FEKA Supplier Code of Conduct
FEKA Otomotiv Mamulleri Sanayi ve Ticaret A.Ş. ("FEKA") Supplier Code of Conduct ("Code") establishes our requirements for suppliers to ensure that working conditions in FEKA's supply chain are safe, that workers are treated with respect and dignity, and that business processes are environmentally responsible. To fully achieve these objectives, this code defines the corporate responsibility requirements for all suppliers working with FEKA. FEKA reserve the right to reasonably modify the requirements of this Code due to the changes in the FEKA compliance program. FEKA may visit (and/or have external monitors visit) supplier facilities, with or without notice, to assess compliance with this Code. Such a right does not mean that FEKA will institute regular inspections or any inspections at all. Suppliers have total responsibility for their compliance with this Code of Conduct, not FEKA.
1. Labor and Human Rights
Non-Discrimination
Suppliers shall be committed to creating a workforce free of harassment and unlawful discrimination of race, color, age, gender, sexual orientation, ethnicity, disability, pregnancy, religion, political affiliation, union membership, national origin, or marital status in hiring and employment practices, such as promotions, rewards, access to training. In addition, workers or potential workers shall not be subjected to medical tests that could be used in a discriminatory manner.
Humane Treatment
Suppliers shall treat all employees with respect void of any harsh or inhumane treatment, such as sexual harassment, sexual abuse, corporal punishment, mental or physical coercion, verbal abuse of workers, or unreasonable restrictions at work.
Freely Chosen Employment
Forced, bonded, indentured labor or involuntary prison labor shall not be used. All work must be voluntary. Workers shall not be forced to hand over government-issued identification, passports, or work permits to suppliers as a condition of employment, unless required by local law.
Avoidance of Child Labor
Child labor shall not be used during any manufacturing. The term “child” refers to a person below a certain minimum age. This minimum working age shall determined by local laws and regulations. FEKA supports legitimate workplace apprenticeship programs that comply with all laws and regulations applicable to such programs.
Working Hours
Working weeks and hours must not exceed the maximum, as established by local laws and regulations.
Wages and Benefits
Compensation paid to workers shall comply with all applicable laws and regulations. Suppliers shall also provide to workers all legally mandated benefits. Furthermore, deductions from wages cannot be used as a disciplinary measure against workers.
Freedom of Association
Suppliers shall respect the rights of workers to associate freely, join or not join labor unions, seek representation, or join worker's councils in accordance with local laws and regulations. Workers shall be able to communicate openly with management regarding working conditions without fear of reprisal, intimidation, or harassment.
2. Health and Safety
Suppliers must collaborate with FEKA to design safe processes and maintain a healthy work environment for ensuring ongoing quality and production efficiency. Suppliers must keep workplace safe and healthy for their employees in compliance with applicable local laws and regulations.
Occupational Safety
Suppliers shall eliminate physical and safety hazards and take precautionary measures that guard against accidents and occupational diseases. These hazards shall be controlled through proper design, engineering/administrative controls, preventative maintenance, safe work procedures, and ongoing safety training. Where hazards cannot be adequately controlled by these means, workers shall be provided appropriate and well-maintained personal protective equipment.
Industrial Hygiene
Worker exposure to chemical, biological and physical agents is to be identified, evaluated, and controlled. Engineering or administrative controls must be used to control overexposures. When hazards cannot be adequately controlled by such means, suppliers shall provide appropriate personal protective equipment programs.
Emergency Preparedness
Emergency situations and events are to be indentified and assessed, and their impact minimized by implementing emergency plans and response procedures.
Occupational Injury and Illness
Procedures and systems are to be in place to prevent, 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 take corrective actions to eliminate their causes; and e) facilitate the return of workers to work.
Sanitation, Food, and Housing
Workers are to be provided with ready access to clean toilet facilities, potable water and sanitary food preparation, storage, and eating facilities. Worker dormitories provided by the suppliers or a third party agent – if any – are to be maintained clean and safe, and provided with appropriate emergency egress and adequate heat and ventilation and reasonable personal space, entry and exit privileges.
Physically Demanding Work
Exposure of workers to the hazards of physically demanding tasks shall be identified, evaluated, and controlled. These physically demanding tasks include manual material handling, heavy or repetitive lifting, prolonged standing, and highly repetitive or forceful assembly tasks.
Maintaining Machine Safety
Production and other machinery are to be evaluated for safety hazards. Physical guards, interlocks, and barriers are to be provided and properly maintained where machinery presents an injury hazard to workers.
3. Environmental Impact
Suppliers must recognize that doing business in an environmentally responsible way is essential for operating a world class product production process. Suppliers should aim to minimize the adverse impact of their manufacturing process on the environment and the local community.
Environmental Permits and Reporting
All required environmental permits (e.g. discharge monitoring), approvals and registrations are to be obtained, maintained and kept current and suppliers shall follow their operational and reporting requirements.
Hazardous Substances
Suppliers shall comply with FEKA's environmental and quality management standards. Also, they shall identify chemical and other materials that pose a safety hazard if released to the environment and manage the safe handling, movement, storage, use, recycling, reuse, and disposal of these substances.
Solid Waste and Wastewater
Suppliers shall identify, monitor, control and treat solid waste and wastewater generated from operations, industrial processes, and sanitation facilities, as required by applicable laws and regulations prior to discharge.
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 before discharge, as required by the applicable laws and regulations.
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, and recycling and re-using materials.
Product Content Restrictions
Suppliers shall adhere to all applicable laws, regulations, and customer requirements regarding prohibition or restriction of specific substances, including labeling for recycling and disposal. Adherence to IMDS and “Conflict Minerals” reporting requirements is a must.
4. Ethics
Business Integrity
The highest standards of integrity are expected in all business interactions. Suppliers shall prohibit any and all forms of corruption, extortion, embezzlement, bribery, kickbacks, gifts including any payments or other forms of benefits conferred on any government official for the purpose of influencing decision making in violation of law. Any other means of obtaining undue or improper advantage are not to be offered or accepted. Monitoring and enforcement procedures shall be implemented to ensure compliance.
Disclosure of Information
Information regarding business activities, structure, financial situation, and performance is to be recorded and disclosed in accordance with applicable laws and regulations and prevailing industry practices.
Protection of Identity
Suppliers shall create and maintain programs to ensure the confidentiality and protection of supplier and employee whistleblowers.
Protection of Intellectual Property
Suppliers shall respect intellectual property rights and transfer of technology and know-how must be done in a manner that protects those rights.
5. Materials Not Obtained Through Illegal and Unethical Ways
Suppliers shall evaluate the origin or source of their materials throughout their supply chains to verify that they have not been obtained through any illegal and unethical ways. (e.g., materials obtained from mining in the Democratic Republic of Congo or an adjoining country, fibres obtained from logging in high conservation value forest areas or prohibited areas).
6. Management System
Suppliers shall adopt or establish a management system designed to ensure compliance with applicable laws, regulations, customer specific requirements, as well as this Code. It should also facilitate continual improvement. The management system should contain the following elements:
Company Commitment
Corporate policy regarding quality, environmental and social responsibilities that affirm suppliers' commitment to compliance and continual improvement. Certification by 3
rd party to latest version of ISO/TS 16949 is required and ISO 14001 is recommended.
Management Accountability and Responsibility
Clear identification of company representative[s] responsible for ensuring implementation of the management systems and associated programs.
Legal and Customer Requirements
Identification, monitoring and understanding of applicable laws, regulations and customer specific requirements.
Risk Assessment and Management
Process delineating the environmental, health, safety, labor practices, and ethical risks associated with the suppliers' operations. Determination of the relative significance for each risk and implementation of the appropriate procedural and physical controls to control the identified risks and ensure regulatory compliance.
Improvement Objectives
Written performance objectives, targets and implementation plans to improve the suppliers' quality, environmental and social performance, including a periodic assessment of suppliers' performance to achieve these objectives.
Training and Communication
Programs for training managers and workers to implement suppliers' policies, procedures and improvement objectives and to meet applicable legal and regulatory requirements and process for communicating clear and accurate information about suppliers' policies, practices, expectations, and performance to workers, suppliers, and customers.
Worker Feedback and Participation
Process for obtaining employee feedback concerning practices and conditions covered by this Code and making improvements upon such feedback.
Audits and Assessments
Periodic self-evaluations to ensure conformity with this Code, as well as applicable local laws and regulations.
Corrective Action Process
Process for timely correction of deficiencies identified by internal or external assessments, inspections, investigations, and review.
Documentation and Records
Creation and maintenance of documents and records to ensure regulatory compliance and conformity with company requirements to protect its confidentiality.
REFERENCES
The following standards were used in preparing this Code and may be a useful source for additional information.
