Code of Conduct
The Steiner Electric Company Code of Conduct ("Supplier Code") sets forth principles that Steiner has adopted to promote ethical conduct in the workplace, safe working conditions in Steiner's supply chain, treatment of workers with respect and dignity, and environmentally responsible distribution processes.
Steiner Electric Company embraces diversity and legal compliance as fundamental principles and key components of its operation. It is our desire that all suppliers to Steiner, similarly embrace diversity and equal opportunity to the fullest extent possible. All suppliers must operate in full compliance with the laws, rules and regulations of the jurisdictions in which they operate, and they must act ethically at all times.
ETHICS AND STANDARDS OF CONDUCT
Suppliers are expected to conduct business with integrity and mutual respect and to uphold the highest standards of ethics and behavior, including:
1) Business Integrity
Any and all forms of illegal or inappropriate activity, including, but not limited to, corruption, misrepresentation, extortion, embezzlement or bribery, are strictly prohibited and may result in termination of any or all supply agreements with Steiner and possible legal action. Records prepared for Steiner, including records of work time and expenses, shall be accurate, truthful and complete, and shall meet applicable standards and requirements.
2) Company Information
Safeguarding from disclosure Steiner's confidential and proprietary information concerning matters such as our business activities, strategies, plans, structure, technology, customers, financial situation and performance is critical to the company's success, and such information cannot be disclosed or used, except in accordance with applicable regulations, contractual requirements and this Code. It is paramount that our business providers safeguard Steiner's information.
- Understand any specific requirements for using Steiner's information and, when not sure, seek guidance from Steiner.
- Comply with applicable non-disclosure agreements and contractual confidentiality requirements regarding information belonging to or in the possession of Steiner.
- Immediately notify Steiner of any request or demand by a third party for Steiner information.
- Never misuse or disclose confidential or proprietary information to unauthorized parties.
- Use caution when discussing non-public information in public or any place where others may overhear.
- Safeguard and appropriately handle Steiner information and information regarding the Steiner brand or logo.
- Secure Steiner's written approval before using information about Steiner or Steiner's name or brand identity publicly in any publicity, advertising or website.
- Do not access, use, copy, manage, store or process company information outside the United States without the prior written approval of Steiner.
3) Competitor Disparagement and Obtaining Information
Steiner competes based on the strength of its products, services, reputation, and fair and accurate comparisons with its competitors. Suppliers should not make unfair, misleading, or inaccurate comparisons with the products and services of Steiner's competitors. Steiner acquires competitive and other information only using proper means and without misrepresentation, and Steiner's suppliers, their agents and permitted subcontractors shall similarly do so.
4) Advertising and Marketing
If a Steiner supplier is, with Steiner's prior written approval, engaged in any advertising, marketing or promotional activities that reference or implicate Steiner, its name, logo or services in any manner, such materials must comply with all laws, rules and regulations, and must be truthful and accurate. Materials must not be false, misleading or have a tendency to deceive, and all claims must be substantiated. All suppliers' advertising must make clear and conspicuous disclosure of material terms and limitations of advertised offers.
5) Alcohol and Drugs
Suppliers must not report to work or engage in any work for or on behalf of Steiner, or in any fashion represent, or make any representations on behalf of Steiner, while under the influence of illegal drugs or alcohol. In addition, suppliers may not possess illegal drugs or controlled substances while on Steiner premises or while conducting business with or for Steiner. This prohibition does not include legally obtained medications used as directed by a licensed medical practitioner that do not create a safety risk such as possible impairment in operating machinery.
6) Conflicts of Interest
Suppliers must avoid engaging in any business activity that would conflict or interfere with their provision of products and services to Steiner.
7) Company Property, Funds and Information
Suppliers must use all Steiner property, including but not limited to, equipment, funds, documents, electronic and written information and communications systems, with care and adherence to acceptable standards, applicable laws, and Steiner's rules and procedures. Suppliers are required to report any suspected or actual misuse, theft, vulnerability, improper exploitation or sabotage of Steiner property.
8) Business Courtesies
Steiner's suppliers, like Steiner, are expected to compete based on the merit of their products and services, not through gifts, entertainment, or other business courtesies. Although business courtesies can promote successful working relationships and good will, Steiner expects its suppliers to follow all applicable laws and Steiner's rules and procedures with respect to gifts, entertainment, and other business courtesies when working with or representing Steiner.
9) Working with the U.S. Government
When interacting with U.S. federal, state and local government bodies and agencies, and their representatives, Steiner's suppliers must conduct themselves with honesty and integrity, and comply with all applicable laws and regulations, including, but not limited to, laws and regulations relating to government ethics, lobbying and the handling of confidential, classified and other government information. Suppliers whose work with Steiner relates to U.S. federal government contracts may be subject to additional requirements as specified in their contracts with Steiner.
10) Reporting Concerns or Misconduct
Suppliers must report concerns and potential or actual misconduct that violate this Supplier Code of Conduct. Suppliers shall, consistent with any applicable law and privilege, provide reasonable assistance to any investigation by Steiner of a violation of the Supplier Code of Conduct. When reporting suspected or actual misconduct, suppliers should report concerns to:
Suppliers of products or services produced in or provided from the United States shall comply with all applicable federal, state and/or local laws and regulations. Suppliers of products or services produced or provided from outside the United States shall comply with applicable laws and regulations of relevant countries. However, regardless of applicable laws and regulations, suppliers must uphold the human rights of workers by treating them with dignity and respect. Supplier shall comply with the Dodd-Frank Wall Street Reform and Consumer Protection Act, Section 1502 concerning conflict minerals. Suppliers retained by Steiner and their agents and permitted subcontractors are fully responsible for the quality, performance, behavior, supervision and protection of their personnel.
HEALTH and SAFETY
Suppliers to Steiner must conform to all applicable health, safety and environmental laws and regulations. Ongoing worker input and education is key to identifying and resolving health and safety issues in the workplace, and these are critical to the overall success of a safety and health program. Accordingly, suppliers retained by Steiner should address the following:
- 1) Occupational Safety
Every supplier shall be committed to the safety and health of its employees, and shall ensure that required training of personnel has been completed prior to initiating any work activity. The supplier should have or subscribe to a written safety and health program. Suppliers are responsible for addressing and controlling worker exposure to potential safety hazards in conformance with all applicable standards and/or regulations and by utilizing suitable means, e.g., design, engineering and administrative controls, preventative maintenance, training, work procedures, and appropriate personal protective equipment.
- 2) Emergency Preparedness
Suppliers to Steiner shall have emergency plans and response procedures that implement all applicable laws and regulations regarding: emergency preparedness, reporting and notification; evacuation procedures, training and drills; appropriate hazard detection and suppression equipment; and adequate exit facilities from job sites.
- 3) Occupational Injury and Illness
Suppliers to Steiner shall have procedures and systems to manage, track and report: motor vehicle incidents, occupational injuries and illnesses, and exposure of workers to chemical, biological and physical agents. Such procedures and systems shall implement all applicable laws and regulations, and include provisions to:
a) encourage worker reporting;
b) classify and record injury and illness cases; and
c) investigate cases and implement corrective actions.
Adverse effects on the community, environment and natural resources are to be minimized while safeguarding the health and safety of the public. Suppliers must comply with all applicable health, safety and environmental laws and regulations when conducting business with Steiner. By way of example and not limitation, Steiner's suppliers must:
1) obtain and keep current all required environmental permits and registrations;
2) reduce, control and/or eliminate wastewater, waste and pollution at the source;
3) reduce, control and/or eliminate air emissions of volatile chemicals, corrosives, particulates, aerosols and combustion products;
4) conform to applicable labeling and warning requirements; and
5) identify, manage, store, move and handle hazardous substances in accordance with law.