Supplier Code of Conduct

Control Techniques expects its suppliers to project its values and principles, to act with integrity and treat people and the environment with respect – all actions that reflect Control Techniques’ priorities. In this way, we are able to employ high calibre suppliers that demonstrate responsibility and a commitment to fairness and honesty.

The Control Techniques Supplier Code of Conduct (“Supplier Code of Conduct”) embodies the broad principles set forth in the Nidec Group Corporate Social Responsibility Charter, entitled “CSR Charter”, which is available at: http://www.nidec.com/en-NA/sustainability/principle/charter/. We encourage all of our suppliers to familiarise themselves with the Supplier Code of Conduct and the CSR Charter as we expect each supplier to adhere to these principles. The following summary provides an overview of the Supplier Code of Conduct principles.

Ethics

Highest Ethical Behaviour – Our policies and practices direct Control Techniques employees to conduct business lawfully and ethically wherever we operate. We adhere to firm, uncompromising standards for Control Techniques’ leadership and employees with respect to interactions with customers, suppliers, government agencies and the public and we demand that our suppliers support this requirement as they work on Control Techniques business.

Anti-corruption – Our suppliers must comply with all laws and regulations forbidding payment of money, products, gifts or services, directly or indirectly, to any individuals or entities in order to corruptly induce favourable business treatment or to corruptly affect governmental decisions.

Conflicts of Interest – Control Techniques considers it inappropriate for suppliers’ employees to have any personal, business or financial interest that conflicts with their responsibilities to their employer.

Ethics Hotline – To facilitate reporting of ethics concerns, we provide Control Techniques employees and suppliers a Global Ethics Compliance Hotline operated by us. Reports to the hotline are anonymous if requested. We tolerate no form of reprisal against employees or suppliers who report concerns. Employees and suppliers can report a concern related to business conduct issues by calling the Nidec Global Ethics Compliance Hotline (inside the US) at 877-522-7545 and (outside the US: 770-582-5264). In addition, there are geographic specific e-mail Hotline options that can be used for reporting ethics concerns: 

• The Americas: nidec_hotline_americas@nidec.com 
• China: nidec_hotline_china@nidec.com 
• Europe: nidec_hotline_europe@nidec.com 
• Southeast Asia: nidec_hotline_asia@nidec.com 
• Japan: nidec_hotline_hq@nidec.com

Human Rights and Labour

Conditions of Employment – Control Techniques stress to our suppliers the importance of operating with reasonable working hours to maintain a positive and productive work environment consistent with commonly accepted practices in each locale. We oppose any form of forced, bonded or indentured labour, or involuntary prison work. Further, compensation practices should comply with applicable wage laws, including those relating to minimum wages, overtime compensation and legally mandated benefits.

Discrimination – Control Techniques require suppliers to prohibit discrimination against or harassment of any employee or applicant on the basis of race, colour, religion, sex, sexual orientation, age, disability, national origin, or any other factor deemed unlawful.

Freedom to Associate – Suppliers should respect the rights of workers to associate freely and seek representation in accordance with local laws.

Humane Treatment – Control Techniques objects to any form of harsh or inhumane treatment, including sexual harassment, sexual abuse, corporal punishment, mental or physical coercion or verbal abuse and expects its suppliers to banish any such practices within their organisation.

Prohibition of Child Labour – Our policies oppose child labour and we forbid our suppliers to use child labour in any facility or business.

Working and Living Conditions – We expect our suppliers to provide their employees with a healthy and safe working environment in accordance with all applicable laws and regulations and to protect their employees from short, immediate and long-term harm. Where housing is made available to employees, we expect our suppliers to ensure a healthy and safe living environment for employees in accordance with all applicable laws and regulations.

Modern Slavery – We expect our suppliers to comply with all applicable laws and regulations preventing slavery and human trafficking, including without limitation the UK Modern Slavery Act 2015 and to comply with our Anti-Slavery and Human Trafficking Policy.

Other

Environment - Suppliers should operate their facilities in a manner that protects the environment and meets or exceeds applicable laws and regulations. We further stress the need for our suppliers to foster programs that reduce energy consumption and waste in their facilities and we emphasise the importance of creating innovative products and services that improve energy efficiency, and minimise environmental harm.

Management Systems – Suppliers should maintain a management system that demonstrates adoption of the principles embodied in this Supplier Code of Conduct and that tracks and documents compliance with all applicable laws, government policies and regulations.

Supply Chain Management – Control Techniques expects its suppliers to use their best efforts to extend the principles embodied in this Supplier Code of Conduct to their suppliers and agents that are engaged in the production, supply and support of products or services for Control Techniques.

Technology - Control Techniques expects its suppliers to keep abreast of developing technology, and employ such technologies in the products supplied, manufacturing techniques and systems used.

Issued November 2022