Legal Compliance
Suppliers must comply with all laws and regulations in their country of operation and all other applicable laws and regulations.
Business Integrity
Bribes, kickbacks, illegal political contributions, or improper payments to customers, government officials, or third parties are strictly prohibited. Suppliers must not directly nor indirectly give or receive improper business advantage by giving or receiving anything of value in exchange for preferential treatment. Christy Metals Code of Conduct prohibits Christy Metals employees from soliciting personal gifts, money, loans, or personal discounts from Christy Metals suppliers and from engaging in any business entertainment that is not customary or reasonable in value.
Protecting Intellectual Property
Suppliers must respect intellectual property rights and safeguard all Christy Metals confidential and proprietary information.
Child Labor
Suppliers must comply with local laws regarding the minimum age of employees and all legal requirements for the work of authorized young workers, particularly those pertaining to hours of work, wages, working conditions, and the handling of certain materials.
Forced Labor and Human Trafficking
Suppliers shall not use any form of involuntary or forced labor or indentured, bonded, or prison labor. Suppliers shall not use, condone, or participate in any form of slavery or human trafficking.
Health and Safety
Suppliers must provide employees with a safe and healthy working environment, including appropriate controls, safety procedures, preventative maintenance, and protective equipment. Practices must comply with all relevant local and national laws. Suppliers must implement management systems to meet these requirements.
Freedom of Association
Suppliers must respect employees’ legal rights to join or refrain from joining worker associations and their legal right to bargain collectively.
Non-Discrimination
All terms of employment — including hiring, payment, benefits, training, promotion, termination, and retirement — should be based on an individual’s ability to do the job and performance. Suppliers shall not discriminate against employees based on age, disability, ethnicity, marital or family status, national origin, race, color, religion, sex, sexual orientation, or any other characteristic protected by law.
Harassment
Suppliers must treat all employees with respect and dignity. No employees shall be subject to corporal punishment, physical, sexual, psychological, or verbal harassment or abuse.
Wages, Benefits and Working Hours
Suppliers must provide wages equal to the applicable legal minimum wage and associated benefits. If there is no legal minimum wage, suppliers must ensure that wages are at least comparable to those at similar companies in the local area or to prevailing industry norms. Suppliers must not exceed prevailing local work hours and appropriately compensate for overtime. In addition, except in extraordinary business circumstances, all workers are entitled to at least one day off every seven days.
Protection of the Environment
Suppliers are expected to operate in a manner that protects the environment. At a minimum, suppliers must fully comply with all applicable environmental laws regarding the workplace, the products produced, and the methods of manufacture. Suppliers should further strive to conduct their operations to minimize exposure to potentially hazardous materials, conserve natural resources, and encourage the development of environmentally friendly technologies.
Counterfeit Materials
Suppliers shall establish systems to stop counterfeit products or materials being introduced into the supply chain.
Conflict Minerals
Suppliers shall ensure that their products do not contain tin, tantalum, tungsten, or gold that directly or indirectly finance or benefit armed groups in the Democratic Republic of the Congo (DRC) or an adjoining country.
Suppliers are expected to exercise due diligence on the source and chain of custody of such minerals in accordance with generally accepted international standards and make such due diligence measures available upon request. Christy Metals’ Conflict Minerals Policy can be found at
ChristyMetals.com.
Suppliers and Subcontractors – Assurance of Compliance
Suppliers must adopt or establish a management system designed to ensure compliance with this Code and applicable laws and regulations, identify and mitigate related operational risks, and facilitate continuous improvement in these matters.
In addition, suppliers are expected to have adequate monitoring and record-keeping systems to verify compliance. Suppliers are also responsible for ensuring their subcontractors and agents comply with this Code. Christy Metals reserves the right to monitor, review, and verify compliance with this Code.
Anonymous Reporting and Whistleblower Protection
Suppliers shall provide an anonymous complaint mechanism for managers and workers to report workplace grievances and illegal or unethical conduct. Suppliers shall protect whistleblower confidentiality and prohibit retaliation.
Violations
Suppliers must report known violations of this Code to Christy Metals. To report violations by suppliers, subcontractors, employees, or any representative doing business on behalf of Christy Metals, please contact Quality Manager Les Rostkowski at 847 729 5744.
Anti-Corruption
Suppliers must comply with the U.S. Foreign Corrupt Practices Act (FCPA)
justice.gov/criminal-fraud/foreign-corrupt-practices-act and other applicable anti-corruption laws and regulations within their country of operation. Christy Metals has a strict, zero-tolerance policy for corruption. Ensuring compliance with anti-corruption laws is vital to Christy Metals’ business interests. This principle applies to all Christy Metals transactions worldwide – without exception.
Conflicts of Interest
Suppliers shall act reasonably and objectively and avoid all conflicts of interest when doing business with Christy Metals. This includes even the appearance of any potential conflict of interest. Suppliers are expected to report any potential, perceived, or actual conflict of interest that may arise during business with Christy Metals. Fair Competition. Anti-trust Suppliers must comply with all applicable competition and anti-trust laws and regulations when conducting business. Christy Metals is committed to providing only honest and truthful information and will not engage in any illegal activity or behave unethically when conducting business. Our suppliers expect this same level of commitment.
Trade Compliance
Suppliers involved with the sale and distribution of Christy Metals’ products and services are expected to know and follow all applicable export and import control laws and Christy Metals’ policies regarding trade compliance. Accurate Accounting/Records Management Suppliers are expected to maintain accurate and complete business records. Records such as company reports, accounts, financial statements, regulatory reports, and publicly filed documents should comply with all applicable and accepted accounting principles and statutory requirements.