, military veteran status, ancestry, sexual orientation, gender identity or expression, marital status, family structure, genetic information, or mental or physical disability, so long as the essential functions of the job can be performed with or without reasonable accommodation.
Human Rights
We expect our suppliers to treat people with respect and dignity, encourage diversity and diverse opinions, promote equal opportunity for all, and help create an inclusive and ethical culture
Child Labor
We expect our suppliers to ensure that child labor is not used in the performance of work. The term “child” refers to any person under the minimum legal age for employment where the work is performed.
Human Trafficking
We expect our suppliers to not engage in the use of forced, bonded (including debt bondage) or indentured labor, involuntary prison labor, slavery, or trafficking of persons. This includes transporting, harboring, recruiting, transferring, or receiving vulnerable persons by means of threat, force, coercion, abduction, or fraud for the purpose of exploitation.
Reporting
Employees of our suppliers should have access to an adequate avenue of raising issues or concerns without fear of retaliation.
Codes of Conduct & Compliance
Commensurate with the size and nature of their business, we expect our suppliers to have management systems in place to support compliance with laws, regulations, and expectations related to or addressed expressly within the Supplier Code of Conduct. We encourage our suppliers to implement their own written code of conduct, and to flow down the principles of a code of conduct to the entities that furnish goods and services to the supplier.
For questions about this Code, please contact LeFiell Ethics & Compliance Office at ethics@lefiell.com