1.1 Purpose

We require all our suppliers to conduct their business in a socially and ethically responsible manner. The CoCS sets out minimum standards of behaviour and practices we require from suppliers.

1.2 Content, scope and applicability

The CoCS is applicable to all suppliers who supply products and/or services related to Elprint contracts or purchase orders.

It is our supplier’s responsibility to ensure that their subcontractors and employees are informed about and comply with our code of conducts. Elprint takes a partnership approach with our suppliers by:

• Proactively seeking continuous improvement on the part of suppliers within the areas covered by the CoCS.
• Support and encourage suppliers to identify areas that require improvements.

Elprint will assess compliance with the CoCS through supplier dialogue, assessments and audits. In the event of announced and unannounced assessments or audits of the supplier for the purpose of verifying compliance with the requirements in this document, Elprint personnel, Elprint’s customer or Elprint consultants shall be provided relevant documentation and have unlimited access to any part of the premises where work under a contract is being performed as well as to relevant personnel.

Elprint will evaluate whether its suppliers have complied with the CoCS or not. Any violation of the CoCS will endanger the business between the suppliers and Elprint and can lead to the termination of the business between both parties. In selecting and retaining qualified suppliers, Elprint will give priority to suppliers that fully comply with the CoCS.

1.3 National Legislation

In all of their activities, Elprint’s suppliers must operate in full compliance with the legislation, rules and regulations of the countries in which they operate. Where national law and the CoCS differ, suppliers shall follow the higher standard. Where suppliers deviate from the higher standard, they shall seek a written exception from Elprint.

In order to meet the standards on human and labour rights included in this CoCS, suppliers are required to comply with ILO International Labour Standards and the UN universal declaration of human rights.

2.1 Freely Chosen Employment

Suppliers shall not use or profit from any form of human trafficking, slavery or forced labour, including involuntary prison labour (ILO Convention 29 (Forced labour) and 105 (Abolition of forced labour)).

Suppliers shall ensure their employees shall have freedom of movement and the right to resign at any time and leave after meeting the conditions of their contract and notice period.

Workers shall not be required to lodge government issued identification, passports or work permits to the supplier or labour agent as a condition of employment.

No recruitment fees or related costs shall be paid by workers. Where evidence of fee-charging is identified, workers shall be reimbursed.

2.2 Child Labour Avoidance

Child labour shall not be hired, used or profited from (ILO Convention 138 (Minimum age), 182 (Worst forms of child labour) and 79 (Night work of young persons), ILO Recommendation 146 (Minimum age), UN Convention on the Rights of the Child).

No child under the age of 15 shall be employed, except where the local minimum age is set to 14 in line with the exceptions contained in ILO Convention 138. Where the local minimum age of employment or mandatory school leaving age is higher than 15, children under that age shall not be employed in the specific country.

Children and young persons under the age of 18 shall not conduct hazardous work. This includes work that could endanger their health, safety or morals. Where young workers are subject to compulsory education laws, they may work only outside of school hours.

2.3 Working Hours

Standard work weeks are not to exceed the maximum set by local law and should not on a regular basis exceed 48 hours (ILO Convention 1 (Hours of work)).

Overtime shall not exceed 12 hours per week, i.e., the total working week including overtime shall not exceed 60 hours. Exceptions to this are accepted in exceptional circumstances when regulated by a collective bargaining agreement or permitted by national law, and appropriate measures are taken to safeguard employees’ health, safety and wellbeing. All overtime work shall be voluntary, other than as permitted where the company is party to a collective bargaining agreement freely negotiated with labour organisations representing a significant portion of its workforce, then it may require overtime work in accordance with such agreement to meet short-term business demand.

Employees shall as a minimum be allowed at least one day off per seven-day week (ILO Convention 14 (Weekly rest)).

2.4 Wages and Benefits

As a minimum, there shall be full compliance with applicable laws regarding wages, working hours, overtime and benefits. In any event, wages should always be sufficient to meet basic needs and to provide some discretionary income (ILO Convention 131 (Minimum wage fixing)).

In compliance with local laws, workers shall be compensated for overtime at pay rates greater than regular hourly rates.

Deductions from wages shall not be permitted as a disciplinary measure.

The basis on which workers are paid is to be specified in a timely manner via a pay slip or similar documentation.

All employees shall be provided with written and understandable information about their employment conditions in respect to wages before they enter employment.

2.5 Humane Treatment

The supplier’s disciplinary policies and procedures shall be clearly defined and communicated to workers. Abuse or harassment shall not be tolerated in the workplace or in any work-related circumstance outside the workplace (UN Universal Declaration of Human Rights). Abuse and harassment include physical abuse or discipline, sexual harassment, verbal abuse, or other forms of intimidation, as well as the threat of any such form of abuse or harassment.

2.6 Non-Discrimination

There shall be no discrimination in hiring or in conjunction with employment practices such as promotions, rewards, access to training, termination, or retirement on the basis of gender, race, religion, national or social origin, ethnicity, caste, age, disability, sexual orientation, gender identifi-cation or expression, pregnancy, political affiliation, union membership or any other status protected by applicable law (ILO Convention 100 (Equal remuneration) and 111 (Discrimination (employment and occupation)), UN Convention on the Elimination of all Forms of Discrimination Against Women).

Supplier employees, or potential employees, should not be subjected to medical tests that could be used in a discriminatory way.

2.7 Freedom of Association

Suppliers shall respect employees’ freedom of association and recognise the right to collective bargaining in accordance with national laws and regulations (ILO Convention 87 (Freedom of association), 98 (Right to organize and collective bargaining), 135 (Workers’ representatives), 154 (Collective bargaining)). Where the right to freedom of association and collective bargaining is restricted under law, suppliers shall facilitate and not hinder, the development of parallel means of free and independent organisation and collective bargaining.

2.8 Regular Employment

Obligations to employees under international conventions, national law and regulations concerning regular employment shall not be avoided through the use of short-term contracting (such as contract labour, casual labour, or day labour) or other labour relationships. The duration and content of apprenticeship programmes shall be clearly defined.

2.9 Minority rights

Suppliers shall not engage in activities that cause or contribute to harm to the livelihoods of marginalised populations, such as through the irresponsible use of land, territories, or other natural resources. Suppliers shall carefully consider whether and how their activities may cause or contribute to such impact.

2.10 Privacy

Suppliers shall recognise and respect employees’ right to privacy and shall handle all personal data in accordance with laws and legislation.

Where surveillance is required, such as for safety purposes, investigating concerns or maintaining cyber security the impact on employees and others will be assessed and measures put in place to minimise interference with their privacy.

Suppliers shall carefully consider whether and how their products, services or technology, including if altered, may pose a potential risk to the right to privacy. Where such risk is identified, they shall put in place measures to prevent or mitigate the risk.

2.11 Humanitarian law

All applicable standards of international humanitarian law shall be respected.

Suppliers shall carefully consider whether and how their products or technology, including if altered, may be used in breach of humanitarian law, which may again constitute human rights breaches. Where such risk is identified, measures shall be put in place to prevent or mitigate the risk.

2.12 Conflict Minerals

Elprint is required to comply with regulatory and customer requirements regarding the prohibition and restriction of substances, including hazardous substances and conflict minerals.

All products supplied to Elprint shall be free from 3TGs and cobalt sourced from the Democratic Republic of the Congo (DRC) or adjoining countries. All suppliers shall, where applicable, yearly present to Elprint a list of their smelters using the Conflict Minerals Reporting Template (CMRT) developed by the Responsible Minerals Initiative (RMI).

Suppliers must, where applicable, certify that iron and steel products supplied by their company, wheresoever processed, do not incorporate or contain any iron and steel products originating in Russia, as prohibited by export control and sanctions laws (including but not limited to the Council Regulation (EU) No 833/2014 and the UK Russia (Sanctions) (EU Exit) Regulations 2019 as amended).

2.13 Occupational Safety

Worker exposure to potential safety hazards shall be minimised through proper design, engineering and administrative controls, preventative maintenance, and safe work procedures, as well as by ongoing safety training (ILO Convention 155 (Occupational safety and health) and Recommendation 164 (Occupational safety and health)).

Where hazards cannot be adequately controlled by these means, workers are to be provided with appropriate, well-maintained, personal protective gear. Workers shall receive regular health and safety training. Training shall be documented. Workers shall not be disciplined for raising safety concerns.

2.14 Emergency Preparedness

Emergency situations and events shall be identified and assessed, and their impact minimised by implementing emergency plans and response procedures, including emergency reporting, employee notification and evacuation procedures, worker training and drills, appropriate fire detection and extinguishing equipment, adequate exit facilities, and recovery plans.

2.15 Occupational Injury and Illness

Procedures and systems shall be in place to prevent, manage, track, and report occupational injury and illness, including provisions to encourage workers to report, classify and record injury and illness cases, provide necessary medical treatment, investigate cases and implement corrective actions to eliminate their causes, and to help workers return to work.

2.16 Sanitation, Food, and Housing

Workers are to be provided with appropriate, safe, and hygienic facilities. There shall be sufficient ventilation, ready access to clean toilet facilities, clean drinking water, facilities for sanitary food preparation, storage, and eating facilities. Worker dormitories provided by the supplier, or a labour agent are to be kept clean and safe, and provided with appropriate emergency exits, hot water for bathing or showering, and adequate heat and ventilation, as well as reasonable personal space along with reasonable entry and exit privileges.

2.16.1 WASH 4 WORK

Elprint has signed the Pledge for Access to Safe Water, Sanitation and Hygiene, WASH4WORK. We have committed to implement access to safe water, sanitation and hygiene at an appropriate level of standard for all employees under our direct control and across our value chain and among our suppliers. We expect all suppliers to provide all workers with access to:

• sufficient, free, physically accessible drinking water from clean drinking stations.
• adequate, improved, clean and convenient toilet facilities with adequate drainage and disposal systems.
• appropriate handwashing facility provisions in all toilets and washroom facilities, including clean water, soap and mechanisms for drying, to ensure personal hygiene.

Elprint is committed to deliver World-Class quality in everything we do, and to seek continuous improvements.

We expect our suppliers to work collaboratively and openly with us to seek best quality and continually improve our operations and products. We expect our suppliers, where applicable, to comply with UL, ISO9001, ISO14001, ISO45001 and/or IATF 16949.

Suppliers are required to have a precautionary approach towards environmental and climate challenges. In manufacturing operations, adverse effects on the community, the environment and natural resources are to be minimised while safeguarding the health and safety of the public.

4.1 Pollution Prevention and Resource Reduction

Waste of all types, including wastewater and energy, are to be reduced or eliminated at source or by practices such as the modification of production, maintenance and facility processes, materials substitution, conservation and the recycling and reuse of materials.

4.2 Hazardous Substances

Chemical and other materials that pose a hazard if released to the environment are to be identified and managed to ensure their safe handling, movement, storage, use, recycling or reuse, and disposal.

4.2.1 EU RoHS (Restriction of Hazardous Substances)

Suppliers must, where applicable, certify that all products supplied to Elprint comply with Article 4(1) of the EU RoHS (Restriction of Hazardous Substances) Directive (2011/65/EU) and the latest RoHS 3 directive (EU 2015/863).

4.2.2 EU REACH – Substances of Very High Concern (SVHC)

Suppliers must, where applicable, certify that all products supplied to Elprint comply with the REACH regulation (Regulation (EC) No. 1907/2006).

4.3 Wastewater and Solid Waste

Wastewater and solid waste generated from operations, industrial processes, and sanitation facilities are to be characterised, monitored, controlled, and treated as required by relevant legislation and permits prior to discharge or disposal.

4.4 Air Emissions

Air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting chemicals and combustion by-products generated from operations are to be characterised, monitored, controlled, and treated as required by relevant legislation and permits prior to discharge.

4.5 Greenhouse Gases (GHG)

Suppliers are required, where applicable, to identify, measure and report greenhouse gases generated from operations. Targets and plans should be established for how to reduce the GHG emissions.

4.6 Water

In areas vulnerable to a scarcity of freshwater, our suppliers are required to seek ways to measure and disclose the use of freshwater. Plans should also be established for how to reduce the use of freshwater in operations.

4.7 Sustainable Technologies

Suppliers are required to encourage the development and use of sustainable technologies, e.g., to choose sustainable effective technologies and components in their own production processes and strive to increase the use of technologies that reduce the environmental footprint.

4.8 Environmental Permits and Reporting

All required environmental permits, approvals, and registrations are to be obtained, maintained, and kept current, and their operational and reporting requirements are to be followed.

5.1 Anti-Corruption

Suppliers shall comply with laws and regulations related to bribery, corruption, fraud, and all other illegal business activities.

Suppliers shall not offer, request, accept, or receive any kind of undue benefit, service, or incentives to/ from government officials, international organizations, or other third parties for the purpose of obtaining or retaining business or business advantage, or personal benefits. This includes a prohibition on so called ‘facilitation’ payments or ‘grease’ payments intended to expedite or secure performance of a routine governmental action like obtaining visa or customs clearance unless there is a formal legal governmental fee schedule for such expediting services and the government provides receipts. Personal safety payments are permitted where there is an imminent threat to health or safety, but this must be documented. This applies whether the benefit is being offered directly or indirectly through an intermediary.

Suppliers shall not by intent or negligently search to get access to confidential information that may give an undue advantage.

Suppliers shall not, directly, or indirectly, offer, give, or accept gifts, hospitality or expense coverage that can give, or be perceived as, an improper advantage in connection with a person’s position, tasks or missions, unless the gift, etc. is of modest value. Representation, gifts, or expense coverage shall never be given or taken in connection with a bidding processes or negotiations related to contracts. The exception is a normal representation, when there is a legitimate business purpose, and the cost is kept within reasonable limits.

Cash or cash equivalents shall not be offered, given, or received.

Suppliers shall not sponsor political parties or politicians in connection with the contract entered into with Elprint. Suppliers must undertake any lobbying activities in compliance with all applicable laws.

5.2 Disclosure of Information

Information regarding business activities, structure, financial situation, and performance shall be disclosed in accordance with applicable regulations and prevailing industry practices.

5.3 Intellectual Property

Intellectual property rights shall be respected; the protection of technology and know-how shall be done by maintaining a system for secure processing, transmitting, storing, and destroying of information.

5.4 Competition

Suppliers shall always meet competitors in an honest and professional manner. The supplier shall not cause or be part of any breach of applicable competition laws and regulations, such as illegal cooperation on pricing, or illegal market sharing.

5.5 Data Privacy

Suppliers shall respect the employees and third parties’ privacy policies and shall record and/or monitor personal data in accordance with applicable data protection legislation.

If the supplier handles personal data on behalf of Elprint, it is required that the supplier signs a Data Processing Agreement. Such agreement regulates the supplier’s obligations to process personal data in accordance with applicable data protection legislation.

For information related to Elprint’s handling of personal data please see www.elprint.no for privacy statement. Elprint comply with applicable data protection legislation, including the EU General Data Protection Regulation (GDPR).

5.6 Money Laundering and Tax obligations

Suppliers shall be firmly opposed to all forms of money laundering and shall take steps to prevent its financial transactions from being used by others to launder money.

Suppliers shall report and pay its public taxes and fees according to the current law requirements.

5.7 Sanctions Denied Parties Lists or Embargoed Countries

Suppliers shall ensure that neither they nor their suppliers are involved in business with parties that are subject to relevant sanctions, denied parties lists, or embargoed countries. Elprint shall immediately be notified of any nonconformity.

5.8 Conflict of interest

Suppliers are required to avoid personal and financial interests which could conflict with their responsibilities to Elprint. All actual or potential conflict of interests should be immediately notified to Elprint and all affected parties.