Code of Conduct for Business Partners
CIN's good name and reputation are the result of many years’ dedication and hard work.
CIN has a responsibility to maintain and improve this reputation, so its objective is not only to comply with the laws, rules and regulations applicable to its business, but also to work towards meeting the highest standards of business conduct.
Its main aim is to be an international benchmark in the sectors in which it operates, aligned with the best market practices in productivity, remaining permanently innovative, forming a strong identity, recognised in technical skill through the provision of an excellent service to its customers and to the community.
But CIN also believes in responsible and ethical social behaviour, assuming its responsibility for all its stakeholders in the various countries where it operates. It therefore runs its business directly, clearly and ethically, taking responsibility for what it says and does and striving to create a challenging and motivational environment that rewards teamwork and respects and recognises different ways of working, as well as lifestyle and cultural differences.
The essential values of honesty, truth, loyalty, rectitude and justice in everyone's daily conduct, combined with training, innovation and integrity, are its main guidelines in all its actions and decisions.
This Code of Conduct for Business Partners provides a general presentation of CIN's core business values, which are based on its business ethics and commitment to integrity, applicable in combination with general laws and regulations. CIN requires its Business Partners, to adopt this as they also have an obligation to observe the highest standards of integrity and fair business practices in their business relationships.
CIN's Code of Conduct for Business Partners applies to everyone who buys or provides products or services from/to CIN Group companies or who are recruited or instructed to act on their behalf, such as customers, suppliers (and subcontractors, if used as part of the relationship with CIN), consultants, distributors, agents and other representatives.
CIN requires that all its Business Partners act in accordance with the principles of this Code of Conduct for Business Partners and in accordance with all applicable legislation and general regulations.
CIN will select its suppliers and service providers independently and objectively, based on market conditions, service quality and cost criteria, and on their social and ethical behaviour.
CIN will negotiate on the basis of good faith and honour in its commitments under contractual obligations.
Accordingly, measures will be taken to ensure that CIN only maintains business relationships with companies and individuals that are aware of this Code and agree to comply with its compliance and integrity standards.
Those who engage in illegal conduct will be barred from business relationships and assistance, and any violations of this code must be reported to CIN on the form in Appendix I, attached.
The Code of Conduct for Business Partners does not replace local legislation and, if there is conflict between the two, the legislation will take precedence. However, if the Code of Conduct for Business Partners imposes a higher standard than existing legislation, the reverse applies.
The form in Appendix II, attached, must be used by CIN's Stakeholders to sign up to its Code of Conduct for Business Partners.
Failure to comply with the terms of this Code of Conduct for Business Partners by any Stakeholder required to fulfil it, or failure by CIN itself to comply, may be reported by any interested party, using form in Appendix I.
APPLICATION AND FOLLOW-UP
CIN will monitor the implementation of this Code of Conduct for Business Partners as well as its Business Partners’ adherence to it.
To this end, CIN will carry out a Compliance assessment of its Business Partners with regard to the provisions of this Code of Conduct.
Any violations of this Code of Conduct for Business Partners will be addressed immediately and may jeopardise the Business Partner's commercial relationship with CIN, which may result in contract termination.
CIN observes the laws and regulations of the countries in which it operates and requires its Business Partners to do likewise.
CIN does not tolerate corruption, including, but not limited to, bribery, conflicts of interest, fraud, extortion, misappropriation, illicit enrichment and gratuities.
With regard to Anti-Corruption and Bribery, Prevention of Money-Laundering and Terrorism Financing rules, the CIN Group is bound by national and international legislation, and requires that its Business Partners not to engage, or cause CIN to engage in, such actions.
Fair competition and antitrust laws
CIN's Business Partners will comply with the legislation and regulations applicable to combating unfair competition and antitrust.
This means, in particular, not engaging in price-fixing, market sharing, fraudulent bidding or customer allocation.
CIN does not accept any form of bribery or facilitation of payments and requires its Business Partners to act in the same manner.
CIN's Business Partners will comply with the legislation and regulations applicable to privacy and data protection.
Conflicts of Interest:
Conflicts of interest between a Business Partner and CIN must be avoided.
Conflicts of interest may include outside business activities, personal financial interest, inside information, offers of employment, doing business with family members and close friends.
In addition, CIN expects commercial interactions with its Business Partners to include the protection of all confidential information provided by CIN and respect for its intellectual property rights and those of third parties.
Export control regulation
Compliance with all the directly or indirectly applicable export control regulations is essential for CIN, and it therefore requires the same commitment of its Business Partners, as this type of regulation is often intended to limit activities that CIN does not support, such as terrorism.
HUMAN AND LABOUR RIGHTS
CIN recognises human rights in all the cultural, socioeconomic and geographical contexts where it operates, respecting the respective traditions and cultures and promoting support for local communities in accordance with the specific interests of each region.
Its action is based on the principles of respect and dignified treatment of each individual in its recruitment and selection processes, in their professional development and performance evaluation.
The same recognition and respect will be demanded of CIN's Business Partners.
CIN recognises the right of children to be protected from economic exploitation and from work that may damage their physical or mental health, that is harmful to their moral or social development or that interferes with their education.
A child in this context is a person under the age of 15, or 14 under the exceptions for developing countries as provided for in Article 2.4 of ILO Convention No. 138 on the minimum age.
If the national legislation of a country imposes a higher age, the local legislation applies.
Some countries apply the definition of “apprentice” to people above the minimum age but under 18, which means that there may be legal restrictions on the types of work they can perform.
CIN does not tolerate child labour and expects the same of its Business Partners.
However, CIN recognises that child labour exists and knows that it is not possible to eradicate it simply by imposing rules or supervision. Therefore, CIN understands that, if child labour is detected, the employer must seek a satisfactory solution that improves the general situation of the child, considering, when making the decision, the age, social class and situation of the child, and requiring such behaviour from its Business Partners.
Mandatory or forced labour
CIN neither employs nor accepts any form of compulsory or forced labour, nor slave labour or workers in an irregular situation, and expects the same of its Business Partners.
CIN recognises that some ways of forcing people to work may include withholding payments, documentation or other belongings, practices which are all prohibited and rejected by CIN.
If Business Partners employ foreign workers, they must do so under a contract, and foreign workers must not be obliged to remain in the employment relationship against their will and must have the same rights as local workers.
All workers will have the right to leave the workplace and accommodation freely (if provided) when they are not working.
Freedom of association and collective bargaining
CIN expects its Business Partners to respect the rights of its employees, who are free to create or join any association, and to negotiate collectively and individually in accordance with the legislation and regulations in force.
No employee must be at risk of having their rights violated or suffering retaliation for exercising or claiming them.
Employment contracts, hours of work and rest
CIN expects its Business Partners to comply with local laws and regulations regarding employment contracts, working hours of employees, including overtime and payment of overtime, rest and remuneration.
Wages must be paid regularly, in accordance with applicable local legislation and the relevant market situation.
CIN is aware that ensuring a good work-life balance for its employees ensures that its human capital is more effective and efficient.
Accordingly, based on the legal right of all Employees to disconnect and in order to protect their right to rest, CIN recognises the right of workers to take the public holidays and weekly rest days set by law, as well as legal vacation leave, and other forms of permitted leave, without this having any negative repercussions on their professional life.
Discrimination, harassment and diversity
CIN values and promotes diversity and gender balance.
CIN expects its Business Partners to provide a work environment where all workers are treated with respect and dignity and have equal opportunities for their professional development.
CIN does not tolerate any form of discrimination or harassment in the workplace, and expects its Business Partners not to discriminate against their workers based on race, ethnicity, sexual orientation, gender, religion, age, disability, political opinion, nationality or any other potential discriminatory factor.
Abuse of alcohol and/or narcotics and mind-altering substances
CIN works proactively to eliminate all risks in the workplace.
Thus, all Employees who are under the influence of alcohol, narcotics or mind-altering substances such that their ability to perform their tasks is compromised will be forced to leave their workplace and company premises.
CIN maintains a zero-tolerance policy with regard to such situations and expects its Business Partners to comply with the same principles.
CIN requires compliance with all legal quality, health, hygiene and safety requirements that apply to its products and services, and expects its Business Partners to apply this principle when supplying or producing goods or providing services to or on behalf of CIN.
Responsibility for obtaining minerals
CIN is committed to complying with legislation and regulations related to the obligation to disclose the use of minerals from conflict zones.
Conflict minerals are minerals from high-risk and conflict-affected areas that have directly or indirectly contributed to the financing of armed groups where such groups are suspected of being responsible for serious human rights violations.
Goods provided to CIN will comply with legislation and regulations relating to conflict minerals.
Environment and sustainability
CIN is committed to complying with the legislation and regulations relating to the environmental requirements applicable in its area of activity and expects that all its Business Partners obtain, update and comply with all the necessary environmental licenses and authorisations for their operations.
CIN encourages the development and dissemination of environmentally correct and sustainable technologies and recommends that all its Business Partners whose activity has a significant environmental impact implement certified or certifiable environmental management systems that facilitate their work in relation to the environment.
CIN seeks to reduce resource consumption and improve the environmental impact of its activity and expects that its Business Partners will do likewise, particularly with regard to water and energy consumption and waste production, by avoiding pollution, reducing noise from their activities to acceptable levels and improving the overall environmental impact of their products and activities throughout the value chain. In addition, chemicals and hazardous materials must be properly labelled and safely stored and recycled, reused and disposed of correctly.
Health and safety
CIN is committed to providing a safe working environment for its Employees, and it therefore works routinely with health and safety bodies to identify, assess and reduce risks in the workplace that may cause accidents or harm health and well-being, by implementing appropriate health and safety audit and monitoring processes.
For CIN, a safe work environment means that the work areas must be clean, tidy and free of pollution, with adequate lighting, temperature and noise; all equipment and machines used must be safe, not putting the health and safety of workers at risk; and that the work and personal protection equipment (PPE) provided must be used rigorously, in accordance with the instructions for use. All production units will be equipped with adequate and clean changing rooms, with showers and washbasins of a high hygienic standard.
CIN expects its Business Partners to adopt the same commitment to the work environment of its employees.
Safety of buildings
All hazardous materials and equipment must be stored in safe locations and must strictly comply with all applicable legislation.
There must be an Internal Safety Plan for Buildings identifying all safety systems, location of fire extinguishers, existence and location of first aid equipment. Emergency exits must be clearly marked and free of obstacles and permanently well illuminated, evacuation plan, which must be displayed on all floors of each building, on which training must be given to all workers.
First aid equipment must be available at the appropriate locations and at least one person at each location must receive basic first aid training.
The fire alarm must be tested and fire drills must be carried out regularly.
Appendix I: Non-compliance report