Airam Code of Conduct for Suppliers and their Subcontractors

Compliance 

This Airam Supplier Code of Conduct defines the minimum ethical principles and sustainability requirements we expect you as our Supplier to implement across all your operations.  

Compliance with laws is a self-evident practice for us. We expect you to follow and comply with all applicable laws and regulations, the requirements set out in this Airam Supplier Code of Conduct, amfori BSCI Code of Conduct, amfori BEPI Code of Conduct and your contractual obligations to us.  

You shall ensure compliance with any applicable Corporate Responsibility Regulations, including but not limited to the following themes: Corporate Sustainability Reporting, Corporate Sustainability Due Diligence and Product Sustainability. 

Human rights and labor rights   

We are committed to respect human rights and labor rights as recognized in the international standards, such as United Nations Universal Declaration of Human Rights, and International Labor Organization Conventions. We expect the same from you as our Supplier. Human rights and fair labor conditions included in amfori BSCI Code of Conduct and amfori BEPI Code of Conduct shall apply in full.  

As our Supplier, you shall give special focus on the following topics: 

Child labor 

We at Airam have a zero-tolerance policy for child labor. Do not employ, directly or indirectly, any workers younger than 15 years of age in any stage of your activities, unless the exceptions recognized by the ILO apply. 

Forced labor 

You must not use or benefit from any form of forced or compulsory labor, including but not limited to involuntary prison labor, victims of slavery and human trafficking.  

You must allow all employees the choice to leave their employment freely upon reasonable notice. 

Freedom of association 

You shall respect the rights of employees to freely associate and bargain collectively. In situations where freedom of association is restricted or prohibited by law, or if no recognized union exists, you should be supportive of alternative means of worker representation and engagement. 

Discrimination and harassment 

We expect you to treat all workers with respect and dignity. You shall prohibit any behavior, that is sexual, coercive, threatening, abusive or exploitative.  

You shall provide equal opportunity and treatment in employment, without regard to gender, age, ethnicity, nationality, religion, disability, union membership, political affiliation, sexual orientation, or any other similar distinction which is not based on the inherent requirements of the work. 

Occupational health and safety 

You must provide a safe and healthy workplace for all your employees.  

Furthermore, we expect you to formally appoint a competent person to manage health and safety programs and improvements, establish appropriate organizational structures and procedures for the effective management of health and safety risks, and ensure that all your workers are sufficiently aware of these risks and appropriately trained on the implementation of control measures. 

Working hours and fair compensation 

You shall compensate employees fairly and follow local wage regulations and/or collective agreements, and where these do not exist, compensate employees so at the minimum they can meet their basic needs. 

We expect you to actively work towards a living wage, that is sufficient to afford a decent standard of living for the workers and their families in the local context. 

You shall ensure that working hours, including overtime, do not exceed applicable legal requirements. Use overtime as an exceptional and voluntary practice, paid at a premium rate.  

You must ensure that employees are allowed at least one uninterrupted day off per week.

Environment and Raw Materials 

Environmental Management 

We take environmental issues into account in our operations and place a high value on environmentally conscious practices and products. As our Supplier, we expect you to conduct your business in an environmentally sustainable manner.  

You shall have a management system, organizational structures and procedures in place to ensure efficient management of environmental issues and risks.  

We expect you to formally appoint a competent person to manage environmental programs and improvements and ensure that all workers are sufficiently aware of these risks and appropriately trained on the implementation of control measures.  

Carbon emissions and climate target 

As our Supplier you commit to monitor and mitigate scope 1 and 2 greenhouse gas (GHG) emissions, as a minimum. Aligned with the GHG Protocol, you must include all your company’s direct GHG emissions in scope 1 and the indirect GHG emissions from consumption of purchased electricity, heat or steam by your company in scope 2. 

We strongly encourage you to set targets to reduce your GHG emissions aligned with the Science Based Targets initiative (SBTi) and develop and implement a plan to achieve them. 

Material compliance, conflict minerals and scarce raw materials  

At Airam, we are committed to complying with regulatory and customer requirements regarding material compliance, as well as restrictions on harmful substances and unethical materials. As our Supplier, we expect you to give special attention to the handling of conflict minerals (tin, tungsten, tantalum and gold), scarce raw materials (such as rare earth elements), and materials in general.  

You shall ensure that the goods provided to Airam comply with all relevant regulatory requirements. 

We specifically expect you to promptly notify us if any substances in the products you supply are subject to EU restrictions. Additionally, you must inform us immediately if any product supplied to us contains a prohibited substance. 

Furthermore, you are expected to establish and enforce a policy prohibiting the use of conflict minerals in your products, and to exercise due diligence in verifying the origin of these minerals. 

Corporate Governance and Business ethics 

Business ethics 

We have a zero-tolerance policy when it comes to unethical business behavior, such as bribery and corruption. We expect all our Suppliers to adhere to these high standards also, and to conduct their business ethically.  

At Airam we follow the development of corporate governance practices and apply them in all our activities. We pay special attention to supervision and reporting practices to ensure that our operations are lawful and that we comply with these principles. We expect you as our Supplier also to incorporate these practices into your own operations to the relevant extent. 

Anti-corruption, competition and conflict of interest 

You must refrain from all forms of corruption, extortion and bribery, and specifically ensure that payments, gifts or other commitments to customers (including Airam employees), government officials and any other party are in compliance with applicable anti-bribery laws.  

You shall adhere to anti-trust and other competition laws.  

We expect you to disclose to Airam information regarding potential conflicts of interest relating to your activities as an Airam Supplier, including disclosure of any financial interest an Airam employee may hold in your business.  

Confidentiality, intellectual property, international trade 

You must protect all confidential information provided by Airam and our respective business partners. 

You shall respect the intellectual property of others, including Airam, and adhere to international trade regulations and export control regulations.  

Sustainability data  

We may request from you any relevant information on relevant environmental, social and corporate governance (ESG) topics. These may relate to but are not limited to, carbon footprint (scope 1-2-3), environmental impact, governance matters, social responsibility such as workers’ rights and impacts in the value chain.  

The information may relate to the performance of the Supplier or that of the Products. You shall respond to the information requests without undue delay and provide the documentation as part of the delivery documentation, if any. 

Security in business activities 

You shall conduct your business in a secure manner. We expect you to implement reasonable measures for minimizing exposure of Airam to security threats such as terrorism, crime, pandemics and natural disasters. 

Due Diligence  

Due Diligence mechanisms and processes 

Human rights and environmental due diligence throughout our supply chain is crucial because it ensures that we, as well as other businesses in our value chain, operate ethically and responsibly, as required by EU laws and increasingly demanded by our customers.  

As our Supplier, we expect you to commit to necessary and appropriate measures to identify actual and potential adverse human rights and environmental impacts in your own operations and in your supply chain.  

You shall also put in place appropriate measures to prevent or adequately mitigate potential adverse impacts that have been identified. You shall also, where applicable, adopt measures to end current adverse impacts either immediately or gradually where immediate cessation is impracticable. 

You shall establish and provide a grievance mechanism that can be used by those negatively affected by your business activities and operations to access a formal complaint process. In addition, you shall support mechanisms that facilitate transparency and speaking up in general. You must ensure that no retaliation measures are taken against any person speaking up. 

Airam is committed to taking corrective action, and as part of this commitment, Airam has a right to take action that also concerns the supply chain. 

You shall also take corrective action and provide remediation in cases where actual adverse impacts have occurred and were caused by your activities or those of your business partners.   

As our Supplier, you specifically commit to obtaining and maintaining adequate information on the environmental and human rights impacts of your entire value chain. 

You shall comply with the procedures required by UNGP and OECD Guidelines for Multinational Enterprises, UN Children’s Rights and Business Principles. 

Procurement by Supplier  

You shall procure goods and services in a responsible manner. In particular, you will select your own tier one Suppliers providing goods or services directly or indirectly to Airam based on them agreeing to adhere to standards comparable to those set forth in this Airam Supplier Code of Conduct. 

Your own Suppliers shall commit to amfori BSCI Code of Conduct, amfori BEPI Code of Conduct principles.   

Implementation 

We expect you to read and comprehend the content of this Code of Conduct and comply with it across your operations. We urge that you actively manage and monitor the implementation of this Code of Conduct to ensure it is properly followed.  

You are obliged to inform your upstream partners of the existence of this policy to secure their awareness and compliance.  

During the new Supplier approval process, we evaluate and select Suppliers based on this Supplier Code of Conduct. If a Supplier does not meet the requirements, they are either given an opportunity to implement corrective actions before approval or they are rejected. 

Audits and corrective actions 

In order to ensure and demonstrate compliance with the Airam Supplier Code of Conduct, you shall keep a record of all relevant documentation, and provide us with supporting documentation upon request.  

To verify your compliance, we reserve the right to audit and inspect your operations and facilities, at our own cost and upon reasonable notice, or no notice, with or without the support of a third party.  

If we determine that you are not in compliance with this Airam Supplier Code of Conduct, you shall take the necessary corrective action in a timely manner, as agreed with us.  

If you fail to take corrective action, we may take action against you, including suspending or terminating your status as one of our Suppliers. 

Reporting on violations and no-retaliation policy 

Speaking up is encouraged. You should promptly notify us of any actual or suspected violation of this Code of Conduct or any applicable laws. This can be done through an anonymous channel at https://app.falcony.io/airam-wb/links/whistleblowing 

We will not tolerate retaliation against anyone who in good faith raises questions or concerns about a potential violation of the law, or this Code of Conduct, or who assists in an investigation of a reported violation.