At Applied Intuition, Inc. and its subsidiaries (“We”, “Our”, “Us” or “Applied Intuition”), our mission is to accelerate the world’s adoption of safe and intelligent machines. Fair and ethical collaboration with our supply chain partners and other stakeholders is an integral part of our ongoing success and a key part of our obligations to our customers.
This Supplier Code of Conduct (this “Code”) establishes the minimum ethical standards we expect the businesses supplying products and services to us and our affiliates (each, a “Supplier”) to follow in conducting their operations.
By doing business with us, Supplier agrees to adhere to this Code, and to cause all of its employees (including permanent, temporary, and agency workers), agents, vendors, and others acting under its control and/or direction to similarly comply. All references to a “Code of Conduct,” “Supplier Code of Conduct” or words of similar import in purchase orders, licenses and/or other contracts with us will refer to this Code, which may be revised from time-to-time at our sole discretion with or without notice, effective immediately upon posting. Continuing to do business with us following the posting of any changes to this Code constitutes Supplier’s acceptance to such changes. Accordingly, we strongly encourage Suppliers to periodically review this Code. This Code supplements, and does not replace or supersede, all other agreements, terms and conditions agreed to between Applied Intuition and any individual Supplier.
1) Labor Practices.
a) Human Rights. Suppliers will respect human rights in all countries in which it operates, including in geographical areas where human rights may not yet be sufficiently protected. Suppliers will abstain from conducting, directly or indirectly, any form of torture, cruel, inhuman or reagrees to prevent situations of complicity or acts of collusion concerning fundamental human rights violations in its operations and throughout its entire supply chain. Suppliers will provide their employees with fair working conditions, which at least meet the minimum standards required by applicable laws as well as the core labor standards promulgated by the International Labor Organization (ILO).
b) Voluntary Work. Suppliers will not tolerate any form of forced, bonded, compulsory, trafficked, modern slavery or non-voluntary labor. Suppliers will enter into written labor contracts with workers, drawn up in a language workers can understand and provide a copy to the workers. When hiring foreign workers, workers shall be allowed to keep their identity or immigration documents. Suppliers will not limit workers’ freedom of movement unreasonably, and workers shall be able to freely resign from their positions if they so desire. Suppliers will not require workers to pay recruiting, uniform, personal protective equipment or other fees needed to obtain and retain employment.
c) Prohibition Against Juvenile Workers. Suppliers will not permit the use of any child labor. All workers will meet the minimum legal age required by applicable law and comply with the minimum employment age standards prescribed by the ILO. Student workers will be supported and managed separately from regular workers depending on the training programs.
d) Fair Compensation and Working Hours. Suppliers will comply with applicable laws, regulations, standards, collective bargaining and other applicable practices in those countries where it operates, whichever is strictest, regarding workers’ working hours, fair compensation, overtime, wage deductions, minimum wages, break times, holidays and periodic days off.
e) Humane Treatment. Suppliers will implement, maintain and enforce policies and procedures to prevent workers from being subjected to sexual harassment, sexual abuse, physical punishment, mental/physical coercion, abusive language, unreasonable restriction or brutal or inhumane treatment.
f) Prohibition Against Discrimination. In employment practices, such as hiring, wages, promotion, compensation and educational training opportunities, Suppliers will not discriminate on account of race, skin color, age, gender, sexual orientation, gender identity and expression, ethnic origin, disability, pregnancy, religion, political orientation, labor union membership, nationality, marital status or any other characteristic protected by applicable law.
g) Freedom of Association. Suppliers will respect its workforce’s freedom to organize and join labor unions pursuant to local laws, and to engage in collective bargaining, peaceful assembly and reject such activities. Workers or workers’ representatives shall be able to share their opinions on working conditions and management policies and their difficulties with the management without fear of discrimination, retaliation or threats.
2) Environmental Practices.
a) Environmental Compliance. Suppliers will comply with all applicable environmental protection laws, including the acquisition and maintenance of all required environmental licenses and permits. Suppliers will regularly monitor legal developments and comply with all new requirements.
b) Sustainability. Suppliers will make efforts to reduce and eliminate resource/energy consumption and waste discharge by improving processes, using alternative sources of energy, conducting preventive maintenance, preserving resources, recycling and reusing. Suppliers will make efforts to reduce power and fuel consumption and minimize greenhouse gas emissions by enhancing energy efficiency. Supplier will monitor, track and document its emissions, wastewater and solid waste generated by its business operations to enable the reduction of environmental impacts.
c) Hazardous Substance Management. Where a Supplier’s operations may involve hazardous materials or waste, such Supplier will identify all chemicals and other materials likely to contaminate the environment when leaked, and make efforts to safely store, transport, use, recycle, reuse and dispose of them.
d) Conflict Minerals. Suppliers will establish and maintain a policy to prevent the use of materials sourced through any illegal and unethical means. Suppliers will exercise due diligence on the source and chain of custody of conflict minerals contained in products and make such Supplier’s due diligence measures available to us upon request. The term “conflict minerals” has the meaning ascribed to it in the rules and regulations of the U.S. Securities and Exchange Commission promulgated under Section 13(p) of the Securities Exchange Act of 1934, as amended.
3) Health and Safety.
a) Industrial Safety. Suppliers will at all times maintain safety procedures and ensure the availability of healthcare for workers at least as required by applicable law and regulation. Suppliers will conduct periodic risk assessments to understand the possibility of workers being exposed to safety risk factors. Suppliers will design safe processes, implement technical/administrative controls and preventive maintenance, prepare safety regulations and provide training and necessary personal protective equipment (PPE) to workers, and supervise the use of such PPE according to the results of risk assessment.
4) Business Practices.
a) Conflicts of Interest. Suppliers will have processes and controls in place around the giving and receiving of gifts and entertainment with business partners to prevent, detect and remediate any conflict of interest, especially any conflict of interest that may influence its business with us.
b) Fair Trade and Competition. Suppliers will comply with all applicable anti-bribery and anti-corruption laws, including, without limitation, the U.S. Foreign Corrupt Practices Act, the U.K. Bribery Act and the French Loi Sapin 2. Suppliers will not engage in any form of commercial bribery, nor directly or indirectly provide or offer to provide, anything of value to or for the benefit of, any official or employee of a governmental authority or of any government-owned, government-controlled or government-affiliated entity to induce such person(s) to violate their official duties in order to grant Supplier any benefit, including obtaining or retaining any contract, business opportunity or other business benefit. Suppliers will adopt their own measures to promote similar compliance amongst their respective subcontractors, vendors, agents or other associated third parties.
c) Export Control and Customs. Suppliers will comply with all applicable laws and regulations for importing and exporting goods, services and information. Suppliers will fulfill the requirements of customs and foreign trade regulations in all countries in which they conduct business. d) Compliance Management. Suppliers will have processes in place by which to prevent, detect, investigate, mitigate, and remediate any non-compliance with the requirements set forth in this Code, working with potentially affected stakeholders as appropriate and will promptly report any non-compliance to us. Suppliers commit to zero retaliation against individuals who make reports in good faith and will work with us to resolve any such non-compliance as necessary.
e) Intellectual Property and Data Privacy. Suppliers will respect parties’ intellectual property rights, and protect such rights when transferring technology or know-how. Suppliers will respect the confidentiality of personal information of employees and other third parties (eg: customers) and must be committed to complying with all applicable laws to maintain and protect data privacy, including the transmission and storage thereof. Access to personal information should only be authorized when there is a legitimate and lawful reason.
f) Management Systems. Suppliers will establish and maintain adequate management systems to oversee all elements of this Code, in proportion to the size, complexity and risk environment of such Supplier’s business. Such a management system shall be continuously reviewed, monitored and improved.
g) Security Awareness Training. Suppliers must ensure that all employees, subcontractors, and agents who have access to our systems, data, or facilities are provided initial and ongoing security awareness training before access to any systems, data, or facilities is granted. This training program must align with industry standards and regulatory requirements and cover key topics such as data protection, phishing awareness, password management, incident reporting, and any other security practices relevant to the Supplier's role within the contract. Specifically, suppliers must:
i) Provide refresher training to appropriate personnel on an annual basis, or more frequently if required by law or in response to emerging security risks.
ii) Maintain accurate records of security training completion for all relevant personnel and make these records available to us upon request for audit or compliance purposes.
iii) Immediately report any security incidents or breaches involving Supplier personnel to us.
References
The following standards were used in preparing this code and may be a useful source of additional information.
EICC Code - http://www.eiccoalition.org/standards/code-of-conduct/ ILO
International Labor Standards - http://www.ilo.org/global/standards/lang--en/index.htm ILO
Code of Practice in Safety and Health - www.ilo.org/public/english/protection/safework/cops/english/download/e000013.pdf
OECD Guidelines for Multinational Enterprises - http://www.oecd.org
OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas - http://www.oecd.org/investment/mne/mining.htm
United Nations Convention Against Corruption - www.unodc.org/unodc/en/treaties/CAC/index.html United
Nations Global Compact - www.unglobalcompact.org
Universal Declaration of Human Rights - www.un.org/Overview/rights.html
ISO 14001 - www.iso.org SA8000 and SAI (Social accountability international) - http://www.sa-intl.org/