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FloWorks is committed to conducting its business in an ethical, legal, and socially responsible manner.
FloWorks expects its suppliers to share this commitment and, therefore, has established this Supplier
Code of Conduct. Although there may be different legal and cultural environments applicable to its
suppliers, FloWorks suppliers must meet the following minimum requirements in order to do business
with FloWorks.
Respect for People is a core value of FloWorks. FloWorks expects its suppliers to adopt sound labor practices and treat their workers fairly in accordance with local laws and regulations. In addition, suppliers must comply with the following standards:
Respect Freedom of Association and Collective Bargaining
Suppliers will respect employees’ lawful right of free association, as well as their lawful right to join, form or not to join a labor union or otherwise engage in collective bargaining.
No Forced and Compulsory Labor
Suppliers shall not use any forced labor, whether in the form of prison labor, indentured labor, bonded labor or otherwise.
No Harassment and Abuse of Labor
Suppliers will ensure that their employees are not subjected to psychological, verbal, sexual or physical harassment or any other form of abuse and will comply with all applicable laws on harassment and abuse of employees.
Labor Laws
Suppliers shall comply with local minimum working age laws and requirements and not employ child labor.
No Discrimination
Suppliers will not discriminate in any condition of employment on the basis of race, color, national origin, sex, religion, age, disability, HIV/AIDS status, trade union membership, sexual orientation or any other personal characteristic unrelated to job performance and will comply with all applicable employment discrimination laws.
Supplier Diversity
Suppliers are encouraged to have an active Supplier Diversity Program and support the businesses and communities where FloWorks operates by engaging with small businesses, minority- and woman-owned businesses and other diverse categories.
Appropriate Work Hours and Wages
Suppliers will comply with all applicable laws on work hours and overtime, as well as all applicable laws on wages and benefits.
Conflict Minerals Sourcing
Supplier will not source tin, tantalum, tungsten, or gold (the “Conflict Minerals”) from the Democratic Republic of the Congo or the adjoining countries (the “Covered Countries”) in a manner which directly or indirectly finances or benefits armed groups in the Covered countries. Supplier will source Conflict Minerals from smelters that have been verified as compliant with the CFSP (Conflict-Free Smelter Program) assessment protocols of the CFSI (Conflict-Free Sourcing Initiative). Supplier commits to abide by all applicable laws and regulations related to Conflict Minerals and agrees to provide all necessary information requested by FloWorks concerning products supplied by Supplier to enable FloWorks to complete its reasonable country of origin inquiries and due diligence with respect to Conflict Minerals.
FloWorks’ commitment to sustainability includes efficient use of resources, respect for the environment and safe and healthy workplaces. FloWorks expects its suppliers to make similar commitments to continuously improve their environmental, health and safety performance.
Respect the Environment
Suppliers will comply with all applicable environmental laws. Suppliers will have systems in place to ensure safe management of waste, air emission and wastewater discharges. FloWorks encourages its suppliers to seek ways to minimize the use of nonrenewable resources, use all resources more efficiently and minimize the environmental impact of their operations.
Protect Health and Safety
Suppliers will comply with all applicable workplace health and safety laws. Suppliers will provide a safe and healthy workplace for their employees, including appropriate controls, training, work procedures and personal protective equipment.
Protect Communities during Transportation
Suppliers will comply with all applicable transportation laws. Suppliers will have systems in place to ensure safe and secure transportation of materials. This includes consideration for selection of logistics service providers (including warehouses and terminals), selection and inspection of transport containers, loading and unloading of transport containers, securing, and sealing of transport containers, and responding to emergencies.
FloWorks expects its suppliers to conduct their business as FloWorks strives to conduct its business: ethically and in compliance with the law.
Avoid Conflicts of Interest
Suppliers will avoid any interaction with a FloWorks employee that may conflict, or appear to conflict, with that employee acting in the best interests of FloWorks. This includes offering payments or employment opportunities to FloWorks employees.
No Bribery
Suppliers will not engage in any form of commercial bribery or otherwise offer any incentive to any FloWorks employee or FloWorks employee’s family or friends in order to obtain or retain FloWorks business. Suppliers will comply with the U.S. Foreign Corrupt Practices Act, the UK
Fair Competition
Suppliers shall not engage in collusive bidding, price fixing, price discrimination or other unfair trade practices in violation of antitrust laws.
Accurate Accounting and Business Records, Money Laundering, and Insider Trading
Suppliers will keep – and provide to FloWorks upon request – accurate records of all matters related to the supplier’s business with FloWorks and shall not engage in any form of money laundering and shall never knowingly accept funds acquired through illicit means. No confidential information in the supplier’s possession regarding FloWorks shall be used to engage in or support insider trading.
Protect Information
Suppliers will protect FloWorks’ confidential information, including personal information, and act to prevent its misuse, theft, fraud, or improper disclosure and will comply with all applicable data privacy laws. Suppliers must take all due care in handling, discussing, or transmitting sensitive or confidential information that could affect FloWorks, its employees, its customers, the business community, or the general public.
International Trade
Suppliers will comply with all applicable laws governing international trade. Suppliers will provide FloWorks with documentation necessary for FloWorks to comply with import/export laws and will implement practices and procedures to ensure security of their supply chain under applicable regulations. If applicable, Suppliers will provide documentation to support the eligibility of their product under a Free Trade Agreement.
Sanctioned Parties
Shippers may not use any supplier of services or equipment which (a) is in any country subject to United Nations, U.S., or EU economic sanctions (or acting on behalf of persons or entities located in such countries) or (b) appears on lists of restricted or prohibited persons maintained by the United Nations, U.S., EU or the country of manufacture, origin/destination of the cargo. Shippers shall screen all vessels, containers and other equipment and their owners to ensure compliance with this requirement.
Intellectual Property Rights
Suppliers shall respect the intellectual property rights of others, including FloWorks, its affiliates and business partners. Suppliers must take appropriate steps to safeguard and maintain confidential and proprietary information of FloWorks and shall use such information only for the purposes specified for use by FloWorks. Suppliers shall observe and respect all FloWorks patents, trademarks and copyrights and comply with all requirements as to their use as established by FloWorks.
In addition to the legal standards mentioned in this Code, suppliers will comply with all other applicable laws in the provision of products or services to FloWorks. FloWorks expects suppliers to implement systems and controls to promote compliance with applicable laws and the principles set forth in this Code, including policies, training, monitoring, and auditing mechanisms. Suppliers should also apply these or similar principles to the subcontractors and suppliers they work with in providing goods and
services to FloWorks.
FloWorks reserves the right to assess and monitor suppliers’ compliance with this Code. Suppliers who are not in compliance with this Code may be terminated and/or precluded from consideration of future business. Suppliers must promptly implement corrective actions.
Suppliers who believe that a FloWorks employee or anyone acting on behalf of FloWorks has engaged in illegal or otherwise improper conduct with respect to their business with the supplier should report the matter to FloWorks’ Legal Department. Suppliers should also report any potential violation of this Code. Reports may also be made through the FloWorks EthicsLine at 1-855-761-0363 or floworks.ethicspoint.com. A supplier’s relationship with FloWorks will not be affected by an honest report of potential misconduct.