Corporate Responsibility

Supplier Code of Conduct / ESG (Environmental Social Governance)

1. Introduction

Connect Com defines the economic, ecological and social principles for its business activities. Accordingly, its direct suppliers and their subcontractors are also required to comply with these principles. In accordance with its corporate values and its environmental and social policy, Connect Com expects its suppliers and thus also its subcontractors to fulfill their responsibility towards society and the environment.

The focus here is on the entire "end-to-end supply chain" from the manufacturer to the supply partner to the user to the disposal company. The aim of Connect Com is to uncover any business risks so that measures can be taken if necessary. These points are also checked during a possible on-site audit.

Compliance with the Supplier Code of Conduct is mandatory for those points that are relevant and specifically related to the business model and the service actually provided by the supplier.

2. General requirement

Connect Com supports and respects the ten principles of the UN Global Compact. We also require our suppliers to support and respect them, regardless of whether the supplier is a member of the UN Global Compact or not. The supplier passes on these minimum requirements to its partners, suppliers and their subcontractors.

3. National and international law

The Supplier Code of Conduct does not replace any applicable laws and regulations of a country in which the supplier operates. It serves to promote, comply with and support these laws and regulations and contributes to their reliable and effective implementation.

In addition to complying with the provisions set out in this Code, the Supplier must comply with applicable national laws, regulatory requirements and any contractual obligations agreed between the Supplier and Connect Com.

If Connect Com's minimum standard is higher than the applicable legislation of the relevant country, this minimum standard must be applied.

4. Environmental and climate protection
4.1 Environmental protection

The supplier must act in accordance with the relevant local and internationally recognized environmental standards and the applicable local laws. The supplier must minimize its environmental impact and implement measures that contribute to the protection of the environment.

Supplier shall obtain, maintain and keep current all required environmental permits (e.g. waste management, transportation), approvals and registrations.

Supplier shall identify, minimize, monitor and control all hazardous air pollutants, wastewater and soil contamination. All emissions must be discharged and treated in accordance with international standards and applicable laws.

The supplier shall preferably operate a certified environmental management system such as ISO 14001.

If no ISO 14001/EMAS certificate is available, the supplier guarantees at least the following activities:

  • Compliance with environmental legislation is checked regularly
  • Workflows and procedures that may have an impact on the environment are documented (e.g. processes, checklists, work instructions)
  • An environmental program is in place and its implementation is verifiable
  • Employees with environmentally relevant activities are demonstrably appropriately trained
  • Continuous improvement in the environmental area is verified by means of internal or external audits
  • The supplier designates a person responsible for all environmental matters
  • The supplier also enforces the requirements mentioned here with its subcontractors by analogy

The entire manufacturing process must be checked for environmental risks and any necessary measures must be taken.

4.2 Conflict minerals and hazardous substances

If the supplier uses raw materials that may originate from conflict areas, it must trace the source of these potential conflict minerals in order to promote transparency along its own supply chain and take effective measures with regard to any human rights violations in the extraction of raw materials. Reasonable suspicions must be communicated proactively and transparently.

The supplier must comply with all applicable laws, regulations and customer requirements regarding bans or restrictions on certain substances. Hazardous chemicals and other materials contained in products, in particular those included in the European Chemicals Regulation (REACH) list of substances of very high concern, must be identified by the supplier and handled in a manner that ensures their safe use, recycling or reuse and disposal. The use of such chemicals and materials by the supplier must be avoided. If this is not possible, it must be minimized. Where required, the supplier must supply electrical and electronic equipment in compliance with all relevant European Union regulations, including RoHS and REACH.

5. Social responsibility
5.1 Child Labor

The supplier must actively prevent child labor within the meaning of the ILO Convention concerning the Minimum Age for Admission to Employment (No. 138, 1973) and the Convention concerning the Prohibition and Immediate Action for the Elimination of the Worst Forms of Child Labor (No. 182, 1999). Furthermore, the supplier must comply with the ILO Child Labor Guidance Tool for Business (2015) and the OECD Guidance for Responsible Business (2018). No persons may be employed who have not reached the legal minimum age for employment. Persons under the age of 18 must not be employed for overtime work, hazardous work1 and night work.

The supplier must ensure, especially if it operates in a risk country classified by UNICEF, that concerns about child labor in its supply chain can be reported and that the reporting option is easily accessible and anonymous for those directly or indirectly affected (see section 5.9 Complaints mechanism). If the supplier becomes aware of child labor, it must take immediate action to remedy the situation in accordance with the best interests of the child. In addition, substantiated suspicions must be communicated proactively and transparently to Connect Com.

5.2 Forced labor

The supplier must not permit any form of forced labor, compulsory labor, slavery or human trafficking.

All employment must be on a voluntary basis and employees must be free to leave the premises after working hours. The supplier's employees must be allowed to terminate their employment relationship with reasonable notice and without penalty.

The supplier may not require its employees to deposit funds, withhold payments, impose debts or require its employees to provide official identification, a passport or a work permit as a condition of employment.

5.3 Working hours

Working hours, including overtime, must comply with applicable local laws.

5.4 Health and safety

The supplier must take all necessary and legally prescribed precautionary measures against accidents and occupational illnesses and periodically monitor their effectiveness and compliance.

In the best case, the supplier has implemented a health and safety management system based on international standards such as ISO 45001 or similar standards.

6. Ethics
6.1 Competition

The supplier shall comply with competition law. In particular, it shall not participate in any unlawful price, quantity or territorial agreements with competitors and second-hand price fixing or agreements on absolute territorial protection.

6.2 Sanctions and embargoes

The Supplier shall comply with all international trade sanctions and shall ensure that it, or its services and goods, comply with applicable laws and regulatory requirements relating to export/import regulations (export, import or transit of goods), in particular of the USA, including sanctions and embargoes.

6.3 Data protection

The Supplier shall comply with all applicable data protection laws and any specific data protection and security requirements deemed relevant.

7. Control and reporting

The supplier shall report serious violations of these requirements immediately and agree a jointly coordinated plan for corrective measures with Connect Com.

The supplier assures Connect Com the right to carry out an audit at its own premises and those of its subcontractors.

The detailed audit program shall be drawn up by Connect Com and agreed between the parties. The supplier guarantees the feasibility of the audit program. The audit team shall be accompanied by representatives of the supplier.

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