Supplier Code of Conduct

At PCH International, our core values are passion, integrity and teamwork. Our purpose is Developing Partnerships Delivering Peace of Mind and these values stand at the core of every decision we make for the company. We expect all of our business partners and suppliers to operate on the same principles.

PCH designs, creates and delivers products for the world's leading brands. At every step in the supply chain and associated processes, we not only comply with legal requirements, we ensure that our values and purpose are strictly adhered to and we expect our partners to behave likewise. Wherever we operate around the world we are guided by this Code of Conduct and we bind our contactors to these principles.

Labor and Human Rights

Suppliers are committed to uphold the human rights of workers, and to treat them with dignity and respect as understood by the international community. Recognized standards such as the Universal Declaration of Human Rights (UDHR), Social Accountability International (SAI) and the Ethical Trading Initiative (ETI) were used as references in preparing the Code and may be a useful source of additional information. The labor standards are:

1. Freely Chosen Employment
Forced bonded or indentured labor or involuntary prison labor is not to be used. All work will 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.

2. Child Labor
Child labor is not to be used in any stage of manufacturing. The term "child" refers to any person employed under the age of 16 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.

3. Working Hours
Workweeks are not to exceed the maximum set by local law. Further, 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 per seven-day week.

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. In compliance with local laws, workers shall be compensated for overtime at pay rates greater than regular hourly rates. Deductions from wages as a disciplinary measure shall not be permitted. The basis on which workers are being paid is to be provided in a timely manner via pay stub or similar documentation.

5. Humane Treatment
There is to 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.

6. Non-Discrimination
Participants should be committed to a workforce free of harassment and unlawful discrimination. Companies shall not engage in discrimination based on race, color, age, gender, sexual orientation, ethnicity, disability, pregnancy, religion, political affiliation, union membership or marital status in hiring and 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.

7. Freedom of Association
Open communication and direct engagement between workers and management are the most effective ways to resolve workplace and compensation issues. Participants are to respect the rights of workers as established by local law to associate freely on a voluntary basis, seek representation, join or be represented by Works Councils, and join or not join labor unions and bargain collectively as they choose. As provided by law, employees who become worker representatives shall not be the subject of discrimination and shall have access to management and co-workers in order to carry out their representative functions. Workers shall be able to communicate openly with management regarding working conditions without fear of reprisal, intimidation or harassment.

Health and Safety

Suppliers recognize that the quality of products and services, consistency of production and workers' morale are enhanced by a safe and healthy work environment. Recognized management systems such as OHSAS 18001 and ILO Guidelines on Occupational Safety and Health were used as references in preparing the Code and may be a useful source of additional information. The health and safety standards are:

1. Occupational Safety
Worker exposure to potential safety hazards (e.g., electrical and other energy sources, fire, vehicle, and fall hazards) are to be controlled through proper design engineering and administrative controls, preventative maintenance and safe work procedures (including lockout/tagout). Where hazards cannot be adequately controlled by these means, workers are to be provided with appropriate personal protective equipment. Workers shall not be disciplined for raising safety concerns.

2. Emergency Preparedness
Emergency situations and events are to be identified and assessed, and their impact minimized by implementing emergency plans and response procedures, including: emergency reporting, employee notification and evacuation procedures, worker training and drills, appropriate fire detection and suppression equipment, adequate exit facilities and recovery plans.

3. Occupational Injury and Illness
Procedures and systems are to be in place to manage, track and report occupational injury and illness, including provisions to: a) encourage worker reporting; b) classify and record injury and illness cases; c) provide necessary medical treatment; d) investigate cases and implement corrective actions to eliminate their causes; and d) facilitate return of workers to work.

4. Industrial Hygiene
Worker exposure to chemical, biological and physical agents is to be identified, evaluated, and controlled. When hazards cannot be adequately controlled by engineering and administrative means, workers are to be provided with appropriate personal protective equipment.

5. Physically Demanding Work
Worker exposure to physically demanding tasks, including manual material handling and heavy lifting, prolonged standing and highly repetitive or forceful assembly tasks is to be identified, evaluated and controlled.

6. Machine Safeguarding
Physical guards, interlocks and barriers are to be provided and properly maintained for machinery used by workers.

7. Dormitory and Canteen
Workers are to be provided with clean toilet facilities, access to potable water and sanitary food preparation and storage facilities. Worker dormitories provided by the Participant or a labor agent are to be clean, safe, and provide emergency egress, adequate heat and ventilation and reasonable personal space.

Environmental

Suppliers recognize that environmental responsibility is integral to producing world class products. In manufacturing operations, adverse effects on the environment and natural resources are to be minimized while safeguarding the health and safety of the public. Recognized management systems such as ISO 14001 and the Eco Management and Audit System (EMAS) were used as references in preparing the Code and may be a useful source of additional information. The environmental standards are:

1. Environmental Permits and Reporting
All required environmental permits (e.g. discharge monitoring) and registrations are to be obtained, maintained and kept current and their operational and reporting requirements are to be followed.

2. 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. Hazardous Substances
Chemical and other materials posing a hazard if released to the environment are to be identified and managed to ensure their safe handling, movement, storage, recycling or reuse and disposal.

4. Wastewater and Solid Waste
Wastewater and solid waste generated from operations, industrial processes and sanitation facilities are to be monitored, controlled and treated as required prior to discharge or disposal.

5. 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.

6. Product Content Restrictions
Participants are to adhere to all applicable laws and regulations regarding prohibition or restriction of specific substances including labeling laws and regulations for recycling and disposal. Participants are also to adhere to processes to comply with each agreed-upon customer-specific restricted and hazardous materials list.

Management System

Suppliers shall adopt or establish a management system whose scope is related to the content of this Code. The management system shall be designed to ensure (a) compliance with applicable laws, regulations and customer requirements related to the Suppliers' operations and products; (b) conformance with this Code; and (c) identification and mitigation of operational risks related to this Code. It should also facilitate continual improvement. The management system should contain the following elements:

1. Company Commitment
Corporate social and environmental responsibility statements affirming Participant's commitment to compliance and continual improvement

2. Management Accountability and Responsibility
Clearly identified company representative[s] responsible for ensuring implementation and periodic review of the status of the management systems

3. Legal and Customer Requirements
Identification, monitoring and understanding of applicable laws, regulations and customer requirements

4. Risk Assessment and Risk Management
Process to identify the environmental, health and safety1 and labor practice risks associated with Supplier's operations. Determination of the relative significance for each risk and implementation of appropriate procedural and physical controls to ensure regulatory compliance to control the identified risks

5. Performance Objectives with Implementation Plan and Measures
Written standards, performance objectives, targets and implementation plans including a periodic assessment of Participant's performance against those objectives.

6. Training
Programs for training managers and workers to implement Participant's policies, procedures and improvement objectives

7. Communication
Process for communicating clear and accurate information about Participant's performance, practices and expectations to workers, suppliers and customers

9. Audits and Assessments
Periodic self-evaluations to ensure conformity to legal and regulatory requirements, the content of the Code and customer contractual requirements related to social and environmental responsibility.

10. Corrective Action Process
Process for timely correction of deficiencies identified by internal or external assessments, inspections, investigations and reviews

11. Documentation and Records
Creation of documents and records to ensure regulatory compliance and conformity to company requirements along with appropriate confidentiality to protect privacy

Ethics

To meet social responsibilities and to achieve success in the marketplace, Suppliers are to uphold the highest standards of ethics including:

1. No Corruption, Extortion, or Embezzlement
The highest standards of integrity are to be expected in all business interactions. Any and all forms of corruption, extortion and embezzlement are strictly prohibited resulting in immediate termination and legal actions

2. Disclosure of Information
Information regarding business activities, structure, financial situation and performance is to be disclosed in accordance with applicable regulations and prevailing industry practices.

3. No Improper Advantage
Bribes or other means of obtaining undue or improper advantage are not to be offered or accepted.

4. Fair Business, Advertising and Competition
Standards of fair business, advertising and competition are to be upheld. Means to safeguard customer information should be available.

5. Whistleblowers
Programs that ensure the protection of supplier and employee whistleblower confidentiality are to be maintained.

6. Community Engagement
Community engagement is encouraged to help foster social and economic development.

7. Protection of Intellectual Property
Intellectual property rights are to be respected; transfer of technology and know-how is to be done in a manner that protects intellectual property rights.

8. Prevention of Conflict metal
Supplier shall not procure or use Conflict Metal. Conflict Metal refers to raw metals used in electronics industry which are sourced from regions of the world known as "conflict regions" such as Eastern region of the Democratic Republic of Congo (DRC). The DRC Eastern region mines are controlled by non-government military groups or unlawful military factions where illegal mine(s) profits have contributed to human rights abuses, severe environmental damage, and the theft from the DRC citizens.

References: The following standards were used in preparing this Code and may be a useful source of additional information.
ILO Code of Practice in Safety and Health
ILO International Labor Standards
OECD Guidelines for Multinational Enterprises
United Nations Convention Against Corruption
United Nations Global Compact
Universal Declaration of Human Rights
Electronic Industry Code of Conduct
SA 8000
SAI
Ethical Trading Initiative
OHSAS 18001
ISO 14001