Supplier Code of Conduct
Last updated: 19 July 2024
CONTENTS
Introduction
1. Work and Human Rights
2. Business Ethics and Integrity
3. Respect for and Enhancement od Local Communities
4. Respect for and Protection of Natural Ecosystems
5. Product Liability
6. Compliance with this Code of Conduct and Form of Dissemination
INTRODUCTION
THE TYRE COLLECTIVE LTD. (hereinafter also referred to as the “Company”) has adopted the principle of combining the goals of achieving economic profit and achieving social and environmental objectives. It has chosen, within the framework of its corporate management, to adhere to and respect ethical and moral values based on the principles of fairness, honesty, and transparency, in accordance with national and international standards. It considers the overall impact of its decisions in any field, whether environmental, social or governance, to be a fundamental element in its business, and it always has the interests and safety of its stakeholders at heart.
This Code of Conduct for Suppliers (hereinafter the “Code”), is a non-exhaustive expression of the Company’s principles and values, and requires strict compliance from all its suppliers, subcontractors and sub-suppliers (hereinafter jointly, the “Suppliers” and individually, the “Supplier”).
The Company intends its Suppliers to act according to the same principles, respecting and enforcing them, and adhering to the same philosophy in the management of their own businesses.
This Code requires compliance with national laws, international agreements, and other laws applicable to the Company’s and its Suppliers’ respective operations, and the principles stated in the Conventions of the International Labour Organisation, the Universal Declaration of Human Rights, the OECD Guiding Principles, and the principles of the Global Compact. In case of conflict between provisions in the aforementioned laws, agreements, conventions, declarations, or principles, the provision(s) with the highest social, environmental, and business standards shall prevail.
This Code is not intended to conflict with the terms and conditions of any contracts between Suppliers and the Company. If a contractual requirement between Suppliers and the Company is more restrictive than the requirements of this Code, the more restrictive contractual requirement shall apply.
Any breach by a Supplier of this Code and/or of the standards in force at national and international level may result in the early termination of their contract/relationship with the Company.
1. WORK AND HUMAN RIGHTS
The Company promotes the principle of work as a free choice by an individual.
Suppliers must comply with the labour laws and the regulations in force in their respective countries and, in particular, with the following provisos considered by the Company to be of fundamental importance. Our suppliers are required to respect human rights, including workers’ rights, in their businesses and transactions, recognising without distinction the freedom and equality in dignity and rights of all human beings, as enshrined in the International Bill of Rights and the fundamental Conventions of the International Labour Organisation (“ILO”). The Company encourages Suppliers to adopt and promote internal mechanisms and tools to ensure that their employees are able to report actual or suspected human rights violations.
1.1. Forced labour
Suppliers must condemn and refrain from all forms and types of forced, compulsory, and exploitative labour, including labour without a work permit, and labour under threat and/or punishment.
Suppliers must comply with applicable legislation to punish illegal, clandestine, and undeclared work.
1.2. Child labour
Suppliers must condemn and refrain from any form of child labour, in line with applicable legislation, relevant ILO Conventions, and the International Convention on the Rights of the Child.
Suppliers must not directly or indirectly employ or otherwise obtain services from any child unless he or she has completed the period of compulsory education and has reached the age of 16 (sixteen), subject to any relevant exceptions provided under applicable laws and regulations. If a Supplier employs a child between the ages of 16 (sixteen) to 17 (seventeen), the child must not work at night or be exposed to dangerous activities.
1.3. Harassment and abuse
Suppliers shall treat their employees with respect and dignity, with no tolerance for corporal punishment, psychological or physical harassment, or any other kind of abuse.
1.4. Salaries and benefits
Suppliers must remunerate their employees and collaborators in accordance with applicable legal and regulatory provisos in addition to any collective agreements adopted. Pay provided to employees must reasonably meet the basic needs and living standards, and respect the dignity of, a reasonable individual. (Suppliers may of course exceed such pay standards.) Suppliers must grant all employees the benefits provided for in collective bargaining, company agreements and any other applicable individual or collective agreements.
1.5. Discrimination
Suppliers must not discriminate against their employees and staff.
Suppliers must ensure that they do not discriminate in hiring, access to training, promotion, or termination on the basis of sex, race, religion, age, disability, sexual orientation, political opinion, nationality, or social and ethnic origin.
1.6. Freedom of association
Suppliers shall respect and recognise the right of each employee to bargain collectively in order to create or join a trade union of their choice without incurring any sanctions, discrimination or harassment.
1.7. Working hours
Suppliers shall comply with the working hour limits set by the laws of the country in which the employment is provided and shall not impose excessive overtime. The total number of hours worked per week by Supplier’s employees shall not exceed 48 (forty-eight) hours, including all overtime, and there shall be at least one day of rest every seven days or, in any case, the maximum number days rest established by the laws in force in the country.
1.8. Health and safety
Suppliers must provide their workers with a safe and healthy working environment to avoid accidents or injuries, including those related to working with machinery.
Suppliers shall have systems in place to detect, avoid, or eliminate any threat to the health and safety of their employees, in accordance with local and international regulations and laws currently in force.
2. BUSINESS ETHICS AND INTEGRITY
The Company promotes and respects the principles of legality, loyalty and fairness.
Suppliers must comply with these principles and operate with the utmost transparency in compliance with the legal and regulatory provisos applicable in the context in which they operate, in addition to any commitments they have undertaken with the Company.
The Company encourages recipients to adopt policies and implement procedures to ensure compliance with applicable laws and regulations in order to protect the integrity of the organisation and its operations.
2.1. Competition based on merit and fair competition
Our Suppliers must compete solely on the basis of their own merit and the quality of their products and services.
Our Suppliers shall not pay bribes or unlawful inducements in any form or amount to anyone in any place and under any circumstances, for any purpose, either on behalf of the Company, their own behalf, or on behalf of third parties.
Suppliers must not engage in anticompetitive behaviour, either on behalf of the Company, their own behalf, or on behalf of third parties.
2.2. Conflicts of interest
Suppliers shall avoid any conflicts of interest in relation to any business with the Company.
Supplier shall report to the Company all instances of actual or apparent conflict that may interfere inappropriately between its own interests and those of the Company.
2.3. Combating money-laundering
Suppliers shall avoid business or financial relationships where there is or ought to be a reasonable suspicion that their counterparts may engage in money laundering.
Suppliers must take measures to regulate the management of financial flows, prohibiting any irregularities that, according to normal professional diligence, give rise to suspicions as to the origin of the funds received.
2.4. Relationships with Public Administration
Suppliers may not offer, directly or through an intermediary, money or any other inducement of any kind to a public official or a public service appointee, his/her family or any other person connected with him/her, or an organisation, entity, or similar owned or operated by, or affiliated with, such person. Suppliers will not seek to establish favourable personal relationships with the aim of directly or indirectly influencing their business.
2.5. Transparency of information
Suppliers must provide clear and accurate information about their methods and resources, their production sites, and the features of the products or services they provide, and refrain from any misleading statements.
2.6. Confidentiality and intellectual property
Suppliers must comply with applicable laws and regulations on the protection of personal data.
Supplier shall treat any information – designs, documents, samples, prototypes, etc. – brought to the knowledge of the Supplier in the course of the performance of its contractual obligations as confidential.
Supplier shall not use trademarks and signs belonging to the Company, whether registered or used by it at any time, for any purpose, other than in accordance with instructions received from the Company. Unless expressly authorised, a Supplier may not use the name and trademarks of the Company by reference to its own trading concern.
3. RESPECT FOR AND ENHANCEMENT OF LOCAL COMMUNITIES
The Company promotes and implements actions to support, sustain, and develop the local communities in which it operates, including through voluntary and educational activities, financial and material donations, and other specific projects.
The Company encourages Suppliers to adopt policies of care and respect for the communities in which they operate, both through actions to reduce negative outcomes and through actions and projects to generate and distribute value.
3.1. Tradition, culture
Suppliers must respect the culture and the traditions of the communities affected by their businesses and/or transactions, minimising any inconvenience caused to local communities and favouring pathways for sharing and cooperation.
3.2. Cooperating with stakeholders
Suppliers shall be committed to creating local employment and working with communities, individuals and collective stakeholders, institutions and governments to improve the social, cultural, and educational well-being of the communities in which they operate.
3.3. Supporting the local productive and economic fabric
Suppliers shall support, as far as possible, the local economic fabric and production, including through the use of local staff and suppliers, in order to contribute to the economic and social development of communities and populations.
4. RESPECT FOR AND PROTECTION OF NATURAL ECOSYSTEMS
The Company pays the utmost attention to environmental sustainability, making a strong commitment to eliminating carbon dioxide and greenhouse gas emissions in the atmosphere and reducing the use of disposable plastic products. The Company actively promotes respect for the environment for the benefit of today’s and tomorrow’s generations, with a view to a sustainable future.
Suppliers are encouraged to monitor and work towards the containment or reduction of emissions related to their businesses. Suppliers are also encouraged to implement processes to reduce or eliminate the use of single-use plastics within their business premises.
4.1. Protecting the environment and respecting animals
Suppliers must comply with the laws and regulations applicable to their sector of business, and endeavour, wherever possible, to adopt behaviour to reduce or eliminate negative environmental outcomes related to their businesses.
4.2. Waste management
Suppliers must follow the laws and regulations in force regarding the management of waste, both hazardous and non-hazardous, and ensure its proper treatment, storage, transfer, and disposal. Our Suppliers are encouraged to take measures to enhance waste sorting processes, including through active recycling and reuse policies, and the replacement of plastic packaging with more sustainable solutions.
4.3. Management of energy sources, emissions and water consumption
Suppliers shall monitor the consumption of water and energy resources, seeking, where possible, solutions that enhance the role of sources with low environmental impact. Suppliers shall be committed to reducing their consumption of water and energy resources that do not have a low environmental impact, improving the efficiency of their production tools, and the sustainability of their ordinary and extraordinary operations. Suppliers shall support awareness of greenhouse gas emissions by evaluating policies for monitoring or offsetting emissions.
5. PRODUCT LIABILITY
The Company shall provide its customers with quality products, guaranteeing maximum attention to the safety of the materials used in the production process.
Suppliers are encouraged to look for the best possible solutions to provide their customers with safe and high quality products and materials.
5.1. Quality and sustainable product development
Suppliers shall pay the utmost attention to the quality and safety of all materials used, both at the procurement stage and in production, encouraging the use of recyclable, renewable, reusable, and locally sourced materials.
5.2. Chemical safety of products
Suppliers shall comply with the provisions of law concerning the use of hazardous or noxious substances and refrain from marketing materials and/or products that potentially endanger the health of consumers and workers. The Supplier shall ensure adequate training and safety equipment for employees who may come into contact with such substances throughout the production chain.
5.3. Traceability of materials and products
Suppliers shall guarantee the traceability of products and communicate information about the places of procurement and processing of the materials used, upon request.
6. COMPLIANCE WITH THIS CODE OF CONDUCT AND FORM OF DISSEMINATION
Supplier shall cooperate with the Company and its representatives in monitoring and assessing its compliance with the expectations set out in this Code when performing work for the Company. Supplier must also provide the Company, upon specific request, with additional information and certification attesting to compliance with this Code.
In the event of any wrongdoing, Supplier shall cooperate fully with any relevant investigation conducted by the Company. Supplier and its business partners shall remedy any non-compliance identified during assessment.
Supplier acknowledges and agrees that it is solely responsible for full compliance with this Code by its directors, officers, employees, representatives, and business partners.
The Company may amend this Code from time to time. The Company undertakes to promptly notify the Supplier of any changes to the Code, and to make it available on its website at all times.