Supplier Code of Conduct

Introduction

Pte Ltd, and each of its associated companies (“we”, “us”, “our”, “Neuron”) is committed to conducting its business with integrity and employing responsible business practices.  We believe in this because it is the right thing to do and it adds long term value to our customers, our communities and our business.  As a responsible business, we engage a select number of strategic Suppliers and we expect these Suppliers to uphold Neuron’s values.  This includes being respectful of the environment, promoting ethical employment, safe and respectful work conditions and practicing business integrity.

This Supplier Code of Conduct (“Code”) sets out Neuron’s fundamental ethical and business conduct standards for its Suppliers. Neuron expects its Suppliers to ensure that they, their directors, officers, employees, representatives and business partners understand and comply with this Code.  We expect full transparency in our supply chain and Suppliers must promptly notify us of any known or suspected violation of this Code and maintain accurate documentation for demonstrating compliance with this Code. 

Labour

Neuron believes that all workers deserve a humane and ethical workplace, and deserve to be treated with dignity and respect. Neuron expects the same of its Suppliers. 

Freely Chosen Employment
Suppliers must not use any forced, indentured or bonded labour, slavery or trafficking of persons. Suppliers are responsible for conducting reasonable investigations of their supply chains to ensure they are free from forced labour of any kind. 

No Child Labour
Suppliers must not engage in the unlawful employment of children in the workplace. Suppliers should actively combat the exploitation of children, conducting reasonable investigations of their supply chains to ensure that their own vendors, suppliers or third-party partners are free of unlawful employment of children. 

Wages and Benefits
Neuron requires that Suppliers comply with all local labour laws in the countries where it operates, including those relating to wages, overtime and benefits.  Suppliers shall pay workers for all work completed and at least the minimum wage required by law or the prevailing industry wage, whichever is higher.

Working Hours
Suppliers must ensure that working hours (including but not limited to overtime) and requirements for providing rest periods, do not exceed that allowed by local law. 

Fair Treatment and Non-Discrimination
Suppliers must maintain a respectful workplace which is free from harassment and unlawful discrimination including discrimination based on race, ethnicity or national origin, age, gender, sexual orientation, marital status, gender identity and expression, ethnicity, disability, pregnancy, religion, political affiliation or marital status.

Freedom of Association
Suppliers must recognize and respect the right of workers to form and join trade unions and other worker organizations and participate in collective bargaining without fear of harassment, interference, or retaliation. 

No Harassment or Abuse
Suppliers must treat each employee with dignity and respect. Suppliers must be committed to a workplace free of harassment. Suppliers must not threaten workers with or subject them to harsh or inhumane treatment, including sexual harassment, sexual abuse, mental coercion, physical coercion, or verbal abuse.

Business Integrity

Neuron expects its Suppliers to conduct their business in an ethical manner. We expect that our Suppliers comply with all laws and regulations in the countries, states, and locations in which they operate, as well as all other applicable international laws and regulations. 

Anti-bribery and Corruption
Suppliers must not take part in any form of bribery, fraud, corruption, extortion or other behavior involving unjust benefits.  Suppliers must never offer, promise, authorise, or provide, directly or indirectly, anything of value (including, without limitation, business gifts, entertainment or courtesies) with the intent or effect of influencing anyone’s business judgement and providing an unfair business advantage to the Supplier, Neuron, or others.

Data Privacy
Suppliers must comply with all applicable data protection, privacy and information security laws and regulations (collectively, “Data Protection Laws”) including, without limitation, such laws pertaining to Neuron customers, Neuron employees or other suppliers.  Suppliers must not render any service or process any information in a manner that causes Neuron to violate Data Protection Laws.

Anticompetitive Business Practices
Suppliers must not engage in any kind of illegal business practice, including any such practice that is anticompetitive, deceptive or an abuse of market power.  This includes not making any kind of representation relating to services provided by Neuron.  

Information Security and Confidentiality
Suppliers must implement technical and organisational measures to ensure that they protect all confidential, proprietary and personal information that it handles or processes.  This includes taking all reasonable steps to protect itself against cyber attacks.  Our Suppliers are expected to notify Neuron of any suspected or actual data breach of any information handled by or supplied to the Supplier by or on behalf of Neuron.  

Environment

Environmental responsibility is at the core of our business values. Neuron expects Suppliers to understand environmental risks and responsibilities, and develop and maintain responsible business practices to protect our environment.  

Environmental Permits
Suppliers must obtain and keep current all required environmental permits, approvals and registrations, and follow their requirements.

Resource Efficiency
Suppliers are expected to reduce inefficient consumption of resources throughout operations, including by minimizing the use of raw materials, energy and water. Suppliers should seek to minimise energy consumption and greenhouse gas emissions, and work to improve energy efficiency and use clean and renewable energy, including using electric vehicles where possible. 

Recycled Materials
Suppliers should increase the use of recycled and recyclable materials in their manufacturing and business operations wherever possible. 

Hazardous Substances
Suppliers must identify and manage any chemicals and other materials that pose a hazard to the environment and ensure safe use and disposal. 

Waste Mitigation
Suppliers should implement waste reduction and responsible recycling practices and promote landfill diversion. 

Health and Safety

At Neuron, safety is at the heart of everything we do. We are fully committed to providing a healthy and safe workplace that promotes employee well-being, and prevents injury and ill-health.  We expect the same commitment to health and safety from our Suppliers.  

Workplace Health and Safety
Neuron expects its Suppliers to comply with all relevant health and safety laws and regulations (including industry requirements) and to identify and control safety and health hazards, with proper maintenance, safe working procedures, resources, training and communications.   This includes ensuring that the Supplier’s employees are qualified, and equipped, to perform activities safely.  

Emergency Preparedness
Suppliers shall identify and assess potential emergency situations and prepare and implement business continuity and response procedures that will minimise harm to employees, its customers, and the environment.

Compliance and Reporting

Neuron expects each Supplier to promptly report to Neuron any actual or suspected violation of this Code.  We thank our Suppliers for their compliance with this Code and commitment to integrity.  We look forward to lasting relationships with our Suppliers based on the highest ethical standards.