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PACTEC CODE OF CONDUCT


Pactec, a division of LaFrance Corp, is committed to the highest standard of business ethics and corporate social responsibilities. This Code of Conduct is established to ensure that working conditions in our supply chain are safe, that workers are treated with respect and dignity, and that manufacturing processes are environmentally and socially responsible.

This Code of Conduct is based on the fundamental principle that a business, in all of its activities, must operate in full compliance with the applicable laws, rules and regulations of the countries in which it operates. The Code also goes beyond legal compliance, drawing upon internationally recognized standards, to advance social and environmental responsibility and business ethics.

This Code applies to Pactec's operations as well as it suppliers and vendors.

  1. LABOR

    Pactec is 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:

    1. Freely Chosen

      Forced, bonded or indentured labor, involuntary prison labor, slavery or trafficking of persons shall not be used. 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. When required by applicable law, workers will be provided with a written employment agreement in their native language as part of the hiring process. All work will be voluntary, and workers shall be free to terminate their employment. Employers and agents may not hold employees' identity or immigration documents, unless required by law.

    2. Young Workers

      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 the greatest. The use of legitimate workplace learning programs, which comply with all laws and regulations, is supported. Workers under the age of 18 shall not perform work that is likely to jeopardize the health or safety of young workers, including night shifts and overtime. The proper management of student workers shall be ensured and appropriate support and training shall be provided to student workers. In the absence of local law, the wage rate for student workers shall be the same wage rate as other entry-level workers performing equal or similar tasks.

    3. Working Hours

      Weekly and monthly working hours are to comply with the maximum set by applicable local law. Workers are allowed at least one day off per seven-day week.

    4. Wages and Benefits

      Compensation paid to workers shall comply with all applicable wage laws, including those relating to minimum wages, overtime hours and legally mandated benefits. 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. The basis on which workers are being paid is to be provided in a timely manner via a pay stub or similar documentation that includes sufficient information to verify accurate compensation for work performed. All use of temporary, dispatch and outsourced labor will be within the limits of the local law.

    5. Humane Treatment

      Disciplinary policies and procedures shall be clearly defined and communicated to workers. There is to be no harsh and inhumane treatment including any sexual harassment, sexual abuse, corporal punishment, mental or physical coercion or verbal abuse of workers; nor is there to be the threat of any such treatment.

    6. Non-Discrimination

      We have a commitment to a workforce free of harassment and unlawful discrimination. There shall be no discrimination 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 such as wages, promotions, rewards, and access to training. Workers shall be provided with reasonable accommodation for religious practices. In addition, workers or potential workers will not be subjected to discriminatory medical tests or physical exams.

    7. Freedom of Association

      In conformance with local law, 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, shall be respected. Workers 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.

  2. HEALTH and SAFETY

    Pactec recognizes that a safe and healthy work environment enhances the quality of products and services, consistency of production, and worker retention and morale. A safe and healthy work environment shall be provided to all workers.

    The Health and Safety Standards are:

    1. Occupational Safety

      Worker exposure to potential safety hazards (e.g., electrical and other energy sources, fire, vehicles, and fall hazards) are to be controlled through proper design, engineering and administrative controls, preventative maintenance and safe work procedures (including lockout/tagout), and ongoing safety training. Where hazards cannot be adequately controlled by these means, workers are to be provided with appropriate, well-maintained, personal protective equipment and educational materials about risks to them associated with these hazards. Workers shall not be disciplined for raising safety concerns.

    2. Emergency Preparedness

      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, appropriate fire detection and suppression equipment, adequate exit facilities and recovery plans. Such plans and procedures shall focus on minimizing harm to life, the environment and property.

    3. Occupational Injury and Illness

      Procedures and systems are to be in place to prevent, manage, track and report occupational injury and illness including provisions to: a) encourage worker reporting; b) classify and record injury and illness cases; c) provide necessary medical treatment; d) investigate cases and implement corrective actions to eliminate their causes; and e) facilitate return of workers to work.

    4. Industrial Hygiene

      Worker exposure to chemical, biological and physical agents is to be identified, evaluated, and controlled. Engineering or administrative controls must be used to control overexposures. When hazards cannot be adequately controlled by such means, worker health is to be protected by appropriate personal protective equipment programs.

    5. Physically Demanding Work

      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.

    6. Machine Safeguarding

      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.

    7. Sanitation, Food, and Housing

      Workers are to be provided with ready access to clean toilet facilities, potable water and sanitary food preparation, storage, and eating facilities. Worker dormitories are to be maintained to be clean and safe, and provided with appropriate emergency egress, hot water for bathing and showering, adequate heat and ventilation, and reasonable personal space along with reasonable entry and exit privileges.

    8. Health and Safety Communication

      Workers are to be provided with appropriate workplace health and safety information and training, including written policies in their language. Health and safety related information shall be clearly posted in the facility.

  3. ENVIRONMENTAL

    Pactec recognizes that environmental responsibility is integral to producing world class products. Adverse effects on the community, environment and natural resources are to be minimized while safeguarding the health and safety of the public in manufacturing operations.

    The Environmental Standards are:

    1. Environmental Permits and Reporting

      All required environmental permits (e.g. discharge monitoring), approvals and registrations are to be obtained, maintained and kept current and their operational and reporting requirements are to be followed.

    2. Pollution Prevention and Resource Reduction

      The use of resources and generation of waste of all types, including water and energy, are to be reduced or eliminated at the source or by practices such as modifying production, maintenance and facility processes, materials substitution, conservation, recycling and re-using materials.

    3. Hazardous Substances

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

    4. Wastewater and Solid Waste

      A systematic approach to identify, manage, reduce, and responsibly dispose of or recycle solid waste (non-hazardous) shall be implemented. Wastewater generated from operations, industrial processes and sanitation facilities are to be characterized, monitored, controlled and treated as required prior to discharge or disposal. In addition, measures should be implemented to reduce generation of wastewater. Routine monitoring of the performance of wastewater treatment systems shall be conducted.

    5. Air Emissions

      Air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting chemicals and combustion by-products generated from operations are to be characterized, routinely monitored, controlled and treated as required prior to discharge. Routine monitoring of the performance of air emission control systems shall be conducted.

    6. Materials Restrictions

      All applicable laws, regulations and customer requirements regarding prohibition or restriction of specific substances in products and manufacturing, including labeling for recycling and disposal, shall be complied with.

    7. Storm Water Management

      A systematic approach to prevent contamination of storm water runoff shall be implemented. Illegal discharges and spills from entering storm drains shall be prevented.

    8. Energy Consumption and Greenhouse Gas Emissions

      Energy consumption and greenhouse gas emissions are to be tracked and documented, at the facility and/or corporate level. Cost-effective methods to improve energy efficiency and to minimize energy consumption and greenhouse gas emissions are to be assessed.

  4. ETHICS

    The highest standards of ethics are to be upheld in all actions.

    The Ethics Standards include, but are not limited to:

    1. Business Integrity

      The highest standards of integrity are expected in all business interactions. Any forms of bribery, corruption, extortion and embezzlement are strictly prohibited. All business dealings should be transparently performed and accurately reflected on business books and records. Monitoring and enforcement procedures shall be implemented to ensure compliance with anti-corruption laws.

    2. No Improper Advantage

      Compliance with the U.S. Foreign Corrupt Practices Act, and any other applicable anti-corruption laws and regulations, must be complied with. Bribes or other means of obtaining undue or improper advantage are not to be promised, offered, authorized, given or accepted.

    3. Disclosure of Information

      Information regarding labor, health and safety, environmental practices, business activities, structure, financial situation and performance is to be disclosed in accordance with applicable regulation, prevailing industry practices, and any Pactec non-disclosure agreement and confidentiality requirements. Policies and procedures to ensure the safeguard on confidential information are to be in place. Falsification of records and information is unacceptable.

    4. Intellectual Property

      Intellectual property rights and customer information privacy must be respected. Any transfer of technology and know-how must be done in a manner that protects intellectual property rights.

    5. Fair Business, Advertising and Competition

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

    6. Protection of Identity and Non-Retaliation

      Programs that ensure the protection of a whistleblowerare to be maintained, unless prohibited by law. Retaliation against workers who utilize a whistleblower program or follow this Code in good faith is not permitted.

    7. Responsible Sourcing of Minerals

      Policies are required to reasonably assure that the tantalum, tin, tungsten and gold in our products does not directly or indirectly finance or benefit armed groups that are perpetrators of serious human rights abuses in the Democratic Republic of the Congo or an adjoining country. Due diligence shall be exercised on the source and chain of custody of these minerals.

    8. Privacy

      Pactec is committed to protecting the reasonable privacy expectations of personal information of everyone with whom we do business with, including suppliers, customers, consumers and employees. Compliance with privacy and information security laws and regulatory requirements when personal information is collected, stored, processed, transmitted, and shared is required.

  5. MANAGEMENT SYSTEM

    A management system whose scope is related to the content of this Code has been established. The management system is designed to ensure: (a) compliance with applicable laws, regulations and customer requirements related to operations and products; (b) conformance with this Code; and (c) identification and mitigation of operational risks related to this Code. It also facilitates continual improvement.

    The Management System contains the following elements:

    1. Company Commitment

      Corporate social and environmental responsibility and the requisite commitment to compliance and continual improvement as stated in the Code.

    2. Management Accountability and Responsibility

      Clearly defined roles and responsibilities for ensuring implementation and periodic review of the management systems and associated programs. Senior management reviews the status of the management system on a regular basis.

    3. Legal and Customer Requirements

      Identification, monitoring and understanding applicable laws, regulations and customer requirements, including the requirements of this Code.

    4. Risk Assessment and Risk Management

      Identification of legal compliance, environmental, health and safety, labor practice and ethics risks associated with operations. 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.

    5. Improvement Objectives

      Written performance objectives, targets and implementation plans to improve social and environmental performance, including a periodic assessment of performance in achieving those objectives.

    6. Training

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

    7. Communication

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

    8. Worker Feedback and Participation

      An ongoing process to assess workers' understanding of and obtain feedback on practices and conditions covered by this Code and to foster continuous improvement.

    9. Audits and Assessments

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

    10. Corrective Action Process

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

    11. Documentation and Records

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

    12. Supplier Responsibility

      A process to communicate this Code's requirements to suppliers and to monitor supplier compliance to the Code.


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