Supplier Code of Conduct
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
Human Rights & Labor
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.
Suppliers shall comply with local minimum working age laws and requirements and not employ
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.
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
HEALTH, SAFETY & ENVIRONMENT
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
ETHICS & LEGAL REQUIREMENTS
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.
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
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
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.
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.
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.
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
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.
ALL RIGHTS RESERVED
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.