Supplier Code of Conduct - FORTNA
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Supplier Code of Conduct

INTRODUCTION

FORTNA is committed to conducting its business consistent with the highest ethical standards and legal requirements wherever it operates and accordingly we expect and require our suppliers to uphold the same values.  Suppliers must comply with all applicable laws where they operate and must adhere to this Supplier Code of Conduct (hereinafter referred to as the “Code”) while doing business with or on behalf of any FORTNA entity.

 

SCOPE

The Code applies to all suppliers and their employees, agents, subcontractors and any one in their supply chain, wherever located.

 

BUSINESS INTEGRITY

  • No Corruption or Bribery

Suppliers must maintain a zero-tolerance policy prohibiting any form of corruption and bribery.  Kickbacks, inappropriate or lavish gifts are strictly prohibited. Suppliers are also required to fully adhere to the FORTNA Global Anti-Bribery and Corruption Policy.

  • Fair Competition

Suppliers must adhere to the principles of fair dealing, which means Suppliers  must not engage in price fixing, bid rigging, allocation of markets or customers, abuse of market power, or any other similar anti-compettive activities.

  • Avoid Conflicts of Interest

Suppliers must avoid any conflict of interest or situations giving the appearance of a conflict of interest when dealing with FORTNA.  Suppliers must also report to FORTNA any actual or potential conflict of interest between the Supplier and FORTNA, for example, any financial interest that a FORTNA employee may hold in the Supplier’s business.

  • Confidential Information

Suppliers must have adequate internal procedures and take every effort to protect any and all confidential information disclosed by FORTNA during the course of business.

  • Protection of Privacy

Suppliers must have adequate internal policies and procedures to protect personal data obtained from FORTNA (including without limitation name, email, phone number, etc.) and comply with applicable legal requirements with respect to the use, storage or transmission of such data.

  • Trade Compliance

Suppliers shall in strict compliance with all applicable trade and export control regulations.

  • Information Security

Suppliers must comply with FORTNA’s Information Security & Risk Vendor Compliance Program.

 

LABOR AND HUMAN RIGHTS 

  • Respect & Dignity

Suppliers shall demonstrate a zero-tolerance policy prohibiting any type of workplace discrimination, harassment, abuse or retaliation.

  • Fair Compensation

Suppliers must follow all applicable laws governing wage and benefits, and if these do not exist, we expect Suppliers to compensate their employees fairly and honestly.

  • Prohibition of Child Labor

Suppliers shall not employ workers under the statutory minimum working age in the applicable jurisdiction, and in the absence of such local laws, under the age of 16.

  • Prohibition of Forced Labor

Suppliers shall not use any type of forced labor, including without limitation forced recruitment for use in armed conflict, human trafficking, use in illegal activities.

  • Freedom of Association

Suppliers must recognize and respect employees’ legal right to freedom of association and collective bargaining without interference and without the fear of discrimination or retaliation.

  • Responsible Sourcing of Minerals

Suppliers must commit to sourcing minerals in an ethical and sustainable manner.  Suppliers are especially prohibited from purchasing “conflict minerals” from sources where Suppliers know or should have known that proceeds of sale may be used, directly or indirectly, to finance armed militias or contribute to human rights abuse.

 

HEALTH & SAFETY

Safety is one of FORTNA’s core values.  Suppliers must fully comply with applicable laws, regulations or standards governing occupational health and safety, and provide a safe and healthy workplace for their employees. Suppliers are expected to provide adequate safety and awareness training to their employees, subcontractors or anyone in their supply chain on workplace hazards, procedures, safeguards.  Use of adequate protective equipment is essential to workplace safety.

Accounting and Records

Suppliers must maintain accurate books, accounting, records, and other business documentation, and upon request shall make such records available to FORTNA for verifying compliance with this Code.

REPORTING CONCERNS

Suppliers with questions regarding the Code or who become aware of an actual or suspected violation of the Code, should promptly contact their FORTNA business point of contact or send an email to Compliance@mhsglobal.com.  Suppliers can also contact us anonymously using the FORTNA Compliance & Ethics Hotline, hosted by Navex, an independent third-party provider, via www.ethicspoint.com (select Fortna Inc.) or by calling the applicable number listed below:

 

Austria            0-800-200-288 (at the English prompt dial 844-564-3371)

Canada            1-844-564-3371 (English primary language) or 1-855-350-9393 (Other primary language)

China              10-811 (Southern) or 108-888 (Northern) (at English prompt dial 844-564-3371)

Germany         0-800-225-5288 (at the English prompt dial 844-564-3371)

Italy                 800-172-444 (at the English prompt dial 844-564-3371)

Mexico            800-288-2872 or 800-112-2020 (at the English prompt dial 844-564-3371)

Poland             0-0-800-111-1111 (at the English prompt dial 844-564-3371)

South Africa   0-800-90-0123 (at the English prompt dial 844-564-3371)

The Netherlands         0800-022-9111 (at the English prompt dial 844-564-3371)

UK                  0-800-89-0011 (at the English prompt dial 844-564-3371)

US                   1-844-564-3371

Vietnam          1-201-0288 or 1-228-0288 (at the English prompt dial 844-564-3371)

 

FORTNA reserves the right at all times to verify the compliance with these obligations through audit with or without the support of third party experts and / or internationally recognized organizations focused on human rights and child labor (e.g. Amnesty International, UNICEF) for the execution of the verification. This includes access to all relevant information as well as to all persons, locations and documentation concerned.

Any Supplier violation of the Code shall be considered as a material breach. FORTNA reserves the right to take legal action, including suspending or terminating the business relationship.