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Supplier Code of Conduct

Latest updated on September 30st, 2023

In accordance with the core concept of sustainable operation, HIWIN has established short, medium and long-term sustainable development goals in three aspects: economy, environment and society (ESG), in response to The Sustainable Development Goals (SDGs) of the United Nations. HIWIN is committed to ensuring that working conditions in its supply chains are safe, that business operations are environmentally responsible and conducted ethically, and that workers are treated with respect and dignity. To this end, HIWIN established this Supplier Code of Conduct (“Code”) and requires our suppliers to operate in accordance with the principles outlined in this Code. In addition, HIWIN also expects our suppliers to hold their suppliers, contractors, and service providers to the standards defined in this Code.

HIWIN will assess its suppliers’ compliance with this Code when making cooperation decisions. Suppliers are expected to fully understand and abide by the Code, and are highly encouraged to contact HIWIN for any questions. It is hoped that through cooperation, communication, HIWIN ESG evaluations, audits, conflict minerals due diligence, and continuous improvement with suppliers, we can achieve a positive cycle in the supply chain, and work together to improve Responsibilities of Social Citizens.

The provisions in this Code are derived primarily from the Responsible Business Alliance (RBA) Code of Conduct and are in alignment with the international standards such as ISO45001, ISO14001, and ISO14064-1. The Code contains six topics including Labor, Health and Safety, the Environment, Business Ethics, Climate Change and Disclosure, and the elements of an acceptable system to manage conformity to this Code.

A. LABOR

Suppliers are committed to uphold the human rights of workers, and to treat them with dignity and respect as understood by the international community. This applies to all workers including temporary, migrant, student, contract, direct employees, and any other type of worker.

The labor standards are:


A1 Freely Chosen Employment

A1.1 Forced, bonded (including debt bondage) or indentured labor, involuntary or exploitative prison labor, slavery or trafficking of persons shall not be used. This includes transporting, harboring, recruiting, transferring or receiving persons by means of threat, force, coercion, abduction or fraud for labor or services.

A1.2 As part of the hiring process, workers must be provided with a written employment agreement in their native language that contains a description of terms and conditions of employment prior to the worker departing from his or her country of origin and there shall be no substitution or change(s) allowed in the employment agreement upon arrival in the receiving country unless these changes are made to meet local law and provide equal or better terms.

A1.3 All work must be voluntary, and workers shall be free to leave work at any time or terminate their employment without penalty if reasonable notice is given as per worker’s contract.

A1.4 Employers and agents may not hold or otherwise destroy, conceal, or confiscate identity or immigration documents, such as government-issued identification, passports, or work permits. Employers can only hold documentation if such holdings are required by law. In this case, at no time should workers be denied access to their documents.

A1.5 There shall be no unreasonable restrictions on workers’ freedom of movement in the facility in addition to unreasonable restrictions on entering or exiting company provided facilities.

A1.5 There shall be no unreasonable restrictions on workers’ freedom of movement in the facility in addition to unreasonable restrictions on entering or exiting company-provided facilities including, if applicable, workers’ dormitories or living quarters.

A1.6 Workers shall not be required to pay employers’ or agents’ recruitment fees or other related fees for their employment.

A2 Young Workers

A2.1 Child labor is not to be used in any stage of manufacturing. The term “child” refers to any person under the age of 15, or under the age for completing compulsory education, or under the minimum age for employment in the country, whichever is greatest.

A2.2 Suppliers shall implement an appropriate mechanism to ensure that child labor is not employed. The use of legitimate workplace learning programs, which comply with all laws and regulations, is supported.

A2.3 Workers under the age of 18 (Young Workers) shall not perform work that is likely to jeopardize their health or safety, including night shifts and overtime.

A2.4 Suppliers shall provide appropriate support and training to all student workers, ensure proper management of student workers through proper maintenance of student records, rigorous due diligence of educational partners, and protection of students’ rights in accordance with applicable law and regulations. In the absence of local law, the wage rate for student workers, interns and apprentices shall be at least the same wage rate as other entry-level workers performing equal or similar tasks.

A3 Working Hours

A3.1 Studies of business practices clearly link worker strain to reduced productivity, increased turnover and increased injury and illness. Working hours are not to exceed the maximum set by local law.

A3.2 A workweek should not be more than 60 hours per week, including overtime, except in emergency or unusual situations.

A3.3 Workers shall be allowed at least one day off every seven days.

A4 Wages and Benefits

A4.1 Compensation paid to workers shall comply with all applicable wage laws, including those relating to minimum wages, overtime hours and legally mandated benefits. Deductions from wages as a disciplinary measure shall not be permitted.

A4.2 In compliance with local laws, workers shall be compensated for overtime at pay rates greater than regular hourly rates. Deductions from wages as a disciplinary measure shall not be permitted.

A4.3 For each pay period, workers shall be provided with a timely and understandable wage statement that includes sufficient information to verify accurate compensation for work performed.

A4.4 All use of temporary, dispatch and outsourced labor will be within the limits of the local law.

A5 Humane Treatment

A5.1 There is to be no harsh or inhumane treatment including any type of gender-based violence, sexual harassment, sexual abuse, corporal punishment, mental or physical coercion, bullying, public shaming, or verbal abuse of workers; nor is there to be the threat of any such treatment.

A5.2 Disciplinary policies and procedures in support of humane treatment requirements shall be clearly defined and communicated to workers.

A6 Non-Discrimination/Non-Harassment

A6.1 Suppliers should be committed to a workplace free of harassment and unlawful discrimination.

A6.2 Companies shall not engage in discrimination or harassment based on race, color, age, gender, sexual orientation, gender identity and expression, ethnicity or national origin, disability, pregnancy, religion, political affiliation, union membership, covered veteran status, protected genetic information or marital status in hiring and employment practices.

A6.3 Workers shall be provided with reasonable accommodation for religious practices.

A6.4 Workers or potential workers should not be subjected to medical tests that could be used in a discriminatory way, including pregnancy or any other physical exams.

A7 Freedom of Association

A7.1 In conformance with local law, suppliers shall respect the right of all workers to form and join trade unions of their own choosing, to bargain collectively and to engage in peaceful assembly as well as respect the right of workers to refrain from such activities.

A7.2 Workers and/or their representatives shall be able to openly communicate and share ideas and concerns with management regarding working conditions and management practices without fear of discrimination, reprisal, intimidation or harassment.

B. HEALTH and SAFETY

Suppliers recognize that in addition to minimizing the incidence of work-related injury and illness, a safe and healthy work environment enhances the quality of products and services, consistency of production and worker retention and morale. Suppliers also recognize that ongoing worker input and education are essential to identifying and solving health and safety issues in the workplace.

The health and safety standards are:


B1 Occupational Safety

B1.1 Worker potential for exposure to safety hazards are to be identified and assessed, and controlled through the Hierarchy of Controls, including elimination of hazards, use of alternative processes or materials, proper design, engineering and administrative controls, preventative maintenance and safe work procedures, and ongoing safety training.

B1.2 Workers are to be provided with appropriate, well-maintained, personal protective equipment and educational materials about risks to them associated with these hazards.

B1.3 Reasonable steps must also be taken to remove pregnant women/nursing mothers from working condition with high hazards, remove or reduce any workplace health and safety risks to pregnant women and nursing mothers including those associated with their work assignments, and provide reasonable accommodations for nursing mothers.

B2 Emergency Preparedness

B2.1 Potential emergency situations and events are to be identified and assessed, and their impact minimized by implementing emergency plans and response procedures including: emergency reporting, employee notification and evacuation procedures, worker training and drills. Emergency drills must be executed at least annually.

B2.2 Suppliers shall set up appropriate fire detection and suppression equipment, clear and unobstructed egress, contact information for emergency responders, adequate exit facilities and recovery plans in their plants and public facilities.

B2.3 Such plans and procedures shall focus on minimizing harm to life, the environment, and property.

B2.4 Suppliers shall identify the natural disasters that may be encountered in the area, evaluate the possibility and severity of affecting operations, and formulate emergency plans and contingency procedures based on the evaluation results to minimize the impact.

B3 Occupational Injury and Illness

B3.1 Procedures and systems are to be in place to prevent, manage, track and report occupational injury and illness including provisions to: encourage worker reporting of occupational injuries and illnesses cases.

B3.2 For occupational injury and illnesses, suppliers shall investigate cases and implement corrective actions to eliminate their causes; classify and record injury and illness cases; provide necessary medical treatment; and facilitate return of workers to work.

B4 Industrial Hygiene

B4.1 Worker exposure to chemical, biological and physical agents is to be identified, evaluated, and controlled according to the Hierarchy of Controls.

B4.2 For identified potential hazards, suppliers shall seek opportunities to eliminate or reduce the possibility of the occurrence of hazards, or eliminate or control potential hazards through proper design and administrative controls.

B4.3 When hazards cannot be adequately controlled by such means, workers are to be provided with and use appropriate, well-maintained, personal protective equipment free of charge.

B5 Physically Demanding Work

B5.1 Worker exposure to the hazards of physically demanding tasks, including manual material handling and heavy or repetitive lifting, prolonged standing and highly repetitive or forceful assembly tasks is to be identified, evaluated and controlled.

B6 Machine Safeguarding

B6.1 Production and other machinery shall be evaluated for safety hazards. Physical guards, interlocks and barriers are to be provided and properly maintained where machinery presents an injury hazard to workers.

B7 Sanitation, Food, and Housing

B7.1 Workers are to be provided with ready access to clean toilet facilities, potable water and sanitary food preparation, storage, and eating facilities.

B7.2 Worker dormitories provided by the supplier or a labor agent are to be maintained to be clean and safe, and provided with appropriate emergency egress, hot water for bathing and showering, adequate lighting and heat and ventilation.

B7.3 Suppliers or agents shall provide individually secured accommodations for storing personal and valuable items, and reasonable personal space along with reasonable entry and exit privileges.

B8 Health and Safety Communication

B8.1 Suppliers shall provide workers with appropriate workplace health and safety information and training in the language of the worker or in a language the worker can understand for all identified workplace hazards that workers are exposed to, including but not limited to mechanical, electrical, fire, and physical hazards.

B8.2 Health and safety related information shall be clearly posted in the facility or placed in a location identifiable and accessible by workers.

B8.3 Training is provided to all workers prior to the beginning of work and regularly thereafter. Workers shall be encouraged to raise safety concerns without retaliation.

B9 Natural disaster risk mitigation

B9.1 Suppliers shall be aware of the natural disasters, such as earthquakes, droughts, floods, typhoons, etc. relevant to its facilities, and assess their likelihood and impact of personnel injury, property damage, and operational disruptions. The risks should be mitigated through establishing hardware protection, developing emergency response procedures, training and drills, and conducting emergency plans.

C. ENVIRONMENTAL

Suppliers recognize that environmental responsibility is integral to producing world class products. In manufacturing operations, adverse effects on the community, environment and natural resources are to be minimized while safeguarding the health and safety of the public.

C1 Environmental Permits and Reporting

C1.1 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.

C2 Pollution Prevention and Resource Reduction

C2.1 Emissions and discharges of pollutants and generation of waste are to be minimized or eliminated at the source or by practices such as adding pollution control equipment; modifying production, maintenance and facility processes; or by other means.

C2.2 The use of natural resources is to be conserved or by practices such as modifying production, maintenance and facility processes, materials substitution, re-use, conservation, recycling or other means.

C3 Hazardous Substances

C3.1 Chemicals and other materials posing a hazard to humans or the environment are to be identified, labelled and managed to ensure their safe handling, movement, storage, use, recycling or reuse and disposal.

C4 Solid Waste

C4.1 Suppliers shall implement a systematic approach to identify, manage, reduce, and responsibly dispose of or recycle solid waste.

C5 Air Emissions

C5.1 Air emissions of volatile organic chemicals, corrosives, particulates, ozone depleting substances generated from operations are to be characterized, routinely monitored, controlled and treated as required prior to discharge.

C5.2 Suppliers shall conduct routine monitoring of the performance of its air emission control systems.

C6 Materials Restrictions

C6.1 Suppliers are to adhere to all applicable laws, regulations and HIWIN’s requirements regarding prohibition or restriction of specific substances in products and manufacturing, including labeling for recycling and disposal.

C7 Water Management

C7.1 Suppliers shall implement a water management program that documents, characterizes, and monitors water sources, use and discharge; seeks opportunities to conserve water; and controls channels of contamination.

C7.2 All wastewater is to be characterized, monitored, controlled, and treated as required prior to discharge or disposal.

C7.3 Suppliers shall conduct routine monitoring of the performance of its wastewater treatment and containment systems to ensure optimal performance and regulatory compliance.

C8 Energy Consumption and Greenhouse Gas Emissions

C8.1 Suppliers are to look for methods to improve energy efficiency and to minimize their energy consumption and greenhouse gas emissions.

D. ETHICS

To meet social responsibilities and to achieve success in the marketplace, suppliers and their agents are to uphold the highest standards of ethics including:

D1 Business Integrity

D1.1 The highest standards of integrity are to be upheld in all business interactions.

D1.2 Suppliers shall have a zero-tolerance policy to prohibit all forms of bribery, corruption, extortion and embezzlement.

D2 No Improper Advantage

D2.1 Bribes or other means of obtaining undue or improper advantage are not to be promised, offered, authorized, given or accepted.

D3 Disclosure of Information

D3.1 All business dealings should be transparently performed and accurately reflected on the Supplier’s business books and records. Information regarding suppliers’ labor, health and safety, environmental practices, business activities, structure, financial situation, and performance is to be disclosed in accordance with applicable regulations and prevailing industry practices. Falsification of records or misrepresentation of conditions or practices in the supply chain are unacceptable.

D4 Intellectual Property

D4.1 Transfer of technical and commercial information is to be done in a manner that protects intellectual property rights; and, customer and supplier information is to be safeguarded.

D5 Fair Business, Advertising and Competition

D5.1 Standards of fair business, advertising and competition are to be upheld.

D6 Protection of Identity and Non-Retaliation

D6.1 Programs that ensure the confidentiality, anonymity and protection of whistleblowers are to be maintained.

D6.2 Suppliers should have a communicated process for their personnel to be able to raise any concerns without fear of retaliation.

D7 Responsible Sourcing of Minerals

D7.1 Suppliers shall prohibit any relevant conflict minerals and develop conflict minerals policies and management systems, exercise due diligence on the source and chain of custody of tantalum, tin, tungsten and gold in the products they manufacture.

D8 Privacy

D8.1 Suppliers are to commit to protecting the reasonable privacy expectations of personal information of everyone they do business with.

D8.2 Suppliers are to comply with privacy and information security laws and regulatory requirements when personal information is collected, stored, processed, transmitted, and shared.

D9 Avoiding Conflict of Interest

D9.1 Conflicts of interest, such as situations where a HIWIN employee or a close relative (parent, child, spouse or sibling) is a significant investor or shareholder in your company (as nonpublic traded stock), should be avoided to prevent misconduct. Excessive or overly-frequent socializing with your HIWIN business contacts may also create a conflict of interest, or the appearance of a conflict of interest. Social contact must be within accepted cultural business norms, and relationships that become conflicts of interest must be reported. If a potential conflict is discovered, suppliers should report such incident immediately to HIWIN and take corrective actions to ensure that no inappropriate actions result from the conflict and relationships that become conflicts of interest must be reported and suspended or resolved. Reporting channel: E-mail: Speak-up@hiwin.tw. Or mailing address: No. 7, Jingke Road, Nantun District, Taichung City, Audit Office. Whistleblowers should report in their real names, and attach their contact information and state facts or evidence. The HIWIN Audit Office will keep the relevant information of the whistleblowers strictly confidential.

D10 Prohibition of Unauthorized Subcontracting

D10.1 Without special authorization, HIWIN employees shall not require the supplier to provide the products or services that should be provided in accordance with the contract from a third party, or designate the purchase from a specific third party. If you receive a request from a HIWIN employee to procure from or subcontract from a specific third party, please report it immediately to HIWIN through HIWIN reporting channel.

D10.2 Reporting channel: E-mail: Speak-up@hiwin.tw. Or mailing address: No. 7, Jingke Road, Nantun District, Taichung City, Audit Office.Whistleblowers should report in their real names, and attach their contact information and state facts or evidence. The HIWIN Audit Office will keep the relevant information of the whistleblowers strictly confidential.

D11 Performing Services as Agreed in Contract

D11.1 Suppliers shall not subcontract or have a third party perform the obligations under the contract or purchase order for products or services that are expected to be fulfilled by the supplier without HIWIN’s prior consent. Furthermore, suppliers shall not provide any products or services to HIWIN without a validly executed contract or purchase order.

D12 Complying with Export and Import Regulations

D12.1 Suppliers should understand and comply with relevant laws and regulations related to the import, export, and transportation of goods to and from HIWIN or on HIWIN’s behalf, including export controls and customs regulations in the country of origin, import and customs regulations in the destination country, duties and other taxes required by payment laws, and relevant transportation regulations. Suppliers should provide operational procedures and training to their employees and subcontractors to ensure their compliance with the aforementioned regulations.

E. MANAGEMENT SYSTEMS

Suppliers shall adopt or establish a management system with a scope that is related to the content of this Code. The management system shall be designed to ensure: (a) compliance with applicable laws, regulations and customer requirements related to the supplier’s operations and products; (b) conformance with this Code; and (c) identification and mitigation of operational risks related to this Code. It should also facilitate continual improvement.

The management system should contain the following elements:


E1 Company Commitment

E1.1 Corporate social and environmental responsibility policy statements affirming suppliers’commitment to compliance and continual improvement, endorsed by executive management and posted in the facility in the local language.

E2 Management Accountability and Responsibility

E2.1 Supplier clearly identifies senior executive and company representative[s] responsible for ensuring implementation of the management systems and associated programs.

E2.2 Senior management reviews the status of the management system on a regular basis.

E3 Legal and Customer Requirements

E3.1 Suppliers shall have an effective compliance process to identify, monitor and understand applicable laws, regulations and customer requirements.

E4 Risk Assessment and Risk Management

E4.1 Suppliers shall develop a risk management system to identify the legal compliance, environmental, health and safety and labor practice and ethics risks associated with Supplier’s operations.

E4.2 Determination of the relative significance for each risk and implementation of appropriate procedural and physical controls to control the identified risks and ensure regulatory compliance.

E5 Improvement Objectives

E5.1 Written performance objectives, targets and implementation plans to improve the supplier’s social, environmental, and health and safety performance, including a periodic assessment of supplier’s performance in achieving those objectives.

E6 Training

E6.1 Programs for training managers and workers to implement suppliers’ policies, procedures and improvement objectives and to meet applicable legal and regulatory requirements.

E7 Communication

E7.1 A process for communicating clear and accurate information about suppliers’policies, practices, expectations and performance to workers, suppliers and customers.

E8 Worker Feedback, Participation and Grievance

E8.1 Ongoing processes, including an effective grievance mechanism, to assess employees’ understanding of and obtain feedback on or violations against practices and conditions covered by this Code and to foster continuous improvement.

E8.2 Workers must be given a safe environment to provide grievance and feedback without fear of reprisal or retaliation.

E9 Audits and Assessments

E9.1 Periodic self-evaluations to ensure conformity to legal and regulatory requirements, the content of the Code, and customer contractual requirements related to social and environmental responsibility.

E10 Corrective Action Process

E10.1 A process for timely correction of deficiencies identified by internal or external assessments, inspections, investigations and reviews.

E11 Documentation and Records

E11.1 Creation and maintenance of documents and records to ensure regulatory compliance and conformity to company requirements along with appropriate confidentiality to protect privacy.

E12 Supplier Responsibility

E12.1 A process to communicate Code requirements to next-tier suppliers and to monitor their compliance to the Code.

F. CLIMATE CHANGE AND DISCLOSURE

Suppliers should pay attention to global climate change trends, assess the impact of climate change on their products, services, and operations, and strive to reduce their carbon footprint while enhancing resilience to climate risks. These efforts include, but are not limited to, conducting and disclosing greenhouse gas inventory, consistently promoting energy efficiency and carbon reduction within the organization, assessing environmental risks and opportunities, reducing the consumption of natural resources such as water, actively supporting biodiversity maintenance and forest conservation, implementing no deforestation and dedicating to land conservation, investing in green research and development for a low-carbon transformation, and actively collaborating with upstream and downstream partners to implement climate change adaptation measures.

F1 Greenhouse Gas (GHG) Inventory and Management

Suppliers should quantify the organization's greenhouse gas emissions annually, including carbon dioxide (CO2), nitrous oxide (N2O), methane (CH4), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), sulfur hexafluoride (SF6), nitrogen trifluoride (NF3), and other gases in terms of carbon dioxide equivalents. A GHG inventory should be properly recorded, reviewed, and managed.

F2 Carbon Footprint Reduction

After the annual inventory is conducted, suppliers should track the GHG emission trend, analyze reasons for any changes, and identify the main sources of emissions and areas for energy conservation and GHG reduction. To reduce carbon footprints, suppliers should plan measures for energy conservation and carbon reduction, setting short-, medium-, and long-term goals for implementation. If introducing renewable power is one of the carbon reduction measures, suppliers should fully consider the impacts of the sources of renewable power on the environment, society, and biodiversity and decide on the sources with low adverse impacts.

F3 Proactive Response to Climate Change

E3.1 Suppliers should keep track of potential climate-related risks and opportunities for their products, services, and operations, and should assess, manage, and respond to climate risks appropriately in order to avoid supply chain disruptions. Suppliers should also establish climate governance and put in place units in charge of setting climate change management indicators and reporting climate progress to C-suite executives on a regular basis.

F4 Communication and Disclosure

E4.1 Suppliers should meet HIWIN product requirements for carbon footprints and provide necessary product-specific GHG emission statistics. If there are publicly accessible platforms such as official websites, suppliers should disclose corporate-level GHG emissions, as well as the achievement of energy conservation and carbon reduction goals, on their official websites, if any, or other public platforms every year.

G. EFFECTIVE DATE

This policy is effective September 30th, 2023

H. EDITION HISTORY

The first edition was in August, 2022

The first amendment was in September, 2023