Supplier Code of Conduct

Standard Operating Procedure
SOP 23-01 Supplier Code of Conduct

1.0 Purpose
  1.1 The purpose of this document is to define the behavior and principles we expect all of our suppliers to comply with. B&E Manufacturing is committed to carrying out all activities connected to our business in accordance with all applicable laws. 
2.0 Ethics and Integrity
  2.1 We expect all of our suppliers to act ethically and with integrity at all times. This means complying with the law, treating people and your suppliers fairly, and engaging only in proper business conduct.
  2.2 This Supplier Code of Conduct does not replace the requirement to comply with applicable laws. Where there are differences between the applicable laws and this Supplier Code of Conduct, suppliers should apply whichever sets the highest standard of behavior.
3.0 Anti-Bribery and Corruption
  3.1 We do not tolerate, permit, or engage in bribery, corruption, or improper payments of any kind in our business dealings both with public officials and with people in the private sector.
  3.2 Bribery is the offer, promise, giving, asking or acceptance of an advantage as an inducement for doing something improper in a person’s work or in carrying out a public function. For public officials, a bribe can be anything of value that is offered or given with the intention of influencing the public official to obtain or retain a business advantage. This is a low threshold because it does not require an intention the official exercises their role improperly. B&E treats any form of “facilitation payment” to be a bribe. Suppliers must not give any form of facilitation payment to public officials in connection with B&E business.
  3.3 Corruption is the misuse of public office or a business position for private gain. This would, for example, cover a situation where a public servant requests a personal payment from a supplier.  
4.0 Hospitality and Gifts
  4.1 Any hospitality or gift offered or given by suppliers to B&E employees or to third parties with connection to B&E business must be reasonable in value and not be intended to improperly influence a business relationship or transaction.
  4.2 Suppliers should not give gifts, hospitality or any form of advantage to a public official in connection with B&E business. Cash or monetary gifts should not be given.
5.0 Fraud Prevention
  5.1 Steps should be taken to detect and prevent any form of Fraud. Fraud is committed when a person acts dishonestly, intending to make a gain or to cause loss to another (or expose another to a risk of loss) through some form of deception or misrepresentation.
  5.2 Suppliers must ensure that all invoices and financial records are accurate. Invoiced amounts should match with agreed contractual terms. Any inflation of amounts or duplicate invoicing will be treated as a suspected fraud.
6.0 Data Protection
  6.1 The personal details of B&E employees and any other personal data that B&E provides to suppliers must be kept confidential and secure. Personal data should not be provided to third parties without B&E express agreement.
7.0 Health, Safety and Environmental Concerns
   7.1 Our goal is to create a safe, healthy and clean working environment such that we cause no harm to people, and we minimize our impact on the environment.
   7.2 Measures should be taken by suppliers to ensure the health, safety and welfare of their employees and those affected by a supplier’s business. We encourage our suppliers to take measures to reduce their environmental impact and to contribute to the communities in which they operate.
   7.3 Please promote an environment in which all co-workers enjoy equal opportunities and treatment, free of any form of discrimination, bias or harassment.
8.0 Human Rights and Modern Slavery
  8.1 We wish to conduct our business with respect for human rights.
  8.2 Slavery and human trafficking (Modern Slavery) are crimes and a violation of human rights. B&E has a zero-tolerance approach to modern slavery.

The following key principles apply to our business and our supply chain:

      • • Child labor must not be used
      • • Any form of forced or compulsory labor must not be used. Workers must be free to leave employment or work after reasonable notice
      • • Passports, visas and other personal documentation should not be taken from employees unless requested to be held by the employee for safekeeping purposes
      • • All forms of debt bondage are prohibited. Workers should not be subject to contracts that tie them into repaying a loan (other than small loans to cover items such as transport costs), excessive accommodation expenses or other costs that they have no or little opportunity to repay
      • • Compensation and benefits must comply with local laws relating to minimum wages, overtime hours and other benefits, and
      • • The formation of trade unions and powers of collective bargaining should be respected.
Revision History

Date Revised