E.I. Microcircuits, Inc. Supplier Code Of Conduct

E.I. Microcircuits, Inc. values integrity and ethical business conduct, and E.I. Microcircuits expects that our suppliers are committed to these same values. This Supplier Code of Conduct (the “Code”) briefly summarizes our expectations for our suppliers, all of which are in line with our corporate values.

General Disclaimer: The expectations set forth in this Code are not intended to conflict with or modify the terms and conditions of a supplier’s contracts with E.I. Microcircuits. If a contract requirement is more restrictive than this Code, the supplier must comply with the more restrictive contract requirement.

Compliance with Laws: At a minimum, suppliers must maintain full compliance with all laws and regulations applicable to the operation of their business and their relationship with E.I. Microcircuits.

Quality & Environmental Health and Safety: Supplier products and services must be designed, produced, and delivered with the paramount consideration being the safety and health of its employees and consumers. Suppliers must have in place quality assurance processes to detect, communicate to E.I. Microcircuits and correct defects to ensure delivery of products and services that meet or exceed contractual quality and legal and regulatory requirements. All required inspection and testing operations must be completed properly by appropriately authorized and qualified individuals, and any required certifications must be completed accurately.

Suppliers must comply with all applicable environmental, health and safety laws, regulations and directives; and also conduct their operations in a manner that safeguards the environment, minimizes waste, emissions, energy consumption, and the use of materials of concern. Suppliers must also assure safe and healthy work environments for their employees and business invitees.

Competition on the Merits and Fair Play:
Suppliers must compete strictly on the basis of the merits of their products and services.

Suppliers must not pay a bribe in any amount, to anyone, anywhere, for any reason whatsoever. Accordingly, suppliers must never offer, promise, authorize, or provide, directly or indirectly, anything of value (including business gifts or courtesies) with the intent or effect of inducing anyone (including a E.I. Microcircuits customer, E.I. Microcircuits employee, or higher tier or sub-tier supplier) to forego their duties and provide unfair business advantage to E.I. Microcircuits, the supplier, or others. This includes facilitating payments (e.g., payments to expedite or secure performance of a routine governmental action like obtaining a visa or customs clearance).

Suppliers must not engage in any anti-competitive conduct for any reason whatsoever. Accordingly, a supplier must never rig bids, fix prices, or allocate customers or markets, or exchange E.I. Microcircuits’ or the supplier’s competitively sensitive information (e.g., price, cost, output, etc.) with E.I. Microcircuits’ competitors or the supplier’s competitors. Suppliers must also refrain from abusing their market power, whether for their benefit or for the benefit of others, by refusing to deal, engaging in predatory or discriminatory pricing practices, conditioning the sale or provision of a particular product or service with that of another product or service, or undertaking similar abusive tactics.

Suppliers must not engage in other deceptive or unfair market practices. Accordingly, suppliers must never make misrepresentations regarding E.I. Microcircuits’ products or services, their own products or services, or the products or services of others.

Conflict of Interest: Suppliers must avoid all conflicts of interest or situations giving the appearance of a conflict of interest in their dealings with E.I. Microcircuits. Suppliers must report to E.I. Microcircuits any instances involving actual or apparent conflicts of interest between their interests and those of E.I. Microcircuits, such as when one of the supplier’s employees (or someone close to one of their employees) has a personal relationship with an E.I. Microcircuits employee who can make decisions impacting the supplier’s business, or when an E.I. Microcircuits employee has an ownership or financial interest in the supplier’s business.

International Trade Compliance: Suppliers must conduct business in strict compliance with all applicable laws and regulations governing (a) the export, re-export and retransfer of goods, technical data, software and services; (b) import of goods; (c) economic sanctions and embargoes; and (d) U.S. antiboycott requirements.
Information Protection: Suppliers must respect the legitimate proprietary rights and intellectual property rights of E.I. Microcircuits and others. Suppliers must take proper care to protect sensitive information, including confidential, proprietary and personal information. Suppliers should not use such information for any purpose other than the business purpose for which it was provided, unless the owner of the information provided prior authorization.

Accuracy of Records and Submissions: Suppliers must maintain books and records that accurately and completely reflect all transactions related to E.I. Microcircuits business and each of the supplier’s submissions to E.I. Microcircuits, its customers, and regulatory authorities must be accurate and complete.

Non-Discrimination: Suppliers must treat their existing and prospective employees and business partners fairly, based only on merit and other factors related to their legitimate business interests, and without regard to race, religion, color, age, gender, gender identity or expression, sexual orientation, national origin, marital status, veteran status or disability, or any other characteristic protected under applicable law, consistent with the principles of applicable ILO conventions.
Freedom of Association: Suppliers must recognize the principle of freedom of association and the right to collective bargaining as they exist under applicable laws in the countries where they operate.

Compensation: Suppliers must comply with all applicable regulations pertaining to wages, hours, and legally mandated benefits. Documentation regarding the terms and conditions of employment (such as compensation and benefits) must be provided to employees, and payment of overtime must be at a premium/higher rate. In addition, there should be no standard wage rate reductions for disciplinary reasons.

Child Labor: Suppliers must ensure that child labor is not used in the performance of their work, whether or not related to E.I. Microcircuits business, consistent with the principles of applicable ILO conventions. The term “child” refers to any person under the minimum legal age for employment where the work is performed.

Human Trafficking: Suppliers must comply with laws and regulations prohibiting human trafficking. Suppliers must not engage in the use of forced or compulsory labor defined as all work or service which is exacted from any person under the menace of any penalty and for which the said person has not offered him or herself voluntarily consistent with the principles of applicable ILO conventions. Other forms of forced or compulsory labor include, but are not limited to, bonded labor, indentured labor, involuntary prison labor, slavery or trafficking in persons.

Harassment and Abusive Behavior: Suppliers must share our commitment to providing a workplace free from harassment, bullying, threats, and violence. Harassment refers to words or actions that create an intimidating, hostile, or offensive work environment. Whether it is in person or online, harassment is not just what is intended, but how others perceive it. It can be (a) what a person says or writes, including racial, ethnic, or gender-based slurs, jokes, or stereotypes as well as threatening, loud, or abusive language; (b) what a person does, such as unwelcome touching, making sexual advances; intentionally blocking someone’s path, ignoring someone, or deliberately humiliating someone, (c) what a person displays, such as placing lewd photos or derogatory slogans on a workstation or sharing them electronically.

Monitoring and Compliance: Suppliers may never engage in any activity prohibited by this Code by knowingly employing – or failing to impose appropriate corrective action, up to and including termination, upon a subcontractor or supplier who performs the prohibited activity on behalf of the E.I. Microcircuits supplier.

If you have any questions regarding this Code or if you would like to report a concern or illegal activity, please contact E.I. Microcircuits at 507-345-5786.