Supplier Code of Conduct

This Supplier Code of Conduct (Code) sets forth the general requirements applicable to any supplier providing goods or services to Servicios de Frontera DEHP S de RL DE CV. Suppliers shall strive to establish and maintain management systems that are designed to ensure compliance with applicable laws, regulations and customer requirements that relate to the supplier's operations and products, compliance with this Code of Conduct and identification of operational risks related to this Code. In addition, suppliers shall commit to a policy of continuous improvement in their respective business activities.

The principles outlined in this Code, the Code of Business Conduct and Ethics, the Human Rights and Working Conditions Policy, the Environmental, Health and Safety Policy, and other policies Servicios de Frontera DEHP are aligned with the Responsible Business Alliance Code of Conduct (RBA COC) and reflect the fundamental values of fairness and integrity articulated in international conventions, national and local conventions, namely the International Labor Organization (ILO) Conventions, the International Bill of Human Rights and the United Nations Guiding Principles on Business and Human Rights (2011).

In addition, we align with the Automotive Guiding Principles to improve sustainability performance in the supply chain. Where national legislation directly conflicts with or does not fully comply with international human rights standards, Servicios de Frontera DEHP expects its Suppliers to respect internationally recognized human rights, such as those enshrined in the conventions mentioned above. Consistent with these commitments, Servicios de Frontera DEHP requires its Providers to acknowledge and adhere to this Code. Policies and procedures related to these standards are presented on the Servicios de Frontera DEHP corporate website.

Certainly, with the correction: The provisions of this Code are added to, and do not replace, the provisions of any legal agreement or contract between a Supplier and Servicios de Frontera DEHP or any of its affiliates. We expect Suppliers to require their supply chain, including subcontractors and third-party labor agencies, to comply with the same standards contained in this Code. This Code does not create any third-party rights or benefits for Suppliers, subcontractors, their respective employees, or any other party.

Servicios de Frontera DEHP reserves the right to update, alter, or change the requirements of its Supplier Code of Conduct, and Suppliers are required to accept such changes and act accordingly. Nothing contained in any documents issued by Suppliers shall be deemed to modify or amend any part of this Code.

  1. Compliance with legislation and customer requirements

Suppliers must maintain a process to identify, control, and understand the laws and regulations applicable to their respective businesses, as well as the specific requirements of Servicios de Frontera DEHP. The business activities of suppliers must comply with the laws and regulations of the jurisdictions in which they operate, transport, and distribute their products. Suppliers providing materials to Servicios de Frontera DEHP for use in the manufacture of products sold to the U.S. Government or its suppliers, or that are contained in such products, must comply with the applicable requirements established in the Federal Acquisition Regulation (FAR) and/or the Defense Federal Acquisition Regulation Supplement (DFARS). This provision applies to activities at the locations where suppliers' goods are produced, related services are provided, and where goods or services enter the supply chain. Suppliers, their employees, and any subcontractors shall not violate any laws, nor shall they instruct others to violate laws, on behalf of Servicios de Frontera DEHP. Additionally, the use of temporary, seconded, and subcontracted labor by suppliers shall be within the limits of local legislation and applicable international laws, as described in this policy.

  2. Human rights and labor

No forced labor.

No form of forced labor will be tolerated, including debt bondage, bonded labor, or involuntary prison labor, nor any involvement in human trafficking. This includes the transportation, harboring, recruitment, transfer, or receipt of individuals through threats, force, coercion, kidnapping, or fraud for the purpose of labor or services. Unreasonable restrictions on the freedom of movement of workers within facilities, as well as unreasonable restrictions on entry or exit from facilities provided by the company, will not be imposed. Suppliers must comply with the provisions of the California Transparency in Supply Chains Act of 2010, the UK Modern Slavery Act of 2015, and, where applicable, regulations established in FAR 52.222-50.

Child Labor.

Suppliers will not employ children below the minimum age for employment according to applicable regional law, and in any case, will not employ anyone under the age of 15. Suppliers shall ensure that persons under the age of 18 do not perform any offshore duties or undertake any hazardous work that could jeopardize their health or safety, including night shifts and overtime. “Child labor” means any work by a child or young person, unless it is considered acceptable under the ILO Minimum Age Convention 1973 (C138). Suppliers shall ensure proper management of student workers through effective maintenance of student records, rigorous due diligence of educational partners, and protection of students’ rights in accordance with applicable law and regulations. Suppliers shall provide appropriate support and training to all student workers. Unless otherwise permitted under local law, authority or regulation, the wage rate for student workers, interns and apprentices shall be at least the same wage rate as other entry-level workers performing equal or similar tasks.

Hiring Process.

As part of the hiring process, workers must be provided with a description of the terms of their employment in the language in which the candidate is fluent. In the case of migrant workers, this must be provided prior to the worker departing from his or her country of origin.

Voluntary Work.

All work must be voluntary, and workers shall be free to leave work at any time or terminate their employment. Employers and agents may not hold or otherwise destroy, conceal, confiscate or deny access by employees to their identity or immigration documents, such as government-issued identification, passports or work permits, unless such holdings are required by law. Workers shall not be required to pay employers’ or agents’ recruitment fees or other related fees for their employment. If any such fees are found to have been paid by workers, such fees shall be repaid to the worker. Employee privacy policy.

Working Hours.

Working hours, breaks, holidays and leave periods will be established in compliance with local laws and agreements, and in any case, a workweek should not be more than 60 hours per week, including overtime, except in emergency or unusual situations. Workers shall be allowed at least one day off every seven days.

Compensation 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. Deductions from wages as a disciplinary measure shall not be permitted. For each pay period, workers shall be provided with a timely and understandable wage statement that includes sufficient information to verify accurate compensation for work performed. All use of temporary, dispatch and outsourced labor will be within the limits of the local law. Imported and migrant workers are to be provided equal wages, benefits and working conditions.

Non-Discrimination.

Suppliers will ensure equal employment opportunity without discrimination or harassment on the basis of sex, race, age, color, disability, ethnic or national origin, sexual orientation, religion, social or marital status, or other status protected by applicable law.

Humane Treatment.

There shall be no harsh or inhumane treatment, including any sexual harassment, sexual abuse, corporal punishment, mental or physical coercion or abuse of workers; nor is there to be the threat of any such treatment.

Freedom of Association & Collective Bargaining.

In accordance with local law, Suppliers shall respect the right of all workers to form and join trade unions of their own choosing, to bargain collectively and to engage in peaceful assembly, as well as respect the right of workers to refrain from such activities. Workers and/or their representatives shall be able to openly communicate and share ideas and concerns with management regarding working conditions and management practices without fear of discrimination, reprisal, intimidation, or harassment.

3. Workplace Health and Safety

Suppliers will commit to providing a drug-free, safe and healthy workplace in accordance with applicable laws and regulations. Suppliers shall ensure that all workers receive communication and training on emergency planning and safe work practices. In addition, Suppliers shall have systems to prevent, detect and respond to potential risks to the safety, health and security of their respective workforces in the workplace. Such systems shall incorporate the general and applicable standards cited by the RBA COC, including:

1. Occupational Safety;
2. Emergency Preparedness;
3. Occupational Injury and Illness;
4. Industrial Hygiene;
5. Physically Demanding Work;
6. Machine Safeguarding;
7. Sanitation, Food and Housing;
8. Health and Safety Communication.

4. Responsibility for the Environment

Suppliers are required to identify the environmental impact of their activities, take active measures to minimize such impact throughout the life cycle of their products and services, acknowledge and commit to supporting Servicios de Frontera DEHP commitment to reducing carbon emissions and working towards carbon neutrality, and adhere to all applicable environmental laws and regulations of the countries where they source, manufacture, ship, or sell their products.

Suppliers must implement and maintain environmental management systems in accordance with ISO 14001 or an equivalent standard, and consistent with the RBA Code of Conduct. These management systems should address the following environmental aspects to the extent that they are relevant to their operations: (i) Environmental permits and regulatory reporting; (ii) Pollution prevention and resource reduction; (iii) Hazardous substances; (iv) Solid waste; (v) Atmospheric emissions; (vi) Material restrictions; (vii) Water management; and (viii) Energy consumption and greenhouse gas (GHG) emissions. To meet specific customer requirements, Servicios de Frontera DEHP may require certain suppliers to obtain and maintain third-party certification of their environmental management system as a condition for doing business with Servicios de Frontera DEHP.

Suppliers are encouraged to take active measures to reduce their Scope 1 and 2 greenhouse gas emissions, as defined in the Greenhouse Gas Protocol, through the use of renewable energy resources and recycled materials. Upon request, suppliers will provide Servicios de Frontera DEHP with documentation of their efforts to comply with these requirements, as well as information to support Servicios de Frontera DEHP's calculation of Scope 3 greenhouse gas emissions associated with their acquired goods and services.

Suppliers shall adhere to the relevant provisions of the International Plant Protection Convention (IPPC), specifically the International Standards for Phytosanitary Measures No. 15 (ISPM 15), and shall strive to comply with guidelines for environmentally responsible packaging that may be established by Servicios de Frontera DEHP and its customers.

5. Business Integrity

Suppliers must uphold the highest standards of integrity in all business transactions. All business dealings should be transparently performed and accurately reflected on the Supplier’s business books and records. Information regarding Supplier’s labor, health and safety, environmental practices, business activities, structure, financial situation and performance is to be disclosed in accordance with applicable regulations and prevailing industry practices. Falsification of records or misrepresentation of conditions or practices in the supply chain are unacceptable. Suppliers also shall understand and comply with all applicable fair business, advertising and competition laws including fair trading and competition laws in the jurisdictions in which they operate.

6. Conflicts of Interest

Suppliers will not take part in or seek to influence any decision in circumstances that could give rise to an actual or perceived conflict of interest. Such circumstances may be a business interest or a personal interest in the subject matter – economical or otherwise – directly or through someone closely related. If a Supplier becomes aware of a potential conflict of interest, it will notify Servicios de Frontera DEHP immediately (see Section 13).

7. Bribery, Kickback and Fraud

Suppliers must comply with all applicable local and international anti-corruption laws, including the U.S. Foreign Corrupt Practices Act and the UK Bribery Act. No supplier to Servicios de Frontera DEHP shall pay, lend, or deliver funds or assets as bribes, kickbacks, or other improper payments intended to influence or compromise the conduct of the recipient. Moreover, no employee of a supplier shall accept funds or other assets to assist in obtaining business or securing special concessions from Servicios de Frontera DEHP. Suppliers are prohibited from hiring third parties to perform actions that the suppliers are forbidden from doing directly as outlined in this Section 6. If a supplier becomes aware of a risk of bribery, kickbacks, or fraud, it must notify Servicios de Frontera DEHP immediately.

8. Material Content Reporting and Responsible Chemical Management

Suppliers will take necessary measures and provide Servicios de Frontera DEHP with required documentation to (i) ensure that the content of supplier material complies with customer, governmental, legal, and regulatory material content standards (i.e., WEEEi, RoHSii, ELViii, and REACHiv, POPsv, California Proposition 65vi, and TSCAvii) and (ii) assess the impact of the material on Servicios de Frontera DEHP's products. At a minimum, Suppliers will provide Material Content Declarations as required by REACH and RoHS annually and/or upon request for each and every part purchased by Servicios de Frontera DEHP. If requested, the Supplier will provide objective evidence of compliance with REACH and RoHS, which may include test results. Automotive sector Suppliers will input all material and substance data for components using the most current version of the International Material Data System (IMDS). Suppliers from all other sectors commit to providing material content data in the form requested by Servicios de Frontera DEHP. Suppliers will ensure that a trained and competent representative is available to input data into the IMDS or another system and to address any issues that may arise during the submission process.

9. Responsible Sourcing

Suppliers must have a policy that prohibits the sourcing of materials and services from places and entities that directly or indirectly finance or benefit serious human rights violations, contribute to armed conflicts, or violate human rights in Conflict-Affected and High-Risk Areas (CAHRAs), or are sanctioned by the U.S. Government. Servicios de Frontera DEHP requires its suppliers to take necessary measures to ensure that when certain raw materials, including tantalum, tin, tungsten, gold (3TG), and cobalt, are incorporated into products sold to Servicios de Frontera DEHP, they originate from mines and smelters audited by a qualified third party and comply with the standards of the Responsible Minerals Assurance Process (RMAP) or an equivalent recognized standard. Changes in the sourcing practices of Servicios de Frontera DEHP's products necessary to meet this requirement must be implemented by suppliers as soon as possible and in accordance with the relevant provisions of Servicios de Frontera DEHP's GSQM regarding change control, notification, and approval. Suppliers of parts or materials containing 3TG and/or cobalt will obtain reasonable written assurances from their suppliers that (i) the 3TG and cobalt in the products sold to Servicios de Frontera DEHP come from smelters that comply with the RMAP standard or another recognized third-party standard, and (ii) their suppliers do not directly or indirectly finance or benefit armed groups involved in serious human rights violations in the Democratic Republic of Congo (DRC) or a neighboring country, declared "DRC Conflict-Free" according to the Dodd-Frank Act, meeting the requirements outlined in the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from CAHRAs (Third Edition), and do not come from an entity sanctioned by the U.S. Government. Suppliers of these minerals or components containing these minerals will exercise due diligence in identifying the source and chain of custody of these minerals and will report their due diligence measures to Servicios de Frontera DEHP annually or as requested. The documentation of such assurance will include, at a minimum, the submission of an updated company-level Conflict Minerals Reporting Template (CMRT) and Cobalt Reporting Template (CRT) to Servicios de Frontera DEHP annually or upon request, using the most current versions of the templates, in accordance with the notification schedule established by Servicios de Frontera DEHP. Suppliers will promptly provide Servicios de Frontera DEHP with a CMRT or CRT at the product or user-defined level when requested. Servicios de Frontera DEHP reserves the right to demand responsible sourcing and transparency regarding minerals other than tantalum, tin, gold, tungsten, and cobalt. When requested, suppliers will promptly respond to Servicios de Frontera DEHP's request to complete and submit an annual Slavery and Human Trafficking Risk Template (STRT).

10. Privacy and Data Protection

Suppliers will maintain policies and internal procedures reasonably designed to protect data provided by Servicios de Frontera DEHP or obtained by the supplier on behalf of Servicios de Frontera DEHP, its affiliates, or its clients ("Servicios de Frontera DEHP Data"). Suppliers will comply with all applicable privacy, data protection, and information security laws, as well as regulatory and judicial requirements related to the collection, preservation, storage, processing, transmission, or disclosure of Servicios de Frontera DEHP Data, including, among others, the requirements outlined in FAR 52.204-21 and DFARS 252.204-7012. Suppliers will enter into appropriate data transfer agreements with Servicios de Frontera DEHP in any form that applicable law requires Servicios de Frontera DEHP or its clients to enter into with service providers or transmit to subcontractors.

11. Intellectual Property

Suppliers will implement and maintain security safeguards, including administrative, physical, and technical safeguards designed to protect their information systems from unauthorized access, and will promptly inform Servicios de Frontera DEHP if a Supplier believes that its systems have been compromised in a manner that could be harmful to Servicios de Frontera DEHP. Suppliers must use confidential information, data, business information, copyrights, and trademarks of Servicios de Frontera DEHP only in the manner allowed in their respective contracts with Servicios de Frontera DEHP and, at a minimum, protect such information with a reasonable degree of care. Suppliers shall not improperly appropriate or infringe upon the trade secrets, trademarks, or copyrighted works of third parties. Suppliers shall not misuse trade secrets or confidential information subject to third-party property rights, nor disclose such information to unauthorized third parties. Suppliers shall immediately notify Servicios de Frontera DEHP of any unauthorized use of data, trade secrets, trademarks, logos, or confidential information of Servicios de Frontera DEHP by the Supplier or a third party.

12. Compliance with Export Controls and Economic Sanctions

Suppliers will comply with applicable laws, regulations and restrictions on the export or re-export of goods, software, services and technology, as well as with applicable laws, regulations and restrictions on trade involving certain countries, regions, companies or entities and individuals.

13. Whistleblower Protection

Suppliers shall (i) maintain a whistleblower hotline or a similar process for their employees to report violations of this Code or any integrity-related issues concerning work for Servicios de Frontera DEHP, or (ii) allow their employees access to Servicios de Frontera DEHP's whistleblower hotline. Suppliers will maintain programs to ensure the confidentiality, anonymity, and protection of suppliers and employees reporting irregularities, unless prohibited by law. In any case, Suppliers have an affirmative obligation to promptly report to Servicios de Frontera DEHP any information or allegation they receive related to a violation of this Code. All reports to Servicios de Frontera DEHP should be directed to compliance@sdf-itc.com.

14. Contractor and Supplier Requirements

Beyond observing these requirements in their own operations, Suppliers shall ensure that their contractors, subcontractors, suppliers and their sub-suppliers respect the principles set forth in this Code.

15. Counterfeit Parts/Product Integrity

Suppliers are expected to minimize the risk of introducing counterfeit and/or diverted parts and materials into deliverable products and adhere to relevant technical regulations in the product creation process, including but not limited to DFARS 252.246-7007 and 84 FR 64680.

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 i DIRECTIVE 2012/19/EU of the European Parliament and of the Council of 4 July 2012 on Waste Electrical and Electronic Equipment (WEEE), 2021 O.J. (L 197) 38-71. 

ii Directive 2011/65/EU of the European Parliament and of the Council of 8 June 2011 on the Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment, 2011 O.J. (L 174) 88-110.

 iii Directive 2000/53/EC of the European Parliament and of the Council of 18 September 2000 on End-of-Life Vehicles, 2000 O.J. (L 269) 34-43.

 iv Regulation (EC) No 1907/2006 of the European Parliament and of the Council of 18 December 2006 Concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH), Establishing a European Chemicals Agency, Amending Directive 1999/45/EC and Repealing Council Regulation (EEC) No 793/93 and Commission Regulation (EC) No 1488/94 as well as Council Directive 76/769/EEC and Commission Directives 91/155/EEC, 93/67/EEC, 93/105/EC and 2000/21/EC, 2006 O.J. (L 396) 1–849. 

v Regulation (EU) 2019/1021 of the European Parliament and of the Council of 20 June 2019 on Persistent Organic Pollutants, 2019 O.J. (L 169) 45–77. 

vi Safe Drinking Water and Toxic Enforcement Act of 1986, Cal. Health & Safety Code §§ 25249.5 - 25249.14 (West 1986) 

VII Toxic Substances Control Act (TSCA) of 1979, 15 U.S.C. §2601 et seq. (2019).