I. PLZ’s Expectations of its Suppliers
At PLZ Aeroscience (“PLZ”), we pride ourselves on consistently delivering outstanding service and quality products to our customers. As the North American leader in specialty aerosol and liquid product manufacturing, we put a premium on safety and compliance and align ourselves with business partners that share those values. This Supply Chain Code of Conduct (“Code”) establishes standards for conducting business with PLZ in an ethical, responsible, and legal manner. It also protects the integrity and continuity in our supply chain so that we may continue to drive value for our customers.
PLZ expects each of its business partners to:
- Act with honesty and integrity.
- Understand and comply with the laws and regulations that apply to your business in the countries where you do business.
- Read, understand, and follow this Code.
- Cooperate with inquiries regarding compliance with this Code.
This Code applies to all suppliers that do business with PLZ and distributors of PLZ-branded products, including their employees, representatives, agents, subcontractors, and other sub-tier sources (“Suppliers”). Suppliers must promptly inform their PLZ contact if a situation develops that causes the Supplier to violate this Code. PLZ may require the immediate removal of any Supplier or Supplier representative who conducts business unlawfully or inconsistent with this Code.
We will update this Code periodically
II. Safety, Health, and the Environment
PLZ puts safety first. We believe it is our duty to protect the health and safety of our employees, customers, neighbors, and environment. Many of our products include chemicals that require special handling to be transported, used, or disposed of safely and minimize the impact on the environment. We demand that our Suppliers have a safe and secure handling process to protect the people and environment that come in contact with the materials supplied to us or services provided to us. Accordingly, each Supplier is responsible for maintaining a safe workplace and conducting operations in compliance with applicable safety, health, and environmental laws, regulations, and standards.
PLZ values companies that strive to minimize any adverse impact on the environment. PLZ strongly encourages its Suppliers to conserve natural resources and energy and reduce or eliminate waste.
III. Compliance with the Laws
Each Supplier must comply with all laws and regulations applicable to its business in the countries where it does business. While laws, regulations, business practices, and customs can vary greatly from one country to the next, this Code sets forth the minimum requirements that all of PLZ’s Suppliers must meet.
A. Anti-Corruption and Gifts and Entertainment
Offering anything of value (e.g., gifts, entertainment, favors, charitable contributions, job offers, etc.) or paying bribes to win business or obtain an unfair advantage is unacceptable. We would rather experience losses or delays in business than be associated with any corrupt behavior. Bribes and other corrupt payments by anyone conducting business for PLZ or in connection with PLZ products may violate multiple anti-corruption laws and expose individuals, PLZ’s Suppliers, and PLZ to civil and criminal liability and severe penalties. PLZ’s Suppliers are prohibited from engaging in corruption, extortion, or embezzlement in any form.
Suppliers must exercise caution in giving and receiving gifts or entertainment in connection with PLZ business. Any gift must be of moderate value, be customary for the region, and comply with the recipient’s internal policies. We hold ourselves to the same standard. We ask that Suppliers only give and accept gifts to or from PLZ employees or representatives that conform to this standard.
B. Labor Practices
PLZ expects its Suppliers to share its commitment to human rights and equal opportunity in the workplace. Suppliers must conduct their employment practices in full compliance with all applicable laws and regulations, and must, without limitation:
- Provide a humane, safe workplace.
- Comply with all wage and hour laws or regulations and not use child labor.
- Use only voluntary labor. Human trafficking of involuntary labor through threat, force, fraud, physical abuse, compulsory debt, or other coercion is strictly prohibited whether done directly or through a third-party recruitment or placement agency.
- Not discriminate in hiring and employment practices based on characteristics that are protected by local law.
- Not intentionally source materials from supply chains associated with human trafficking and take reasonable efforts to assure that its own Suppliers comply with this requirement.
C. Fair Competition
Suppliers are required to act truthfully in advertising, sales, and competition. Suppliers are required to comply with applicable antitrust and competition laws where they do business. These laws prohibit agreements between competitors that affect prices or otherwise limit competition.
D. Anti-Money Laundering
PLZ conducts business only with reputable Suppliers involved in legitimate business activities using funds from legitimate sources. PLZ’s Suppliers are required to comply with applicable laws relating to money laundering.
E. Trade Compliance
PLZ’s Suppliers are required to comply with all applicable US and international trade laws and regulations, including import, export, and re-export controls regulations, as well as applicable embargoes, sanctions, and anti-boycott laws.
F. Conflict Minerals
Suppliers are expected to ensure that products supplied to PLZ do not contain metals derived from minerals or their derivatives originated from conflict regions that directly or indirectly finance or benefit armed groups.
PLZ requires its Suppliers to know, understand, and comply with all applicable laws governing product safety and quality. Suppliers must meet generally recognized or contractually agreed quality requirements in order to provide goods and services that consistently meet PLZ’s needs, perform as warranted, and are safe for their intended use.
V. Business Integrity
A.Protecting PLZ Information
PLZ derives significant value from its proprietary information and the proprietary information that it holds in confidence for its customers. Suppliers must protect that information and use it only for authorized purposes for the benefit of PLZ and its customers. This means only sharing PLZ’s and its customers’ proprietary information on a need-to-know basis, with someone who is obligated to keep it confidential, and with PLZ’s authorization. Suppliers must also follow all applicable data privacy laws.
B. Avoiding Conflicts of Interest
Suppliers must avoid involvement in actual or apparent conflicts of interest between the supplier’s interests and the interests of PLZ. A conflict of interest occurs when an individual has an interest in both sides of a transaction, whether directly or through a family member. For example, a Supplier may not negotiate pricing with a family member who is an employee of PLZ or hold a financial interest (other than nominal investments in public companies) in a PLZ competitor.
C. Maintaining Business Records
Each Supplier must maintain accurate records concerning the business it conducts with PLZ, including compliance with all applicable legal requirements regarding the creation, retention, and disposal of those records.
VI. Speak Up
PLZ strongly encourages anyone who knows of or suspects behavior that violates this Code to alert your primary PLZ contact or a member of PLZ management. If your concern is not resolved, please contact Jessica Nolan, Senior Vice President, General Counsel, at Jessica.Nolan@PLZAeroscience.com or 630-543-7600.
January 1, 2019