TIER’S SUPPLIER CODE OF CONDUCT

Our principles

At TIER we are committed to the highest standards of labour, human rights, environmental and ethical conduct. To ensure that these standards are not only met within the organisation, but wherever our activities have an impact, we actively work with our business partners along the entire value chain to further develop their sustainability performance.

As part of these efforts we expect all our suppliers to adhere to our Supplier Code of Conduct, which is based on the ten principles of the UN Global Compact and derived from the Universal Declaration of Human Rights, the International Labour Organisation's Declaration on Fundamental Principles and Rights at Work, the Rio Declaration on Environment and Development, and the United Nations Convention against Corruption.

Code Implementation

At TIER, we want to ensure compliance with our Code of Conduct throughout our entire value chain. To this end, we closely collaborate with our suppliers, and reserve the right to verify compliance with the Code, as well as the information provided to us by our suppliers, through assessments and audits. To ensure compliance at the lower tiers of our value chain, all our direct suppliers are responsible for ensuring that this Code is adhered to by all of their direct suppliers, vendors, agents and subcontractors.

In case there are indications that a Supplier does not comply with this Code of Conduct, we shall work with that Supplier to agree on a corrective action plan with a reasonable timeline that enables the Supplier to reach full compliance with the Code of Conduct. If a Supplier has intentionally provided false or falsified information or cannot implement the required improvements, we reserve the right to terminate our business relationship, in which case the Supplier shall not be entitled to compensation. All costs arising from the Supplier's compliance with this Code of Conduct shall be borne solely by the Supplier. The Code may be revised by TIER with due notice to Suppliers.

In this Code of Conduct, references to:

• Export Control Laws are to all export control laws and regulations in Relevant States;
• Relevant States include the countries of the European Union, the United States of America and any other countries with jurisdiction over TIER;
• Restricted Party List are those lists published by the Relevant States of individuals or companies who have breached or are of concern in relation to Sanctions;
• Restricted List States are to such countries as from time to time appear on restricted lists published by the Relevant States;
• Sanctions are to all economic, trade and financial sanctions laws, regulations, embargoes or restrictive measures of any Relevant States; and
• Supplier shall, where relevant, also include all officers and employees of the Supplier.
  
  

Human and labour rights

At TIER we are committed to upholding the highest standards of human and labour rights and want to ensure that all workers in our supply chain have a fair and ethical workplace. Suppliers should have in place a policy recognising, respecting and protecting the human rights of their employees, those of their own suppliers and business partners and the communities affected by their operations.

• Fair terms of employment. All workers should be provided with simple, written contracts which must detail the terms and conditions of their employment. Work carried out should be on the basis of the applicable local recognised employment law and practice.
• Working hours. Working hours for all workers should not be excessive and must comply with relevant national laws. Overtime should be voluntary. TIER supports the requirements of the International Labour Organisation (ILO) and we encourage our suppliers to adhere to and respect the relevant ILO standards on working time.
• Anti-discrimination. Suppliers must seek to eliminate discrimination in access to employment, training and working conditions, on grounds of age, disability, ethnicity, gender, marital status, national origin, political affiliation, race, religion, sexual orientation, gender identity, union membership, or any other status protected by applicable national or local law and to promote equality of opportunity and treatment.
• Fair compensation. Wages and benefits should meet national standards or collective labour agreements, where applicable. Workers should be provided with clear written information on their pay and conditions and excessive deductions on wages should not be permitted as a disciplinary measure. All use of temporary and outsourced labour shall be within the limits of the local law. In case suppliers are using any third-party employment agencies they are to ensure that these are compliant with the provisions of this Code and the law.
• Prevention of forced labour and human trafficking. Suppliers shall comply with all applicable anti-slavery and human trafficking laws. Suppliers must ensure they have taken steps to ensure that their business operations do not make use of any form of force, bonded, involuntary labour and are free from any kind of slavery and human trafficking practices, both internally and within their supply chains and other external business relationships.
• Prevention of underage labour. Suppliers shall not employ workers under 15 years of age, the applicable minimum legal age for employment, or the applicable age for completion of compulsory education, whichever is highest.
• Protection of juvenile workers. Suppliers should observe the provisions of the UN International Labour Organisation such that any young persons under the age of 18 should not be employed to work at night or for any hazardous work and their employment should not harm the young person’s education, health or physical, mental, moral or social development.
• Grievance mechanisms. Suppliers must establish effective grievance reporting mechanisms that allow for open communication on grievances and facilitate the exchange between management and workers without jeopardising the worker's employment.

Health and safety

TIER places a high priority on ensuring a safe and healthy work environment for all workers in the supply chain. Our Suppliers must create and maintain a safe work environment and incorporate sound health and safety management practices into their business, as well as give their workers the right to refuse unsafe work and report unhealthy working conditions.

• Working environment. A healthy and safe working environment should be provided for all employees and visitors in accordance with applicable international standards and national laws.
• Occupational health and safety management. Suppliers shall identify, evaluate and eliminate potential occupational health and safety hazards through a prioritised management process of hazard elimination, substitution, engineering controls, administrative controls and/or personal protective equipment. Adequate policies and management procedures relating to health and safety should be in place, which are either provided to, or accessible by employees.
• Health and safety training. Suppliers shall provide appropriate training on workplace health and safety to their employees.

Environment

TIER is committed to protecting the environment and promoting environmental responsibility together with our business partners. We expect our Suppliers to develop, implement and maintain environmentally friendly business practices to minimise the negative impact on the environment and natural resources.

• Environmental Impact. Suppliers must continuously strive to identify and reduce negative impacts of their operations on the environment.
• Environmental regulations and permits. Suppliers shall comply with all applicable local and national laws and regulations relating to the protection of the environment and shall further obtain and comply with all required environmental permits.
• Resource management. Suppliers shall quantify, set targets, monitor progress, and reduce their consumption of fossil fuels, water, and other manufacturing and/or office materials wherever possible. In order to reduce their consumption of virgin materials and close resource loops, Suppliers shall also aim to increase the proportion of recycled and recyclable materials in the manufacturing of their products.
• Greenhouse Gas Emissions management. Suppliers shall quantify and reduce their emissions of greenhouse gases through conservation, use of green energy, or other measures, wherever possible.

Ethics and legal requirements

We expect that our Suppliers operate under a code of business ethics or a similar policy that adheres to industry best practice standards. All applicable laws, rules and regulations must be complied with and business should be carried out in an ethical, transparent, responsible and respectful manner and in a way which adheres to the highest standards of ethical conduct.

• Anti-bribery and corruption. Suppliers must comply with all applicable anti-bribery and anti-corruption laws. Suppliers must establish and maintain procedures to prevent: 1) any offer, promise, gift or solicitation of an advantage as an inducement or reward to a person for the improper performance of that person’s position or as an attempt to influence a person in that person’s capacity as a public official; and 2) participation in any other form of corrupt practice (such as theft, fraud, blackmail, participation in a criminal organisation and money laundering) under any circumstances.
• Responsible sourcing of conflict minerals. Suppliers which are sourcing conflict minerals shall develop specific due diligence processes in accordance with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. Due diligence must be conducted at the material processing level to determine whether conflict materials originate from high-risk regions, which include areas with conflict, worst forms of child labor, forced labor and human trafficking, severe human rights violations, or other objectively high-risk activities, including severe security risks, as well as negative environmental impacts.
• Fair trading and competition. Suppliers must comply with all applicable advertising, fair trading and competition laws.
• Disclosure of Information. Suppliers must not make any false representations or provide false information or data to TIER or in connection with any transaction or work involving TIER or its customers.
• Personal Information. Suppliers must commit to protecting the reasonable privacy expectations in relation to the personal information of their clients, suppliers and employees. Suppliers must comply with all applicable privacy and information security laws and regulatory requirements when personal information is collected, stored, processed, transmitted or shared.
• Confidentiality. Suppliers must ensure that confidential information and trade secrets obtained by them in the course of business activities with TIER are treated in strict confidentiality and are not disclosed to third parties.
• Intellectual Property. Suppliers are obliged to protect TIER’s intellectual property rights and not to use them for any purposes other than as authorised by TIER in the course of its business activities with the Supplier.
• Security. Suppliers must implement and maintain security safeguards, including administrative, physical and technical safeguards designed to protect its information systems from unauthorised access, and shall promptly inform TIER if it believes its systems have been compromised in a manner that could result in any damage to TIER.

Compliance

The Supplier shall, in relation to its business with TIER:

• not do anything which may cause TIER to breach Export Control Laws or Sanctions;
• comply with all Export Control Laws and Sanctions, including clearly indicating on all delivery notices the relevant export control classification and export licence numbers;
• not carry out any activities from a Restricted List State or sub-contract to any entity from a Restricted List State or on a Restricted Party List;
• keep TIER informed at all times of such information as TIER may require in order to comply with Export Control Laws and Sanctions, including details and copies of applicable restrictions and export classification numbers, export licences or equivalent documentation, exemptions or exception and conditions relating to export, transfer or use, and provide TIER with such assistance as TIER may reasonably request in this respect; and
• keep TIER informed at all times of all relevant information on: (i) any changes in circumstances relevant to compliance with Export Control Laws and Sanctions; (ii) actual or potential breaches of Supplier’s obligations in relation to Export Control and Sanctions; (iii) loss, suspension or invalidation of any relevant licence, authorisation, approval or export control privileges, including by being placed on a Restricted Party List; or (iv) it becoming aware that any relevant authority has initiated or will initiate any investigation or proceedings against the Supplier relating to an actual or potential breach of any Export Control Laws or Sanctions.

Commitment to Suppliers

TIER seeks to engage in long-term relationships with suppliers that are committed to sustainable development. TIER’s goal is to partner with suppliers to deliver value to customers and to demonstrate responsible supply chain management.

To that effect, TIER offers a channel for employees and external stakeholders, including suppliers, to report any behaviour or business practice, happening within TIER’s supply chain ecosystem, that violates any of the principles mentioned in this Supplier Code of Conduct:

Access to TIER Integrity Line by clicking HERE.

We respect the right of all workers, at our own business or at a supplier level, to speak up and raise grievances. TIER is committed to non-retaliation against individuals making reports and to maintain confidentiality and anonymity with respect to such reports, as allowed by local laws.