Corporate Responsibility
Radwell International Supplier Code of Conduct
Our Core Values
Radwell International and its global subsidiaries (collectively “Radwell International”) are committed to a set of core values that serve as Radwell International’s guiding principles when conducting business with the highest standards of ethics, responsibility, and focus on sustainability. We expect the same commitment from our suppliers, who play a critical role in delivering products and providing services that reflect our values. The Radwell International Supplier Code of Conduct (“Code of Conduct”) outlines our minimum expectations regarding legal compliance, the protection of human rights, environmental stewardship, business ethics, and responsible sourcing, among other key values.
This Code of Conduct applies to each member of Radwell International’s global vendor, supplier, and third-party community (“Suppliers”) and each must adhere to the principles outlined below and promote them within their own supply chains.
1. Legal and Regulatory Compliance
Compliance with Laws: We expect our Suppliers to maintain full compliance with all laws and regulations applicable to their business, and when conducting international business, Suppliers must comply with local and national laws, codes, rules, orders regulations in the countries or jurisdictions in which such business is conducted (collectively, “Applicable Law”). All requirements in this Code of Conduct are to be interpreted as obligations in addition to the foregoing requirement to comply with Applicable Law.
2. Human Rights and Labor Practices
2.1 Respect for Human Rights
Suppliers shall support and respect internationally recognized human rights and ensure they are not complicit in human rights abuses. In accordance with the International Labour Organization (“ILO”), Suppliers shall commit to uphold human rights of workers and treat workers with dignity and respect. This commitment applies to all workers including temporary, contract, student, migrant, and direct employees. Suppliers will also respect the rights of vulnerable groups including women, migrants, and children in accordance with ILO conventions. Suppliers will ensure that workers are protected against physical, sexual, psychological, and verbal harassment and abuse.
2.2 Freely Chosen Employment
All forms of forced labor, including without limitation, bonded labor, involuntary prison labor, slavery, and human trafficking are strictly prohibited. Suppliers will ensure that all workers should be free to leave work or terminate employment upon reasonable notice. Suppliers will maintain documentation on all workers leaving their employment in order to properly document their work history.
2.3 Child Labor Suppliers
must adhere to the minimum working age in any region where they operate, while prohibiting employment of anyone under the age of 15 or under the minimum age for employment as defined by Applicable Law and as aligned with ILO Convention 138. Suppliers will verify the age of young workers to ensure the age is above that of minimum employment. Suppliers will ensure that child labor will not be tolerated in any form.
2.4 Fair Wages and Working Hours
Suppliers shall provide fair wages, benefits, and working hours that comply with Applicable Laws and industry standards. Overtime must be voluntary and compensated accordingly. Compensation and benefits must at least comply with Applicable Laws, including overtime and legally mandated benefits. Employees must also be permitted to have adequate breaks and rest periods, and to take holiday and time off in accordance with Applicable Law.
2.5 Non-Discrimination
Suppliers must promote an inclusive work environment and shall not discriminate based on race, gender, color, age, religion, sexual orientation, gender identity, ethnicity, pregnancy, disability, political affiliation, marital status, or any other protected status.
2.6 Freedom of Association
Suppliers shall recognize and respect the rights of employees to freely associate, join trade unions, and engage in collective bargaining. Suppliers will ensure workplace environments enable workers to pursue alternative forms of organizing including worker councils or worker-management dialogues where there are regulatory constraints.
2.7 Humane Treatment/Anti-Harassment
Harassment, abuse, or any form of inhumane treatment, including sexual harassment or coercion, is strictly forbidden in accordance with Applicable Laws. Suppliers shall:
Respect the basic human rights of their employees.
Not allow physical, sexual, psychological, or verbal harassment or abuse.
Not allow discrimination based on race, origin, color, gender, disability, sexual orientation, political or religious convictions, age, world view, or any other category protected by Applicable Law.
Not use forced, bonded, indentured, or involuntary labor.
3. Health, Safety, and Wellbeing Suppliers must provide a safe and healthy workplace.
This shall include requirements to:
Comply with applicable occupational health and safety laws.
Provide appropriate personal protective equipment (PPE) based on the work environment.
Identify and mitigate health and safety risks.
Ensure employees receive health and safety training.
Maintain clean and accessible facilities, including restrooms, drinking water, and food areas.
Provide Hazmat or similar awareness training on handling, movement, storage, disposal, and spill response in accordance with international, national, or local laws.
4. Environmental Stewardship
Suppliers shall operate in an environmentally responsible and sustainable manner. This may include minimizing detrimental environmental impact of their operations, supply chain, products, and services, as much as possible towards environmental neutrality. This may also include:
Comply with applicable environmental laws and regulations.
Work to reduce emissions, water consumption, energy use, and waste, and to recycle effectively.
Promote circular economy practices whenever possible.
Monitor, and where possible report, Greenhouse Warming Gases
Reducing and eliminating practices that lead to deforestation, or the loss of natural forest due to conversion to agriculture or non-forest land use.
Avoid the use of restricted substances and ensure proper handling of hazardous waste.
5. Ethical Business Practices
5.1 Anti-Corruption and Bribery
Suppliers must comply with the anti-corruption laws, directives, and regulations that govern operations in the countries in which they do business, regardless of local customs, including, without limitation, the U.S. Foreign Corrupt Practices Act and the UK Bribery Act of 2010. Suppliers must not engage in any form of corruption, fraud, bribery, money laundering, extortion, or embezzlement. Suppliers must not offer, directly or indirectly, any illegal or improper payments, gifts, or hospitality intended to exert undue influence or impact business decisions.
5.2 Fair Competition
Suppliers must comply with all antitrust and fair competition laws and refrain from collusion, price fixing, bid-rigging, or market manipulation. Suppliers should also respect the intellectual property of others.
5.3 Conflicts of Interest
Suppliers must avoid actual or perceived conflicts of interest and disclose any that may arise in their business dealings with Radwell International. Supplier employees and immediate family members (spouse, domestic partner, parents, children, siblings, and their spouses) may not serve as officers, directors, employees, agents, or consultants who may affect business decisions that may appear improper. Any appearance of impropriety shall be disclosed to Radwell International. In addition, Suppliers shall:
Maintain the highest standards of integrity in all interactions with Radwell International.
Not offer improper gifts or services that may appear as undue or improper business advantages.
Refrain from providing charitable donations on behalf of Radwell International which may appear as inappropriate business advantages.
5.4 Intellectual Property, Product Quality and Counterfeit Parts
Suppliers must respect intellectual property rights, product quality, and prevention of counterfeit parts in the supply chain in accordance with the following:
A commitment to preventing the introduction of counterfeit parts and components into the supply chain.
Enhancing quality assurance processes to identify defects while implementing corrective actions and continuous improvements to prevent re-occurrences.
Monitoring processes to minimize the risk of introducing counterfeit parts and materials into deliverable products.
Avoiding compromises to intellectual property rights and properties within the international supply chain.
6. Responsible Sourcing, Conflict Minerals and Supply Chain Management
Radwell International seeks supply chain partners that utilize sustainable and responsibly sourced energy, minerals and raw materials and implement supply chain practices that do not cause or contribute to human rights violations and conflict. Radwell International works collaboratively with supply chain partners to increase the transparency and traceability of products sold by Radwell International. We also expect Suppliers to respect all internationally recognized human rights and conduct responsible supply chain management practices and conflict free sourcing practices. Suppliers shall comply with Applicable Laws requiring disclosure of the use of conflict minerals. The term “conflict minerals” refers to certain identified minerals that may have directly or indirectly contributed to the financing of armed groups in the Democratic Republic of Congo (“DRC”) and neighboring countries.
Suppliers must avoid sourcing materials from Conflict-Affected and High-Risk Areas that contribute to human rights violations or environmental harm.
Suppliers shall supply products to Radwell International that do not contain conflict minerals that directly or indirectly finance, or benefit armed groups in DRC and any country that shares an internationally recognized border with DRC.
Suppliers are expected to ensure that their own supply chains adhere to the principles outlined in this Code of Conduct.
Radwell International encourages inclusive sourcing practices and engagement with diverse and local suppliers within the confines of the lawful movement of goods.
7. Grievance Mechanism and Whistleblower Protection
Suppliers must provide a safe, accessible, and confidential grievance mechanism for workers to raise concerns or report violations without fear of retaliation. Whistleblowers must be protected from harassment, dismissal, or disciplinary action. Suppliers should also have the following:
A strong reporting procedure to eliminate miscommunication and misinterpretation.
No corporate retaliation.
A prompt investigation procedure.
8. Monitoring and Compliance
Radwell International reserves the right to assess and monitor supplier compliance with this Code of Conduct through audits, site visits, and self-assessments. Non-compliance may result in corrective action requests, suspension, or termination of the business relationship. This includes:
Ensuring global compliance with applicable international trade law, without limitation, export controls, customs, and tax laws
Complying with global sanctions
Complying with international rules on embargoed countries and territories
Complying with conflict minerals laws
9. Confidentiality, Data Protection and Data Privacy
We expect Suppliers to safeguard confidential information with the most stringent information and data protection requirements and ensure data is managed responsibly and securely. Suppliers shall have processes and procedures in place to protect data, including personal data, from unauthorized access, use, or disclosure.
Trade and business secrets and confidential information must be managed discretely and confidentially and must not be shared with or made accessible to unauthorized parties.
The protection of the intellectual property of third parties, or customers of Radwell International, which may be required to be shared with a Supplier on a case-by-case basis, must also be respected with the Supplier using at least the same degree of care it exercises to protect its own confidential information.
All confidential information must be maintained in confidence and stored properly or as agreed to by Radwell International and not altered, copied, or misused.
Suppliers shall protect the privacy expectations of individuals with respect to the access, collection, use, processing, transmission, and storage of personal data.
Supplier must comply with privacy and information security laws and requirements when personal information is collected, stored, processed, transmitted, and shared. Suppliers shall also ensure the security of all business data.
A Shared Commitment
Suppliers are encouraged to go beyond compliance by adopting sustainable practices, adhering to Applicable Laws, providing safe working conditions, promoting continuous improvement, and partnering with Radwell to create long-term value for society, the environment, and our mutual business success.
Non-Compliance Reporting
Violations of the Code of Conduct can be reported in any of the following ways:
Email: Legal@radwell.com
Mail: Radwell International
Attn: Legal and Compliance Department
3025 Highland Parkway, #550
Downers Grove, IL 60515
Modification
Radwell International may at any time update, modify or change the information or application of the policies described in this Code of Conduct as required to meet changing circumstances.