Supplier Code of Conduct
Introduction
Precision Technologies is committed to conducting business with the highest ethical, environmental, and social standards. This Supplier Code of Conduct outlines expectations for all suppliers and partners, ensuring alignment with our ESG commitments.
This Code supports the policies defined in our ESG Compliance Framework and is reinforced by specific ESG Compliance Addendums. Suppliers are expected to understand, acknowledge, and adhere to all applicable requirements.
Human Rights and Supplier Expectations
Labor and Fair Treatment
- Prohibit all forms of forced labor, bonded labor, prison labor, and child labor
- Ensure dignity, respect, and a workplace free of harassment or discrimination
- Respect freedom of association and collective bargaining rights
- Protect against retaliation for raising concerns in good faith
Wages and Benefits
- Meet or exceed legal minimum wage requirements
- Provide legally mandated benefits
- Ensure transparent and lawful wage deductions
- Deliver clear and accurate wage statements
Working Conditions and Health & Safety
- Maintain safe, healthy, and sanitary workplaces
- Identify and manage occupational risks
- Provide proper safety equipment and training
- Implement emergency protocols and continuous improvement systems
Environmental Responsibility
- Comply with all environmental laws and regulations
- Reduce waste, pollution, and environmental impact
- Support sustainability initiatives including resource efficiency and emissions tracking
This Code reflects our commitment to responsible, ethical, and sustainable business practices
across our entire supply chain
Anti-Bribery and Corruption
- Prohibit bribery, corruption, extortion, and embezzlement
- Comply with global anti-corruption laws including FCPA and UK Bribery Act
- Maintain accurate and transparent records
- Avoid conflicts of interest
Anti-Counterfeiting Measures
Product Integrity
- Prevent use of counterfeit components
- Maintain traceability of materials
- Support quality investigations and verification processes
Responsible Sourcing
Conflict Minerals and Transparency
Suppliers must ensure materials do not contribute to conflict, human rights abuses, or illegal practices.
- Conduct country-of-origin inquiries for 3TG materials
- Avoid unethical sourcing from harmful operations
- Extend sourcing standards to sub-tier suppliers
- Maintain documentation such as CMRTs and sourcing records
Grievance Mechanism and Oversight
- Provide safe and anonymous reporting channels
- Ensure non-retaliation
- Cooperate in investigations when necessary
Import / Export and Trade Compliance
- Follow all applicable trade laws, sanctions, and regulations
- Maintain accurate documentation and classifications
- Report involvement of restricted parties or materials
Recruitment and Employment Practices
- Do not charge recruitment or placement fees
- Cover all recruitment-related costs
- Ensure third-party recruiters comply
- Clearly communicate policies during hiring
ESG Expectations and Flow-Down
- Apply ESG standards to sub-tier suppliers
- Include Code acknowledgment in contracts
- Maintain compliance documentation
- Participate in assessments when required
Fair Competition, IP, and Data Privacy
- Comply with antitrust and competition laws
- Protect confidential and proprietary information
- Respect intellectual property rights
- Safeguard personal and sensitive data
ESG Addendum Compliance
This Code is supported by the following addendums:
- Addendum A. Human Rights and Supplier Expectations
- Addendum B. Responsible Sourcing
- Addendum C. ESG Expectations and Flow-Down
- Addendum D. Fair Competition, IP, and Data Privacy
- Addendum K. Anti-Bribery and Corruption
- Addendum L. Anti-Counterfeiting
- Addendum M. Trade Compliance
- Addendum N. Grievance and Oversight
Full versions are available upon request.
Reporting Concerns
Suppliers may report concerns through:
- Phone: 978-649-8715
- Mail: Precision Technologies 42 Westech Drive, Tyngsboro, MA 01879
- Attention: General Counsel
Confidential submissions should be labeled:
“To be opened by General Counsel only – submitted pursuant to Supplier Code of Conduct”
Anonymous reporting is permitted.
Acknowledgment and Certification
By conducting business with Precision Technologies, suppliers agree to comply with this Code and all ESG Addendums. Non-compliance may result in corrective action or termination.
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