Samsung Code of Conduct for Suppliers

1. BACKGROUND

   Samsung (“Samsung” means Samsung India Electronics Pvt. Ltd.) firmly believes in conducting its affairs with the highest level of integrity and fairness.  Samsung respects and strives hard to meet the objectives of commitments and social responsibility in all dealings with stakeholders, regulatory authorities and suppliers.

   It is Samsung’s intent to select and retain its partners and suppliers, their personnel, agents, representatives and subcontractors (collectively, “Samsung Suppliers”), who share and embrace the letter and spirit of Samsung commitment to integrity and fairness.  We recognize that Samsung Suppliers are independent entities; however, the conduct of Samsung Suppliers may impact and/or reflect upon Samsung. For this reason, Samsung expects that all Samsung Suppliers shall adhere to the Samsung Code of Conduct (“Code of Conduct”) while they are conducting business with and/or on behalf of Samsung.

   Samsung expects all its Suppliers to:

   1. Uphold and respect Samsung’s commitment to integrity, fair dealing and compliance with all local laws and practices; and
   2. Conduct their activities in accordance with this Code of Conduct and other lawful local business practices while conducting business with or on behalf Samsung,

   Samsung expects that all our Suppliers and their employees will adhere to and comply with following guidelines.

2. LEGAL AND REGULATORY COMPLIANCE PRACTICE

   All Samsung Suppliers and their employees shall conduct their business activities in full compliance with the applicable laws and regulations of their respective countries and in respect of their transactions while conducting business with and/or on behalf of Samsung including but not limited to:

   1. Comply with all applicable trade control and applicable laws as well as all export, re-export and import requirements.
   2. Comply with all applicable environmental laws and regulations regarding hazardous materials air emissions, waste and wastewater discharges, including the manufacture, transportation, storage disposal, and release to the environment of such materials. Supplier shall identify and assess potential emergency situations. For each situation, Supplier shall develop and implement emergency plans and response procedures that minimize harm to life, environment, and property.
   3. Comply with the anti-corruption laws of the countries in which they do business and not make any direct or indirect payments or promises of payments, bribe, kickback, any incentive or gifts to anyone (including Samsung personnel or any officials) for the purpose of inducing the individuals to misuse his/her position.
   4. Be honest, and fair in discussions with regulatory agency representatives and government officials and in all of their business transactions.
   5. Comply, with all  applicable rules, laws or ordinances (including but not limited to, the applicable laws governing consumer protection, unlawful trade practices, fair trading, anti-competition, Information Technology Act 2000, Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011.
3. BUSINESS PRACTICES

   All Samsung Suppliers and their employees shall conduct their business interactions and activities with integrity and in accordance with their obligations under agreements with the Samsung.  It is essential that all Samsung Suppliers and their employees understand and uphold the requirements of the Samsung for acceptable business conduct while doing business with or on behalf of Samsung.  In addition to any specific obligations under each agreement(s) with the Samsung, all Samsung Suppliers and their employees shall, without limitation:

   1. Honestly and accurately record and report all business information.
   2. Create and maintain all business records in full compliance with applicable legal and regulatory requirements and make those available to Samsung for compliance check purpose.
   3. Protect and comply with the intellectual property ownership rights of Samsung and others, including but not limited to copy rights, patents, trademarks and trade secrets.
   4. Conduct business in a professional manner at all times while on Samsung’s and/or its customer’s property or while conducting business.
   5. Refrain from offering, giving or providing directly or indirectly, gifts unless such gifts and/or entertainment (i) have nominal economic value, and (ii) carry an advertising message directly related to promotion of Suppliers products.  In no event shall Suppliers or its Representatives offer a bribe, kickback, or any other incentive to a Samsung employee.
   6. Shall not knowingly deal with Samsung where actual or likely clash of interests may arise.
   7. Comply with the applicable policies of Samsung to the extent expected as a part of its dealings with or through Samsung (including but not limited to confidentiality obligations)
   8. Shall not take unfair advantage of anyone through manipulation, concealment, abuse of confidential, proprietary or trade secret information, misrepresentation of material facts, or any other unfair dealing-practices.
   9. Shall not engage in conduct that could reasonably give rise to an appearance of impropriety or cause reputational damage to Samsung or its interests.
   10. Supplier shall identify company representatives responsible for ensuring implementation and periodic review of its management systems. Supplier shall have a Corporate Social Responsibility (CSR) or Sustainability representative that reports directly to executive management and has the responsibility and authority to manage social and environmental compliance requirements for the business.
4. EMPLOYMENT PRACTICES

   Samsung expects Samsung Suppliers to share their commitment to diversity, equal employment opportunity, and a safe and harassment-free workplace.  Samsung’s Suppliers and their employees shall conduct their employment practices in full compliance with all applicable laws and regulations.  In addition to any specific obligations under agreement with Samsung, all Samsung Suppliers and their employees shall, without limitation.

   1. Conduct their employment practices in full compliance with all applicable laws and regulations.
   2. Co-operate with Samsung’s commitment to a workforce free of harassment and unlawful discrimination and provide appropriate treatment to women workers.
   3. Provide a safe and healthy work environment and fully comply with all applicable safety and health regulations and practices. Supplier shall identify, evaluate, and manage occupational health and safety hazards through a prioritized process of hazard elimination, engineering controls, and/or administrative controls. Supplier shall provide its workers with job-related, appropriately maintained personal protective equipment and instruction on its proper use. Supplier personnel shall have the right to refuse unsafe work and to report unhealthy working conditions. Supplier shall have a system for workers to report health and safety incidents and near-misses, as well as a system to investigate, track, and manage such reports. Supplier shall implement corrective action plans to mitigate risks, provide necessary medical treatment, and facilitate personnel return to work. Supplier shall identify and assess potential emergency situations. For each situation, Supplier shall develop and implement emergency plans and response procedures that minimize harm to life, environment, and property.
   4. Use only voluntary labor. The use of forced labor whether in the form of indentured labor, bonded labor or prison labor by Samsung Suppliers or its subcontractors is unacceptable.  Comply with all minimum wage laws and requirements and to employ child labor.
   5. Comply with all applicable laws and policies governing compensation and working hours.  In those countries where there is no applicable standard, overtime shall be paid at their own cost, at a minimum, at the rate equal to the employee’s regular wages.
   6. No person is employed who is below the minimum legal age for employment. Children are not employed for any hazardous work, or work that is inconsistent with the child’s personal development
5. COMPLIANCE WITH CODE OF CONDUCT

   It is the responsibility of the Samsung Suppliers to ensure that its representatives understand and comply with the Samsung Code of Conduct and to inform Samsung immediately if and when any situation develops that requires the Suppliers to operate in violation of the code set forth in this document.  Suppliers and their employees are expected to self-monitor their compliance with this Code of Conduct.  Failure to read and/or acknowledge the Code of Conduct does not exempt Suppliers and their employees of their responsibility to comply with the Code of Conduct, applicable laws and regulations.

    

   This is to acknowledge that we have received a copy of the Samsung Code of Conduct for Suppliers and understand that it contains important information about Samsung’s general business practices and ethics and we understand that this pertains to specifically our obligations as a Supplier. We have read the Code of Conduct and understand that we are governed by its contents.