Supplier Code of Conduct

Revision 1.0 – June 18, 2025

INTRODUCTION

This Supplier Code of Conduct ("Code") establishes the fundamental principles and requirements that all suppliers, vendors, contractors, and their subcontractors ("Suppliers") must follow when conducting business with Sumix. These standards reflect our commitment to responsible business practices and our expectation that all partners share these values.

Compliance Requirement: All Suppliers must operate in full compliance with applicable laws, regulations, and industry standards of the jurisdictions in which they operate. Where this Code sets higher standards than local law, Suppliers are expected to meet these higher standards.

 

1. Business Ethics and Integrity

1.1 Ethical Business Conduct

Suppliers must conduct business with the highest level of integrity, honesty, and ethical behavior. We expect our Suppliers to maintain zero tolerance for corruption, bribery, extortion, kickbacks, or any other form of unethical business practice.

1.2 Anti-Corruption and Bribery

Suppliers must not engage in any form of corruption or bribery, whether dealing with government officials, private parties, or Sumix personnel. This includes: offering or accepting bribes, kickbacks, or inappropriate gifts, making facilitation payments or similar irregular payments, engaging in any activity that could create conflicts of interest, and providing inappropriate entertainment or hospitality.

1.3 Fair Competition

Suppliers must compete fairly and comply with all applicable antitrust and competition laws. Anti-competitive practices such as price-fixing, market allocation, or bid-rigging are strictly prohibited.

1.4 Accurate Records and Transparency

Suppliers must maintain accurate and complete business records, including financial records, quality documentation, and compliance records. All information provided to Sumix must be truthful and accurate.

1.5 Intellectual Property Protection

Suppliers must respect and protect intellectual property rights, such as patents, copyrights, trademarks, and trade secrets. They are responsible for protecting Sumix's proprietary information and technology, respecting third-party intellectual property rights, properly handling confidential information, and complying with technology transfer regulations.

 

2. Human Rights and Labor Standards

2.1 Prohibition of Forced Labor

Suppliers must not use forced, bonded, indentured, trafficked, or involuntary labor of any kind. All work must be voluntary, workers must not be required to surrender identity documents, recruitment fees must not be charged to workers, and workers must be free to leave employment with reasonable notice.

2.2 Child Labor Prohibition

Suppliers must not employ anyone under the minimum age for employment as defined by local law, or under 15 years of age, whichever is higher. Workers under 18 must not perform hazardous work or work that interferes with their education.

2.3 Non-Discrimination and Equal Opportunity

Suppliers must provide equal employment opportunities and maintain workplaces free from discrimination and harassment based on race, color, religion, gender, sexual orientation, gender identity, national origin, disability, age, or any other protected characteristic.

2.4 Freedom of Association

Suppliers must respect workers' rights to associate freely, join or not join labor unions, and engage in collective bargaining in accordance with local laws.

2.5 Working Hours and Compensation

Suppliers must comply with all applicable wage and hour laws, pay at least minimum wage and provide legally required benefits, not require workers to work more than 60 hours per week, including overtime, provide at least one day off every seven days, and ensure all overtime is voluntary.

3. Health and Safety

3.1 Workplace Safety

Suppliers must provide a safe and healthy work environment for all workers. This includes identifying and controlling workplace hazards, providing appropriate personal protective equipment, maintaining safety equipment and emergency systems, training workers on safety procedures, and encouraging reporting of safety concerns without retaliation.

3.2 Emergency Preparedness

Suppliers must have emergency response plans, procedures, and equipment in place, including fire detection and suppression systems, clear evacuation routes, and regular emergency drills.

3.3 Occupational Health

Suppliers must monitor workplace conditions and worker health, control exposure to hazardous materials, and provide necessary medical care and support for work-related injuries and illnesses.

3.4 Facility Standards

Suppliers must provide clean, safe facilities including adequate lighting, ventilation, sanitation facilities, and access to potable water. Any worker housing provided must meet local housing standards.

 

4. Environmental Responsibility

4.1 Environmental Compliance

Suppliers must comply with all applicable environmental laws and regulations, maintain required environmental permits, and report environmental impacts as required by law.

4.2 Pollution Prevention and Waste Reduction

Suppliers must minimize environmental impact by reducing waste generation and emissions, implementing recycling and reuse programs, using resources efficiently, properly managing hazardous materials, and treating wastewater and controlling air emissions.

4.3 Sustainable Practices

Suppliers are encouraged to adopt sustainable business practices, including energy efficiency measures, renewable energy use, and sustainable sourcing of materials.

 

5. Information Security and Data Protection

5.1 Confidentiality

Suppliers must protect Sumix's confidential and proprietary information, including technical data, business information, and customer data. This information must not be disclosed to unauthorized parties or used for purposes other than fulfilling contractual obligations.

5.2 Data Security

Suppliers must implement appropriate technical and organizational measures to protect personal data and confidential information from unauthorized access, use, disclosure, modification, or destruction.

5.3 Privacy Protection

Suppliers must comply with applicable privacy laws and regulations when handling personal information of Sumix employees, customers, or other stakeholders.

 

6. Quality and Product Safety

6.1 Quality Management

Suppliers must maintain quality management systems appropriate for their products and services, including proper documentation, testing, inspection, and continuous improvement processes.

6.2 Product Safety

Suppliers must ensure that all products and services meet specified safety requirements and applicable safety standards.

6.3 Traceability

Suppliers must maintain adequate records to ensure product traceability throughout the supply chain, including component sourcing, manufacturing processes, and quality control measures.

 

7. Supply Chain Responsibility

7.1 Supplier Management

Suppliers must implement appropriate due diligence processes for their own suppliers and subcontractors to ensure compliance with the principles of this Code.

7.2 Risk Management

Suppliers must identify and manage supply chain risks, including developing contingency plans for business continuity and implementing security measures to protect against supply chain disruptions.

7.3 Sub-supplier Compliance

Suppliers must ensure that their subcontractors and sub-suppliers are aware of and comply with the requirements of this Code.

 

8. Monitoring and Compliance

8.1 Management Systems

Suppliers must establish and maintain management systems to ensure compliance with this Code. These systems must include documented policies and procedures, regular risk assessments, training programs for employees, performance monitoring and measurement, and corrective action processes.

8.2 Audits and Assessments

Sumix reserves the right to audit or assess Supplier compliance with this Code through self-assessments, on-site audits, or third-party evaluations. Suppliers must provide reasonable access to facilities, records, and personnel for such assessments.

8.3 Continuous Improvement

Suppliers must continuously work to improve their performance in areas covered by this Code and implement corrective actions when deficiencies are identified.

 

9. Reporting and Non-Retaliation

9.1 Reporting Violations

Suppliers and their employees must report any known or suspected violations of this Code or applicable laws. Reports can be made through the following channels:

9.2 Non-Retaliation

Suppliers must not retaliate against any person who reports violations or participates in investigations in good faith. Sumix takes reports of retaliation seriously and may terminate business relationships with Suppliers who engage in retaliation.

 

10. Implementation and Enforcement

10.1 Compliance Commitment

By doing business with Sumix, Suppliers commit to complying with this Code and all applicable laws and regulations. Suppliers must communicate these requirements to their employees, subcontractors, and suppliers.

10.2 Corrective Actions

When violations of this Code are identified, Suppliers must take immediate corrective action and implement measures to prevent recurrence. Sumix may require specific corrective action plans and timelines.

10.3 Consequences of Non-Compliance

Failure to comply with this Code may result in the requirement for immediate corrective action, additional monitoring and oversight, suspension of business activities, termination of business relationship, or legal action where appropriate.

10.4 Updates and Revisions

Sumix reserves the right to update or revise this Code as needed. Suppliers will be notified of any changes and must comply with the updated requirements.