About Us > Sustainability > Swagelok Supplier Code of Ethics
Swagelok Supplier Code of Ethics
Supplier Expectations
Swagelok Company expects its Suppliers to be passionately focused on assisting Swagelok in achieving its brand promise of exceptional quality and service. Because the business practices and actions of a Supplier may impact Swagelok, Swagelok expects its Suppliers to adhere to the highest standards of legal compliance and business ethics.
Swagelok conducts its business in accordance with its core values: Quality, Integrity, Respect, Continuous Improvement, Customer Focus, and Innovation. As a result, we expect that Suppliers will operate in a manner that is consistent with these values. This Supplier Code of Ethics (‘Code’) outlines the minimum standards that we expect our Suppliers to uphold.
The requirements set forth in this Code support principles set forth in the Responsible Business Alliance (RBA) Code of Conduct.
Compliance with Applicable Laws
Suppliers must operate in full compliance with all applicable laws, rules, and regulations of the United States and the countries, states, and municipalities in which they operate. Swagelok also encourages Suppliers to go beyond legal compliance to advance social and environmental responsibility.
Bias For Quality
All products and services delivered by Suppliers must meet the quality and safety standards required by applicable law. When conducting business with or on behalf of Swagelok, Suppliers must comply with all Swagelok quality requirements.
Ethics
Business Integrity
Suppliers must comply with all applicable anti-bribery and anti-corruption laws. Corruption, extortion, and embezzlement, in any form, are strictly prohibited. Suppliers must never, directly or through intermediaries, provide, offer, or promise any payments, gifts, or other improper advantage to Swagelok personnel or others to obtain or retain business or an improper advantage. Nor may the Supplier accept any such advantage in return for any preferential treatment by Swagelok or a third party. Records prepared for Swagelok shall be accurate, truthful, and complete, and shall meet applicable standards and requirements. Falsification of records or misrepresentation of conditions or practices in the supply chain are unacceptable.
Conflict of Interest
Suppliers acting on Swagelok’s behalf should be free from conflicts of interest that could adversely influence their judgment, objectivity, or loyalty in conducting business with or involving Swagelok. Any potential conflict of interest should be proactively disclosed to Swagelok.
Responsible Material Sourcing and Conflict Minerals
Swagelok expects its Suppliers to adopt a policy and exercise due diligence to assure that they only source materials from legal and environmentally and socially responsible sources. In support of this obligation, upon request, Suppliers shall disclose to Swagelok the source and chain of custody of potential conflict minerals (including without limitation tantalum, tin, tungsten and gold) used in products or services provided to Swagelok.
Unfair Business Practices
Suppliers must adhere to relevant laws and standards of fair business, advertising, and competition. Suppliers shall not engage in collusive bidding, price fixing, price discrimination, or other unfair trade practices in violation of any applicable antitrust or fair competition laws.
Marketing and Advertising
Suppliers may not engage in advertising, marketing, or promotional activities that reference or implicate Swagelok, its name, logo, or services without Swagelok’s prior written consent.
Intellectual Property Protection & Data Privacy
Suppliers must respect the intellectual property rights of others. Suppliers may use Swagelok intellectual property and confidential information only as authorized by Swagelok and must take reasonable steps to protect Swagelok’s confidential information. In addition, Suppliers must have in place procedures to comply with applicable privacy and data protection laws and should use protected information only as authorized.
Non-Retaliation for Whistleblowers or Others Raising Concerns
Suppliers shall maintain appropriate rules and procedures for individuals to report concerns and to reasonably protect such individuals and others from retaliation. There shall be no retaliation against any individual who raises a good faith concern. Programs should allow confidential or anonymous reporting where possible.
Trade Compliance
Suppliers must comply with applicable trade control laws, including without limitation import/export laws, sanctions, trade restrictions, customs declarations, tariffs, country-of-origin, and export classification control numbers. Upon request, Suppliers will provide Swagelok accurate and complete information and documentation demonstrating such compliance and to enable Swagelok to fulfill its own legal requirements.
Labor and Human Rights
Anti-Discrimination
Suppliers shall not discriminate against any employee based on race, ethnicity, creed, color, religion, sex, age, national origin or ancestry, disability, pregnancy, pregnancy-related medical conditions, genetic information, veteran/military status, sexual orientation, gender identity, or other protected characteristic consistent with applicable law.
Employees with disabilities or pregnancy and pregnancy-related medical conditions will be provided reasonable job accommodations as needed to perform their essential job functions provided that doing so would not impose an undue hardship.
Fair Treatment
Suppliers shall commit to a workplace free of harassment and shall prohibit unlawful harassment and discrimination in the workplace.
Prevention of Child Labor
Suppliers shall comply with all child labor laws and shall not employ anyone under the legal minimum working age or use any goods or services that were created using child labor. Where an employee meets the legal minimum working age but is under the age of legal adulthood, Suppliers should assign the employee only non-hazardous work assignments and limit working hours during periods when the employee is or should be attending school to a reasonable maximum per day and per week and, at all times, Suppliers should limit working hours to avoid overnight shifts.
The use of legitimate workplace apprenticeship programs, which comply with all applicable laws and regulations, is supported.
Working Hours
Suppliers must comply with all applicable laws and mandatory industry standards regarding working hours. In the event of conflict between a statute and a mandatory industry standard, Suppliers must comply with the more restrictive requirement. Generally, a workweek should not exceed 60 hours per week and overtime should be voluntary, except in emergencies or unusual situations. Employees shall be allowed at least one day off every seven days.
Wages and Benefits
Suppliers shall comply with all applicable laws and binding agreements regarding wages and benefits, including those pertaining to overtime work and other premium pay arrangements. Deductions from wages as a disciplinary measure shall not be permitted.
Antislavery and Human Trafficking
Forced labor in any form is not permitted. There shall be no unreasonable restrictions on employees’ freedom of movement in the facility in addition to unreasonable restrictions on entering or exiting facilities including, if applicable, employees’ living quarters. As part of the hiring process, all employees must be provided with a written employment agreement in a language the employee understands that contains a description of terms and conditions of employment. Foreign migrant workers, if any, must receive the employment agreement prior to the individual departing from his or her country of origin. All work shall be voluntary, and employees shall be free to terminate their employment without penalty if reasonable notice is given. Suppliers may not hold or confiscate passports, work permits or other identity or immigration documents. If a Supplier is required to hold documentation to comply with the local law, employees shall at no time be denied access to their documents. Employees shall not be required to pay Suppliers’ agents or sub-agents’ recruitment fees or other related fees for their employment. If any such fees are found to have been paid by employees, such fees shall be repaid to the employee.
Freedom of Association
Open communication and direct engagement between employees and management are the most effective ways to resolve workplace issues. Employees should 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. Suppliers should recognize their employees’ right to engage in peaceful assembly, as well as employees' right to refrain from such activity.
Health and Safety
Workplace Environment
Suppliers shall comply with all applicable health and safety laws and shall provide employees with safe and healthy working conditions. If a Supplier provides housing to its employees, it shall provide safe and healthy housing conditions. At a minimum, potable drinking water, adequate sanitation, fire exits, essential safety equipment, access to emergency medical care, and appropriately lit and equipped workstations must be provided.
In addition, facilities must be constructed and maintained in accordance with the standards set by applicable codes and laws. In all cases, Suppliers shall provide employees with appropriate personal protective equipment. Suppliers shall also ensure that their workplace has appropriate security procedures and that their employees follow Swagelok’s security procedures when on-site at Swagelok. Employees shall not be disciplined for raising safety concerns and shall have the right to refuse unsafe working conditions without fear of reprisal.
Emergency Prevention, Preparedness, and Response
Suppliers shall implement emergency plans and response procedures, including emergency reporting, employee notification and evacuation procedures, employee training and drills, appropriate first-aid supplies, appropriate fire detection and suppression equipment, adequate exit facilities, and recovery plans.
Occupational Safety Procedures and Systems
Suppliers shall have or subscribe to a written health and safety program. Suppliers are responsible for appropriately controlling employee exposure to potential safety hazards (e.g., physically demanding tasks, electrical and other energy sources, fire, vehicles, slips, hazardous chemicals, trip and fall hazards) in conformance with all applicable standards and/or regulations and by utilizing suitable means (e.g., design, engineering and administrative controls, preventative maintenance, training, work procedures, and appropriate personal protective equipment). Physical guards, interlocks, barriers, or other appropriate protection shall be provided and properly maintained where production or other machinery presents an injury hazard to employees. Where hazards cannot be adequately controlled by these means, employees are to be provided with appropriate personal protective equipment.
Procedures and systems shall be in place to prevent, manage, track, and report occupational injuries and illnesses.
Training
Suppliers shall ensure that required health and safety training has been completed prior to initiating any work activity. Suppliers shall provide employees with appropriate workplace health and safety information and training in the language of the employee or in a language the employee can understand for all identified workplace hazards that employees are exposed to.
Product Content
Suppliers shall ensure that chemicals, waste, and other materials posing a hazard to humans or the environment shall be identified, labeled, and managed to ensure their safe handling, movement, storage, use, recycling or reuse, and disposal. Suppliers shall comply with applicable laws and regulations regarding product content (e.g., REACH, RoHS, TSCA, etc.) to the extent applicable to Suppliers’ own products, services and/or operations and shall reasonably cooperate with Swagelok to provide necessary information and documentation upon request.
Environmental Impact
Environment
Swagelok is committed to protecting and preserving the environment. We continually strive to minimize our environmental impact and improve the environmental quality of our operations. We seek to do business with Suppliers who share these same values. We expect Swagelok’s Suppliers to make efforts to reduce energy usage, natural resources, waste materials, and greenhouse gasses.
At a minimum, Suppliers must comply with all current, applicable environmental rules, regulations, and laws in their countries. By way of example and not limitation, Swagelok’s Suppliers must:
- Obtain and comply with all required environmental permits and regulations
- Reduce, control, and/or eliminate wastewater, waste (including solid non-hazardous waste, etc.), and pollution at the source
- Reduce, control, and/or eliminate air emissions of volatile chemicals, corrosives, particulates, aerosols, and combustion products
- Conform to applicable labeling and warning requirements
- Identify, manage, and handle regulated substances in accordance with law
We encourage Suppliers to look for opportunities that go beyond basic environmental compliance and adopt approaches that fit their business to help reduce climate and environmental impacts. This could include measures such as improving energy efficiency, generating or sourcing clean energy, setting emissions reduction goals, reducing water usage, minimizing waste, or exploring more sustainable and environmentally friendly materials in products.
Compliance with Code
If a Supplier becomes aware of any violation of this Code by any of its employees, officers, or representatives or any employee, officer, or any representative of Swagelok, the Supplier should report such violation to Swagelok’s ethics hotline at: https://swagelok.alertline.com/gcs/welcome.
Alternatively, address letters to:
Swagelok Company
Attn: Legal Department
29500 Solon Road
Solon, Ohio 44139, USA
Swagelok reserves the right to verify by audit or other means each Supplier’s compliance with the Code. In cases where Swagelok becomes aware of any actions or conditions not in compliance with the Code, Swagelok reserves the right to demand corrective measures or terminate an agreement with any Supplier that does not comply with the Code.
This Code also applies to any sub-contractor(s) to the Supplier providing goods or services to the Supplier. The Supplier is fully responsible for ensuring compliance by any such sub-contractor(s) as if it were the Supplier itself. Swagelok reserves the right to audit the Supplier’s sub-contractors for compliance to the Code.
We trust that our mutual compliance with these standards creates a better work environment for our customers, employees, community, and the world in which we live.