NEUTRONIC STAMPING & PLATING has built a reputation of honesty, integrity and fairness by conducting our business according to the highest ethical standards. The NEUTRONIC STAMPING & PLATING Code of Conduct, Human Rights Policy embody these core values and reflect Neutronic Stamping & Plating commitment to operate with the highest level of integrity, while demonstrating respect for human rights at NEUTRONIC STAMPING & PLATING and throughout its supply chain.
As part of this commitment, NEUTRONIC STAMPING & PLATING requires our business partners and the supply chain to share in these same core values and business practices. This Code of Conduct governs all employees of NEUTRONIC STAMPING & PLATING and any company or entity that sells or seeks to sell any products or services to NEUTRONIC STAMPING & PLATING and/or any of its affiliates, whether directly or indirectly through its employees, affiliates, distributors, subcontractors, agents or other representatives.
NEUTRONIC STAMPING & PLATING expects its employees and the supply chain to operate using the highest ethical and legal principles. Suppliers are responsible for ensuring that any employees, affiliates, distributors, subcontractors, agents or other representatives of Supplier providing products or services to NEUTRONIC STAMPING & PLATING or to Neutronic Stamping & Plating customers on behalf of NEUTRONIC STAMPING & PLATING read and comply with this NEUTRONIC STAMPING & PLATING Supplier Code of Conduct.
This NEUTRONIC STAMPING & PLATING Code of Conduct applies to all relevant aspects of Neutronic Stamping & Plating employees and its Suppliers. NEUTRONIC STAMPING & PLATING Suppliers must comply with applicable laws, rules and regulations (collectively, “Laws”) in all countries where NEUTRONIC STAMPING & PLATING and its affiliates conduct business. Specifically, we expect all Suppliers to adhere to the following standards, consistent with Neutronic Stamping & Plating core values of Integrity, Respect, Trust, Simplicity, and Shared Risk, and to take reasonable and appropriate efforts to ensure that their suppliers do the same:
1. WE DO NOT TOLERATE INHUMANE TREATMENT: NSP and its Suppliers must treat all workers with dignity and respect. Suppliers must not subject workers to, or threaten to subject workers to, harsh and inhumane treatment, including but not limited to sexual harassment, sexual abuse, corporal punishment, mental or physical coercion or verbal abuse. Disciplinary policies and procedures related to this requirement shall be clearly communicated to workers. Where supplier provides housing for workers, housing must comply with applicable housing and safety standards. All workers must be given accurate work agreements in a language understood by the worker.
2. WE DO NOT UTILIZE CHILD LABOR: NSP and its Suppliers will not directly or indirectly employ workers that are younger than the applicable minimum age specified by applicable Laws. Under no circumstances shall a Supplier employ any worker under the age of 15. Additionally, workers under the age of 18 may not be required to perform work that may be hazardous to their health or safety.
3. WE DO NOT UTILIZE FORCED LABOR: NSP and its Suppliers will not utilize or source products or services from entities associated with forced, bonded, indentured, involuntary or exploitative prison, trafficked or slave labor. Involuntary labor includes transporting, harboring, recruiting, transferring, receiving or employing persons by means of threat, force, coercion, abduction or fraud for labor or services. All work must be voluntary, and workers shall be free to terminate their employment at any time. There shall be no unreasonable restrictions on entering, exiting or movement within company provided facilities. Suppliers must not withhold worker identity or immigration documents and must not charge workers or potential workers recruitment fees. Suppliers must provide return transportation at the end of their work period if workers were brought to the country for the purpose of working for their organization.
4. WE PROTECT SAFETY AND WELL-BEING IN THE WORKPLACE: NSP and its Suppliers strive to promote improved health and safety in conducting their businesses. NSP and its Suppliers provide workers with a safe and healthy work environment, provide necessary medical treatment and implement corrective actions to eliminate causes of injury. We also ensure that employees, affiliates, agents or other representatives comply with NEUTRONIC STAMPING & PLATING policies and applicable site requirements while on-site at any NEUTRONIC STAMPING & PLATING location or at an NEUTRONIC STAMPING & PLATING supplier and customer location on behalf of NSP.
5. WE RESPECT WORKERS’ RIGHTS: NSP and its Suppliers must respect workers’ rights to associate freely and in compliance with applicable Laws, without discrimination, intimidation or harassment, as well as respect the right of workers to refrain from such activities. Workers and/or their representatives should be able to openly communicate and share ideas and concerns with management regarding working conditions and management practices without fear of discrimination, intimidation or harassment.
6. WE COMPLY WITH EMPLOYMENT LAWS: NSP and its Suppliers must comply with all applicable wage and hour Laws, including those relating to minimum wage, overtime hours and other elements of compensation, and must provide all legally mandated benefits. Suppliers will not require employees to work more than the maximum number of hours permitted under applicable Laws. For each pay period, NSP and its Suppliers shall provide workers with a timely and comprehensible wage statement that includes enough information to enable workers to verify that they have received accurate compensation for work performed.
7. WE PROHIBIT DISCRIMINATION, HARASSMENT AND RETALIATION: NSP and its Suppliers will treat their employees with respect and dignity and to refrain from any unlawful harassment and discrimination. Suppliers will not discriminate against any person because of their race, color, gender, religion, ethnicity or national origin, age, disability or other medical condition, sexual orientation, gender identity, genetic information, pregnancy, marital status, veteran status, political affiliation, union membership or any other basis protected by applicable Laws.
8. WE COMPLY WITH ENVIRONMENTAL LAWS: NSP and its Suppliers strive to be more “eco-efficient” in conducting their businesses, which means striving to create more environmentally efficient product and services while using fewer resources and creating less waste and pollution. Suppliers must reduce their impact on the environment through the conservation of natural resources, reduced energy consumption and GHG emissions, reduced waste and responsible chemical management.
9. WE COMPETE FAIRLY: NSP and its Suppliers are expected to deal fairly with employees and representatives as well as other business partners. We should not take unfair advantage through manipulation, concealment, abuse, misrepresentation of material facts or any other unfair dealing. Suppliers will not engage in collusive bidding, price fixing, price discrimination or other unfair trade practices in violation of applicable antitrust and competition Laws. We will uphold fair business standards in advertising, sales and competition.
10. WE PROTECT TRADE SECRETS: In addition to protecting Neutronic Stamping & Plating assets and information, suppliers must respect and refrain from infringing upon the intellectual property rights of others, including patents, trademarks, copyrights and other proprietary rights.
11. WE COMPLY WITH INTERNATIONAL TRADE LAWS: NSP and its Suppliers comply with all export import Laws, including all applicable labeling requirements, customs duty requirements and other Laws applicable to their international business activities.
12. WE DO NOT MAKE IMPROPER PAYMENTS OR GIFTS: NSP and its suppliers work against corruption in all its forms and are prohibited from engaging in extortion, embezzlement and other corrupt activities. We comply with all applicable anti-corruption Laws of the countries in which they operate, such as the U.S. Foreign Corrupt Practices Act, and, as applicable, the UK Anti-Bribery Act, the OECD Anti-Bribery Convention and any other international anti-corruption conventions. Suppliers will not offer or accept bribes or employ other means to obtain an undue or improper advantage. Paying or facilitating the payment of bribes, kickbacks and similar payments to government officials or to NEUTRONIC STAMPING & PLATING employees or agents acting on its behalf is prohibited. NSP and its suppliers may not offer gifts of more than minimal value or lavish entertainment to employees. When business meals and entertainment are appropriate to further a legitimate business purpose, any associated expenses may not be extravagant in nature.
13. WE SAFEGUARD NEUTRONIC STAMPING & PLATING CONFIDENTIAL INFORMATION: NSP employees and it Suppliers must protect the Confidential Information entrusted to them by NEUTRONIC STAMPING & PLATING and its affiliates, customers or suppliers. Confidential Information may only be used and disclosed in a manner authorized by NSP. “Confidential Information” includes any business information of NEUTRONIC STAMPING & PLATING or its affiliates, customers or suppliers that is not generally known to the public.
14. WE SOURCE OUR MATERIALS RESPONSIBLY: Pursuant to its Responsible Materials Policy, NEUTRONIC STAMPING & PLATING and its employees are committed to the responsible sourcing of materials and expects the same commitment from its Suppliers. Upon request of NSP, Suppliers shall determine whether any products provided by Suppliers contain tin, tantalum, tungsten, gold or any other material. Suppliers shall also take such necessary actions and provide such additional information concerning the materials for which information is requested in the format requested by NEUTRONIC STAMPING & PLATING as may be necessary in order (1) for NEUTRONIC STAMPING & PLATING to comply with applicable Laws and (2) to demonstrate compliance by the Supplier with Neutronic Stamping & Plating policies and procedures, including those relating to responsible sourcing.
15. WE REQUIRE COMPLIANCE WITH THE CODE OF CONDUCT: NSP and its suppliers must establish and maintain a process for ensuring compliance with the Code of Conduct. This includes communicating the requirements of this Code to all employees, affiliates, distributors, subcontractors, agents and other representatives of the Supplier who provide products or services to NEUTRONIC STAMPING & PLATING or to Neutronic Stamping & Plating customers on behalf of NSP. Suppliers must maintain all documentation necessary to demonstrate compliance with the NEUTRONIC STAMPING & PLATING Supplier Code of Conduct. Upon Neutronic Stamping & Plating request, Suppliers should be prepared to provide NEUTRONIC STAMPING & PLATING or its affiliates access to such documentation. This Code of Conduct may be updated by NEUTRONIC STAMPING & PLATING from time to time. All references herein to the NEUTRONIC STAMPING & PLATING Code of Conduct refer to the most current version of this Supplier Code of Conduct, available at www.neutronic.com
Neutronic Stamping & Plating Leadership Team
October 30, 2024, Ver 1