This Supplier Code of Conduct (“Code”) articulates Hero Motors Limited (“HML”) expectations of the conduct of suppliers and service providers doing business with HML (“suppliers”). This Code is based on our corporate values for responsible and sustainable products and operations. Suppliers are expected to understand and act consistent with HML’s approach to integrity, responsible sourcing, and supply chain management. HML expects suppliers will cascade similar expectations through their own supply chains.
HML endeavours to do business with suppliers that meet our standards and behave consistently with, and positively reflect, HML’s values throughout the supply chain. HML expects that suppliers will satisfy contractual requirements, comply with laws, regulations, and HML policies and act consistently with the principles and values of our HML Code of Conduct, and this Code.
Human Rights
HML expects all suppliers to have processes in place to prevent, mitigate, and take effective measures to remediate adverse human rights impacts. Suppliers are expected and required to adhere to and cascade HML’s Human Rights Policy or equivalent expectations throughout their supply chain.
The United Nations Guiding Principles on Business and Human Rights serve as a guiding framework for HML’s work related to human rights. HML is also committed, and expects suppliers to commit, the International Labor Organization’s (ILO) Declaration on Fundamental Principles and Rights at Work; Suppliers are expected to comply with these internationally recognized standards.
Freedom of Movement
Suppliers and their employment agencies will not impose restrictions on entering or exiting company provided facilities including, if applicable, workers’ dormitories or living quarters, except when lawful and necessary for safety or security purposes. Suppliers will refrain from restricting workers’ movement through the retention of bank payment cards or similar arrangements for accessing wages. Suppliers will also refrain from requiring workers to use company-provided accommodation. Suppliers and their employment agencies, will not destroy, withhold, or conceal identity or immigration documents, such as government-issued identification, passports, or work permits.
Child Labor
Suppliers and their employment agencies will not use child labour. HML has a zero-tolerance policy regarding the use of child labour. Suppliers will implement an appropriate mechanism to verify that the age of workers and workers recruited comply with the government regulations and will provide substantiation of this verification upon request. If child labour is discovered in its supply chain, suppliers will cease employment of the child/children and take reasonable measures to enroll the child/children in a remediation/ education program. Suppliers will not use workers under the age of 18 to perform work that is likely to jeopardize their health or safety. If young workers are found to be involved in work that is likely to jeopardize their health or safety, suppliers will take reasonable measures to immediately remove the young workers from the situation and provide alternative work that is age appropriate.
Working Hours
Suppliers will comply with local laws and collective bargaining agreements (where applicable) regarding working hours. Working hours must not exceed the maximum set by local law.
Wages and Benefits
Suppliers and their employment agencies will pay wages and provide benefits and compensation to workers that comply with all applicable wage laws and regulations, including those relating to minimum wages, overtime hours, medical leave, and legally mandated benefits. Suppliers will refrain from making any deductions from wages as a disciplinary measure or imposing any financial burdens on workers related to recruitment costs. For each pay period, suppliers will provide workers with a timely and understandable written wage statement that includes sufficient information to verify accurate compensation for work performed. Workers shall receive equal pay for equal work, including paying a fair wage that meets or exceeds legal minimum standards. All use of temporary, dispatch and outsourced labour shall be within the limits of the local law. Workers must be paid directly, in a timely fashion, and in recognized currency. Suppliers will keep records of worker hours and wage documentation in accordance with local law.
Human Treatment
Suppliers will not engage in harsh or inhumane treatment including violence, gender-based violence, sexual harassment, sexual abuse, corporal punishment, mental or physical compulsion, bullying, public shaming, or verbal abuse of workers; nor is there to be the threat of any such treatment. Suppliers will have disciplinary policies and procedures in place for any violations of these requirements that are clearly defined and communicated to workers.
Recruitment Practices
Suppliers will not require workers to pay supplier’s agents or sub-agents recruitment fees or other related fees for their employment. Suppliers will provide full reimbursement to job seekers and workers, if they have been required to pay any such fees or related costs. If necessary for a supplier to use a labour supply contractor, the supplier will only use labour supplier that employ ethical recruitment practices, comply with applicable laws, and do not withhold identity documents.
Non-Discrimination / Non-Harassment
Suppliers will be committed to a workplace free of harassment and unlawful discrimination. Suppliers will not engage in discrimination, harassment, intimidation, violence, or other adverse actions to employees based on race, color, age, gender, sexual orientation, gender identity and expression, ethnicity or national origin, disability, pregnancy, religion, political affiliation, union membership, marital status or any other basis prohibited by law including in hiring and employment practices such as wages, promotions, rewards, and access to training.
Freedom of Association
Suppliers will comply with and respect all applicable local laws and ILO core conventions related to the rights of workers to form and join trade unions of their own choosing, to bargain collectively, to engage in peaceful assembly, as well as respect the right of workers to refrain from such activities. Suppliers will avoid any form of threats, intimidation, physical or legal attacks against stakeholders, including union members and union representatives, exercising their legal rights to freedom of expression, association, and peaceful assembly.
Diversity, Equity, and Inclusion
HML encourages suppliers to develop and promote inclusive cultures where diversity is valued and celebrated, and everyone can contribute fully and reach their full potential. Suppliers should encourage diversity in all levels of their workforce and leadership, including boards of directors.
Health & Safety
Suppliers will provide clean, healthy, and safe working environments for their personnel that meet or exceed legal standards. Suppliers will have safety procedures for their employees and tracking tools that drive to a goal of zero workplace safety incidents. Supplier employees will have the right to refuse work and report any conditions that do not meet these criteria. Suppliers will also properly manage the health and safety of contractors performing work on supplier’s premises.
Occupational Safety
Suppliers will identify, assess, and mitigate worker potential for exposure to all health and safety hazards including eliminating the hazard, substituting processes or materials, controlling through proper design, implementing engineering and administrative controls, preventative maintenance, and safe work procedures including energy lockout/tagout. Suppliers will provide ongoing occupational health and safety training, including prior to the beginning of work. Health and safety related information shall be clearly posted in the facility or placed in a location identifiable and accessible by workers. Where hazards cannot be adequately controlled by these means, suppliers will provide workers with appropriate, well-maintained, personal protective equipment (PPE) and associated training on how and when it needs to be applied. Suppliers will also provide communication and training to their workforce regarding the risks to them associated with these hazards.
Emergency Preparedness
Suppliers will work to actively identify and assess potential emergency situations and events and minimize their impact by implementing emergency plans and response procedures including emergency reporting, employee notification and evacuation procedures, worker training, and drills. Suppliers will execute emergency drills at least annually or as required by local law. Emergency plans should include appropriate fire detection and suppression equipment, clear and unobstructed egress, adequate exit facilities, contact information for emergency responders, and recovery plans.
Machine Safeguarding
Suppliers will evaluate production and other machinery for safety hazards. Physical guards, safeguarding devices, and barriers must be provided and properly maintained where machinery presents an injury hazard to workers.
Sanitation & Food
Suppliers will take reasonable measures to provide workers with ready access to clean toilet facilities, potable water, and clean eating facilities, adequate illumination, and ventilation.
Occupational Injury and Illness
Suppliers will have procedures and systems to prevent, investigate, root cause, manage, track, and report occupational injury and illness, including provisions to encourage worker reporting, classify and record injury and illness cases, provide necessary medical treatment, investigate cases, and implement corrective actions to eliminate their causes, and facilitate the return of workers to work.
ENVIRONMENT
Responsible Stewardship
- Suppliers will continually strive to protect the communities and environment that surround them. Suppliers will also continually strive to conserve natural resources including water, fossil fuels, minerals, and virgin forest products by practices such as modifying production, maintenance and facility processes, materials substitution, re-use, conservation, recycling, or other means. Suppliers should promote circularity and closed loop systems by supporting the use of sustainable, renewable natural resources while reducing emissions, pollution, and waste.
Environmental Permits and Reporting
- Suppliers will follow applicable local, national laws. Suppliers will obtain and keep current all required environmental permits, approvals, and registrations, follow their operational and reporting requirements, and will provide said documentation to HML upon request. HML encourages all suppliers to be bold and go beyond compliance obligations to integrate additional environmentally sustainable practices throughout the company.
Pollution Prevention
- Suppliers will minimize or eliminate emissions and discharges of pollutants and generation of waste at the source or by practices such as adding pollution control equipment, modifying production, maintenance, and facility processes, or by other means. Suppliers will routinely monitor and disclose, appropriately control, minimize, and strive to eliminate contributing to pollution, as required by and in accordance with applicable law. Suppliers should assess cumulative impacts of pollution sources at their facilities.
Greenhouse Gas Emissions
- Suppliers will continually strive to reduce greenhouse gas emissions. Suppliers will track Scope 1, 2, and 3 greenhouse gas emissions. Upon request, suppliers will share Scope 1, 2, and 3 greenhouse gas emissions data with HML, Suppliers shall establish time-bound emission reduction goals and shall aligned with HML’s GHG emission reduction targets.
Other Air Emissions
- Suppliers will follow applicable local, national air pollution control laws. Suppliers will characterize, routinely monitor, control, and treat emissions of air pollutants as required by law. Ozone depleting substances must be effectively managed in accordance applicable regulations. Suppliers will conduct routine monitoring of the performance of their air emission control systems. Hazardous air emissions shall be characterized, monitored, and controlled as required by permits and local, national regulation. Suppliers will monitor performance of air emission control systems for effectiveness.
Hazardous Substances
- Suppliers will identify, label, store, and manage chemicals, waste, and other materials posing a hazard to human health or the environment and will use safe handling, movement, storage, use, recycling or reuse, and disposal in compliance with requirements of national, and local laws. Suppliers will look for ways to reduce the use of hazardous materials and substances of concern within products and their manufacturing processes.
Materials Restrictions strong
- Suppliers will adhere to all applicable laws, regulations and HML requirements regarding restrictions and prohibitions of specific substances in products and manufacturing including labelling and disposal. If requested, suppliers will provide information or reports of the composition of all substances or materials supplied to HML.
Solid Waste
- Suppliers will implement a systematic approach to identify, manage, reduce, and responsibly dispose of or recycle solid waste (non-hazardous).
Water Management
- Suppliers will implement a water management program that documents, characterizes, and monitors water sources, use, and discharge; seeks opportunities to conserve water; and controls source of contamination. Waste water must be characterized, monitored, controlled, and treated as required prior to discharge or disposal. Suppliers will conduct routine monitoring of their wastewater treatment for optimal performance and to meet regulatory compliance. Suppliers should effectively use water. Supplier should prevent unpermitted discharges and mitigate the potential impacts of such discharges.
Animal Welfare
- Suppliers will respect the welfare of animals and provide humane treatment. No animal should be raised and killed for the single purpose of being used in automotive products.
- HML does not conduct or commission the use of animals in tests for research purposes or in the development of our automotive parts, either directly or indirectly. Suppliers will not supply any raw materials, components, parts, or assemblies to HML that involved testing on animals in its research or development.
Responsible Sourcing
Due Diligence
- Suppliers will implement a policy committing to the responsible sourcing of all minerals and materials in line with local and national regulatory requirements. These policies require conducting due diligence in accordance with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict Affected and High-Risk Areas, including its current supplements on tin, tantalum, tungsten and gold (3TG). Suppliers will disclose to HML, as necessary, updated smelter/ refiner information for any 3TG mineral used in the production of its parts, materials, components, and products. Suppliers will also engage with sub-tier suppliers to conduct due diligence by providing reporting templates or other information upon request.
Land Rights
- Suppliers will respect the communities in which they are based and serve. Suppliers will respect the land rights of individuals, indigenous people, and local communities in accordance with local laws, the ILO Indigenous and Tribal Peoples Convention, and the United Nations Declaration on the Rights of Indigenous People. Suppliers will respect the rights of local communities to decent living conditions, education, employment, social activities, and the right to Free, Prior, and Informed Consent (FPIC) to developments that affect them and the lands on which they live, with consideration for the presence of vulnerable groups. Suppliers should also protect ecosystems, especially key biodiversity areas, impacted by their operations, and avoid illegal deforestation in accordance with national biodiversity regulations. Suppliers should routinely monitor and control their impact on soil quality to prevent soil erosion, nutrient degradation, subsidence, and contamination. Suppliers should routinely monitor and control the levels of industrial noise to avoid noise pollution.
BUSINESS INTEGRITY
Anti-Corruption/Anti-Bribery
- Suppliers will not tolerate corruption, bribery, money laundering, extortion, or fraud in any form. This includes giving or receiving anything of value, including money, gifts, or unlawful incentives to improperly influence negotiations or any other dealings with governments and government officials, customers, or any other third parties. Suppliers will implement monitoring, record keeping, and enforcement procedures to comply with anti-corruption laws.
Disclosure of Information
- Suppliers will accurately disclose information regarding their labour, health and safety, environmental practices, business activities, structure, financial situation, and performance in accordance with applicable regulations. All of supplier business dealings will be transparently performed and accurately reflected on the supplier's business books and records. Falsification of records or misrepresentation of conditions or practices in the supply chain are unacceptable.
Intellectual Property
- Suppliers will respect intellectual property rights. Transfer of technology and know-how must be done in a manner that protects intellectual property rights, and customer and supplier information must be safeguarded.
Counterfeit Parts
- Suppliers will never utilize counterfeit parts in any product supplied to HML. Suppliers will also minimize the risk of introducing diverted parts and materials into deliverable products and adhere to relevant technical regulations in the product design process.
Privacy
- Suppliers will protect the reasonable privacy expectations of personal information of everyone they do business with, including suppliers, customers, consumers, and employees. Suppliers will comply with privacy and information security laws and regulatory requirements when personal information is collected, stored, processed, transmitted, and shared.
Export Controls and Economic Sanctions
- Suppliers will comply with all applicable restrictions on the export, re-export, release or other transfer of goods, software, services, and technology; all applicable economic sanctions restrictions involving certain territories, entities, and individuals and all other similar trade-related laws and regulations.
Confidential Information
- Company’s information is a vital corporate asset that merits the same protection as the Company’s physical assets. This information is integral to Company’s success and it is critical that the Suppliers safeguard this information. Carelessness in the protection of confidential information may have a direct impact on Company’s financial performance. Suppliers have entered into a non-disclosure or confidentiality agreement detailing their obligations regarding the Company’s confidential information and they must adhere to this agreement.
Fair Competition
- Company is committed to competing fairly in the marketplace. Company strives to achieve competitive advantages through excellent quality and performance and not through unethical or illegal business practices. Suppliers must refrain from any and all unfair behavior and not engage or tolerate unfair competition practices.
Data Privacy
- The Suppliers shall ensure that all assets (whether tangible or intangible) of the Company are used for legitimate and authorized business purposes only. Supplier shall keep any confidential information in strictest confidence and not misuse it in any manner, even after cessation/termination of contract with Company. The Supplier shall not sell or disclose the Personal Data related to the Company or it’s customers to any third party. The Suppliers shall not retain, use, disclose or otherwise process the Personal Data outside of the direct business relationship with the Company. The Suppliers shall comply (and ensure that its contractors, agents or related third parties comply) with applicable Data Privacy.
Grievance Mechanisms and Non-Retaliation
- Suppliers will provide a clearly communicated grievance mechanism, in local languages, for workers to utilize to report integrity concerns, human rights concerns, safety issues, and misconduct without fear of reprisal. suppliers will provide workers with a safe, confidential, and anonymous environment to provide grievance and feedback and will reasonably protect whistleblower confidentiality. Suppliers will also have a process inplace for subcontractors and the community associated with the supplier’s operations to raise concerns to the supplier. Suppliers should periodically assess their grievance mechanism. Suppliers will prohibit all forms of retaliation against those who raise concerns in good faith. Suppliers will also appropriately investigate reports and take corrective action, if needed. Suppliers will cascade these expectations through their own supply chain.
Reporting Concerns to HML
- Subject to any restriction posed by law, suppliers will promptly inform HML of any concern related to issues governed by this Code and collaborate with HML in subsequent investigations. HML policy prohibits retaliation against any person reporting such a concern. To report a concern, suppliers can always speak directly to their HML Purchasing and Supply Chain representative. In addition, the HML whistleblower email [email protected] allows employees, contractors, suppliers, and others to report concerns of misconduct affecting HML.
MANAGEMENT SYSTEMS
Suppliers will develop and implement an appropriate internal management system to comply with applicable law and the content of this Code. Suppliers will be able to demonstrate compliance with this Code upon HML’s request and will take any action to correct any non-compliance. If requested, suppliers will complete questionnaires or participate in on-site assessment or audits.
The management system should contain the following elements: