In all activities, Kitron’s suppliers must comply with applicable legislation, rules and regulations in the
countries in which they operate. If any legislation, rules or regulations is in conflict with the Kitron Supplier
Code of Conduct, the highest standard shall be applied.
The suppliers are expected to support the UN’s Universal Declaration of Human rights and ensure that they
are not complicit in human rights abuse.
1. Labor rights
1.1. Freely chosen employment
Forced, bonded or indentured labour or involuntary prison labour is not to be used. All work must be voluntary,
and workers should be free to leave upon reasonable notice. Workers shall not be required to hand over
government-issued identification, passports or work permits as a condition of employment.
1.2. Child labor avoidance
Child labour is not to be used in any stage of manufacturing. The term “child” refers to any person employed
under the age of 15 (or 14 where the law of the country permits), or under the age for completing compulsory
education, or under the minimum age for employment in the country, whichever is greatest. The use of
legitimate workplace apprenticeship programs, which comply with all laws and regulations, is supported.
Workers under the age of 18 should not perform hazardous work and may be restricted from night work
with consideration given to educational needs.
1.3. Working hours
Workweeks are not to exceed the maximum set by local law. Further, a normal workweek should not on a
regular basis exceed 60 hours per week, including overtime. Workers shall be allowed at least one day off
per seven-day workweek.
1.4. Wages and benefits
Compensation paid to workers shall comply with all applicable wage laws, including those relating to
minimum wages, overtime hours and legally mandated benefits. The compensation should meet basic
needs and provide some discretionary income. In compliance with local laws, workers shall be compensated
for overtime at pay rates greater than regular hourly rates. The basis on which workers are paid is to be
specified in a timely manner via a pay stub or similar documentation.
1.5. Humane treatment
The supplier’s disciplinary policies and procedures shall be clearly defined and communicated to the
personnel. There shall be no harsh and inhumane treatment including any sexual harassment, sexual abuse,
corporal punishment, mental or physical coercion or verbal abuse of workers. Nor is there to be the threat
of any such treatment.
Companies shall not engage in discrimination based on gender, race, religion, sexual orientation, colour, age,
ethnicity, disability, pregnancy, political affiliation, union membership or marital status when hiring or in con-
junction with employment practices such as promotions, rewards, and access to training. In addition, workers
or potential workers should not be subjected to medical tests that could be used in a discriminatory way.
1.7. Freedom of association
Open communication and direct engagement between workers and management are the most effective ways
to resolve workplace and compensation issues. Suppliers shall respect the rights of workers to associate
freely, to join or not to join labour unions, to seek representation, join workers’ councils in accordance with
local legislation, etc. Workers shall be able to communicate openly with management regarding working
conditions without fear of reprisal, intimidation or harassment. Where the right to freedom of association
and collective bargaining are restricted under national legislation, the supplier shall allow workers to freely
elect their own representatives.
2. Health and safety
2.1. Occupational safety
Worker exposure to potential safety hazards shall be minimized through proper design, engineering and
administrative controls, preventative maintenance and safe work procedures as well as by on-going safety
training. Where hazards cannot be adequately controlled by these means, workers are to be provided with
appropriate, well-maintained, personal protective gear. Workers shall not be disciplined for raising safety
2.2. Emergency preparedness
Potential emergency situations and events shall be identified and assessed, and their impact minimised
by implementing emergency plans and response procedures, including emergency reporting, employee
notification and evacuation procedures, worker training and drills, appropriate fire detection and extinguishing
equipment, adequate exit facilities and recovery plans.
2.3. Occupational injury and illness
Procedures and systems shall be in place to prevent, manage, track and report occupational injury and
illness, including provisions to encourage worker to report, classify and record injury and illness cases,
provide necessary medical treatment, investigate cases and implement corrective actions to eliminate their
causes, and to help workers return to work.
2.4. Sanitation, food and housing
Workers are to be provided with ready access to clean toilet facilities, water fit for human consumption and
sanitary food preparation, storage, and eating facilities. Worker dormitories provided by the supplier or a
labour agent are to be kept clean and safe, and provided with appropriate emergency exits, hot water for
bathing or showering, and adequate heat and ventilation, as well as reasonable personal space along with
reasonable entry and exit privileges.
3. The environment
Kitron suppliers with manufacturing operations should minimize the adverse effects to community,
environment and natural resources while safeguarding the health and safety of the public.
All required environmental permits are to be obtained, maintained, kept current and their reporting
requirements are to be followed.
3.1. Pollution prevention and Resource reduction
Waste of all types, including water and energy, are to be reduced or eliminated at the source or by practices
such as modifying production, maintenance and facility processes, materials substitution, conservation,
recycling and re-using materials.
3.2. Hazardous substances
Chemical and other materials that pose a hazard if released to the environment are to be identified and
managed to ensure their safe handling, movement, storage, use, recycling or reuse and disposal.
3.3. Wastewater and solid waste
Wastewater and solid waste generated from operations, industrial processes and sanitation facilities are to
be characterised, monitored, controlled and treated as required prior to discharge or disposal.
3.4. Air emissions
Air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting chemicals
and combustion by-products generated from operations are to be characterized, monitored, controlled and
treated as required prior to discharge.
In areas vulnerable to a scarcity of freshwater, suppliers are expected to seek ways to measure and disclose
the use of freshwater. Plans should also be established for reducing the use of freshwater in operations.
4. Anti - corruption
4.1. Business integrity
Suppliers are to uphold the highest standards of integrity and business ethics in all business transactions.
Suppliers and those working on behalf of the suppliers shall have a zero tolerance policy to prohibit all forms
of bribery, extortion or embezzlement. Monitoring and enforcement procedures shall be implemented to
4.2. No improper advantage
Bribes or other means of obtaining undue or improper advantage are not to be offered or accepted.
4.3. Disclosure of information
Information regarding business activities, structure, financial situation and performance shall be disclosed in
accordance with applicable regulations and prevailing industry practices.
4.4. Intellectual property rights
Intellectual property rights shall be respected; the transfer of technology and know-how shall be done in a
manner that protects intellectual property rights.
4.5. Fair trading, advertising and competition
Standards for fair trading, advertising and competition are to be upheld. Appropriate means should be
available to safeguard customer information.
4.6. Protection of identity
Programmes shall be implemented to ensure confidentiality and protection of a supplier or an employee
4.7. Responsible sourcing of minerals
Kitron’s suppliers shall have policies to reasonably assure that the tantalum, tin, tungsten and gold in the
products they manufacture does not directly or indirectly finance or benefit armed groups that are perpetrators
of serious human rights in the Democratic republic of Congo or an adjoining country. Suppliers shall exercise
due diligence on the source and chain of custody of these minerals and make their due diligence measures
available on request.
Kitron suppliers are expected to have a communicated process for their personnel to be able to raise
concerns without fear of retaliation.
5. Practicalities and follow-up
The supplier should designate an individual in a senior management position to ensure compliance with the
Supplier Code of Conduct.
5.2. Records and audits
The supplier is expected to maintain appropriate records to demonstrate conformance with the requirements
of the Supplier Code of Conduct.
In the event of an audit of the supplier for the purpose of verifying compliance with the requirements in this
document, Kitron personnel, Kitron’s customer or Kitron consultants shall have necessary access to the
appropriate records and any part of the premises where work under the contract is being performed. This Supplier Code of Conduct
also includes work performed at the subcontractor’s suppliers’ premises.
5.3. Communication of the Supplier Code of Conduct
Suppliers are expected to communicate the requirements of this Supplier Code of Conduct to all appropriate
employees, suppliers or sub-contractors engaged in their supply chain. Suppliers should take steps to
ensure that their suppliers and sub-contractors comply with requirements of this Supplier Code of Conduct.
Suppliers should also provide means for employees to report on or discuss non-compliance confidentially.