COMMSCOPE POLICY
CATEGORY: Supply Chain
SUBJECT: Supplier Code of Conduct
EFFECTIVE DATE: 26 Mar 2018
PAGE(S): 5
I. SCOPE
This policy establishes a code of conduct for current and potential CommScope suppliers.
II. INTENT
CommScope is committed to conducting its business in an ethical, legal and socially
responsible manner. CommScope expects its suppliers to share this commitment and,
therefore, has established this Supplier Code of Conduct. Although there may be different legal
and cultural environments applicable to its suppliers, CommScope suppliers must meet the
following minimum requirements in order to do business with CommScope.
III. SUPPLIER CODE OF CONDUCT
Compliance with Laws, Regulations and Published Standards
CommScope suppliers must comply with all applicable laws, codes or regulations of the
countries, states and localities in which they operate. This includes, but is not limited to, laws
and regulations relating to environmental, occupational health and safety, and labor practices.
In addition, CommScope suppliers must require their suppliers (including temporary labor
agencies) to do the same.
Ethical Business Practices
Suppliers shall conduct their businesses in accordance with the highest standards of ethical
behavior and in accordance with applicable laws and regulations. Suppliers are expected to
conform to these requirements in each of the following areas:
- Fair Trade Practices. Suppliers shall not engage in collusive bidding, price fixing, price
discrimination or other unfair trade practices in violation of antitrust laws.
Bribery, Kickbacks and Fraud. No funds or assets of the supplier shall be paid, loaned
or otherwise disbursed as bribes, "kickbacks", or other payments designed to influence
or compromise the conduct of CommScope, its employees or representatives.
- Foreign Corrupt Practices Act. While laws and customs vary throughout the world,
suppliers must comply with foreign legal requirements and United States laws that apply
to foreign operations, including the Foreign Corrupt Practices Act. The Foreign Corrupt
Practices Act generally makes it unlawful to give anything of value to government
officials, foreign political parties, party officials, or candidates for office for the purposes
of obtaining or retaining business.
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CommScope Policies and Procedures. Suppliers must comply with the CommScope’s published
policies and procedures, including, but not limited to, the Conflict of Interest, Procurement
Relationships and other relevant provisions of the CommScope Code of Ethics & Business
Conduct, which can be found at
http://www.commscope.com/About-Us/Corporate-Responsibility-and-Sustainability/Document-Library/
Intellectual Property Rights.
Suppliers shall respect the intellectual property rights of others, including CommScope, its
affiliates and business partners. Suppliers must take appropriate steps to safeguard and
maintain confidential and proprietary information of CommScope and shall use such information
only for the purposes specified for use by CommScope. Suppliers shall observe and respect all
CommScope patents, trademarks and copyrights and comply with all requirements as to their
use as established by CommScope. Suppliers shall not transmit confidential or proprietary
information of CommScope via the internet unless such information is encrypted accordance
with minimum standards established by CommScope.
Environmental Practices
CommScope suppliers shall comply with all environmental laws and regulations applicable to
their operations worldwide. Such compliance shall include, among other things, the following
items:
- Obtaining and maintaining environmental permits and timely filing of required reports
- Proper handling and disposition of hazardous materials
- Monitoring, controlling and treating discharges generated from operations
Occupational Health and Safety Practices
CommScope suppliers shall provide their employees with a safe and healthy working
environment in order to prevent accidents and injury to health arising out of, linked with, or
occurring in the course of work or as a result of the operation of the supplier. Suppliers shall,
among other things, provide:
- Occupational health and safety training
- A system for injury and illness reporting
- Worker exposure to physically demanding tasks, including manual material handling and
heavy lifting, prolonged standing and highly repetitive or forceful assembly tasks is to be
identified, evaluated and controlled.
- Medical treatment and/or compensation to injured/ill workers arising as a result of
working for supplier.
- Worker exposure to chemical, biological and physical agents is to be identified,
evaluated, and controlled. When hazards cannot be adequately controlled by
engineering and administrative means, workers are to be provided with appropriate
personal protective equipment.
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- Machine safeguarding and other protective measures to prevent injuries/illnesses
to workers
- Workers are to be provided clean and safe facilities including clean toilet facilities,
access to potable water and sanitary food preparation and storage facilities.
- Worker dormitories provided by the Suppliers are to be clean, safe, and provide
emergency egress, adequate heat and ventilation and reasonable personal space.
Labor Practices
CommScope expects its suppliers to adopt sound labor practices and treat their workers
fairly in accordance with local laws and regulations. In addition, suppliers must comply with the
following standards:
- Freely Chosen Employment. Suppliers shall not use any forced labor, whether in the
form of prison labor, indentured labor, bonded labor or otherwise.
- No Child Labor. Suppliers shall comply with local minimum working age laws and
requirements and not employ child labor.
- Minimum Wages. Suppliers shall provide wages for regular and overtime work and
benefits that meet or exceed legal requirements.
- Working Hours. Suppliers shall not require workers to work more than the maximum
hours of daily labor set by local laws.
- No Harsh, Inhumane Treatment or Abuse. Suppliers shall treat each employee with
dignity and respect. In no event shall Supplier’s workers be subject to threats of
violence, physical punishment, confinement or other form of physical, sexual,
psychological or verbal harassment or abuse.
- No Discrimination. Suppliers shall not discriminate in its employment practices on the
basis of race, color, religion, sex, age, physical disability, national origin, creed or any
other basis prohibited by law.
- Freedom of Association. Suppliers shall recognize and respect the rights of its workers
to join or to refrain from joining associations of their own choosing and the right to
collective bargaining in accordance with local labor laws and established practices.
-
Export Sanctions/Terrorism Activities
CommScope suppliers must abide by all economic sanctions or trade embargoes that United
States has adopted, whether they apply to foreign countries, political or to particular foreign
individuals and entities.
Suppliers must not directly or indirectly engage in or support any terrorist activity.
Neither suppliers nor any of their affiliates, nor any officer or director of the supplier or any of
their affiliates, should be included on any lists of terrorists or terrorist organizations compiled by
the United States government or any other national or international body, including but not
limited to: (i) the U.S. Treasury Department’s Specially Designated Nationals List, (ii) U.S. State
Department’s Terrorist Exclusion List, (iii) the United Nations List Pursuant to Security Council
Resolution 1390 (2002) and Paragraphs 4(B) or Resolution 1267(1999and 8(C) of Resolution
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1333 (2000), and (iv) the European Union List Article (2)(3) of Regulation (EC) No. 2580/2001
on Specific Restrictive Measures Directed Against Certain Persons and Entities with a View to
Combating Terrorism.
Solicitations by Suppliers
All suppliers shall comply with all guidelines issued by CommScope relating to access to
CommScope facilities, offices and departments, and employees. No Supplier shall use
CommScope’s computer system, including its electronic mail system and internet site, for
purpose of sending unsolicited electronic mail messages to the CommScope community.
Suppliers must receive prior written authorization from CommScope Supply Chain Management
to hold trade shows, demonstrate products, utilize CommScope’s resources (i.e. bulletin
boards), or make unsolicited calls on CommScope departments.
Monitoring and Compliance
Suppliers shall conduct audits and inspections to insure their compliance with this Supplier
Code of Conduct and applicable legal requirements. If a supplier identifies areas of non-
compliance, the supplier agrees to notify the relevant CommScope Purchasing Manager as to
its plans to remedy any such non-compliance.
CommScope or its representatives may engage in monitoring activities to confirm Supplier’s
compliance to this Supplier Code of Conduct, including on-site inspections of facilities, use of
questionnaires, review of publicly available information, or other measures necessary to assess
supplier’s performance.
Any CommScope supplier or CommScope employee that becomes aware of violations of this
policy is obligated to notify CommScope’s Supply Chain management. Based on the
assessment of information made available to CommScope, CommScope reserves the right (in
addition to all other legal and contractual rights) to disqualify any potential supplier or terminate
any relationship with any current supplier found to be in violation of the supplier Code of
Conduct without liability to CommScope.
IV. APPLICATION/EXCLUSIONS
This Supplier Code of Conduct is a general statement of CommScope’s expectations with
respect to suppliers. This Policy should not be read in lieu of but in addition to any supplier
obligations as set forth in any (i) request for proposal or other solicitation, or (ii) agreements by
and between CommScope and the Supplier. In the event of a conflict between this Policy and
any CommScope solicitation document or applicable agreement, the terms of the solicitation
document or applicable agreement shall control.
No exclusions are applicable to this policy.
V. REFERENCES
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Policy: Conflict of Interest and Procurement Relationships
Policy: CommScope Code of Ethics & Business Conduct
IN WITNESS WHEREOF, the undersigned have caused this Supplier Code of Conduct to be
executed by their authorized officers as of the date and year first written above.
SUPPLIER
By:
Name:
Title:
Date:______________________________________
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