Scantinel GmbH and its affiliated entities (collectively, “Scantinel,” the “Company,” “our,” or “we”) are committed to complying with all applicable laws and regulations, to upholding human rights and labor standards and to protecting the environment – in our own operations as well as in relation to our business partners. At Scantinel, we uphold the universal principles of human rights, labor, environment and anti-corruption. This is important to the customers who purchase our products, to our stakeholders, to our community, and to ourselves. This Supplier Code of Conduct defines the basic requirements to meet our standards.

This Code is based on the International Bill of Human Rights, including the Universal Declaration of Human Rights; the ILO Declaration on Fundamental Principles and Rights at Work; the OECD Guidelines for Multinational Enterprises; the International Covenant on Civil and Political Rights; and the International Covenant on Economic, Social, and Cultural Rights. We expect our suppliers to fully comply with applicable laws and to adhere to internationally recognized human rights as well as environmental, social and corporate governance standards (ESG standards) as in particular laid down in international conventions and the Social Accountability 8000 International Standard (SA8000). We expect you, as our business partner, to share this commitment and ensure that these requirements and expectations are also passed on appropriately to your downstream partners in the supplier network. Suppliers must adopt adequate and efficient management systems, polices, procedures and training and conduct human rights and environmental due diligence to uphold the standards and requirements set forth in this Supplier Code of Conduct. Compliance with the minimum requirements outlined in this Code is a binding part of Scantinel’s terms and conditions of purchase.

Your cooperation as a Supplier is crucial to the success of this code and is the basis for our business relationship.

Please contact us if you ever need more information about how to act in accordance with this code.

Consequences for code violations

There are serious consequences for violating this Supplier Code of Conduct and any applicable laws, including the loss of future business dealings with Scantinel and possibly the termination of contracts. Consequences for legal violations can include heavy fines for companies and individuals as well as jail time.

Scantinel requires its suppliers to comply with the following Supplier Code of Conduct provisions at all times when conducting business with Scantinel.

1. Health and safety

Our business partners must:
- Comply with all applicable laws and regulations on occupational health and working safety.
- Commit to continuous improvements of occupational health and safety.
- Use or set up a reasonable occupational health and safety management system.
- Maintain drug- and alcohol-free workplaces and prohibition of the distribution, sale, purchase, exchange, possession and use of illegal drugs in the workplace.
- Prohibit smoking, except in designated areas.

2. Human rights and labor standards

Working time: 

Our business partners must address the following topics:

Comply with applicable law and sector-specific labor regulations concerning working time, including rest time and overtime laws.

Wages and benefits: 

Provide wages and benefits as prescribed by the respective national laws, including minimum wage legislation, and in line with existing practice in the industry and local labor markets.

Non-discrimination and fairness: 

Apply the principles of equal opportunity and fair treatment. Tolerance of any form of discrimination or verbal or physical harassment of employees or other such conduct that interferes with an individual’s work performance or creates an intimidating, hostile or offensive work environment, is totally forbidden.

Freedom of association and collective bargaining: 

Recognize, as far as legally permitted, the right of free association and collective bargaining of employees.

No forced labor: 

Do not tolerate any form of forced labor, including forced prison labor, indentured labor, bonded labor, slave labor or any form of human trafficking.

No child labor:

Comply with minimum working age requirements prescribed by national laws and international agreements.

Protection of vulnerable groups: 

Commit to protect the rights of vulnerable groups within supplier’s businesses and supply chains, particularly the rights of women, indigenous people, children, and migrant workers. Suppliers will develop and implement internal measures to provide equal pay and opportunities throughout all levels of employment. Suppliers will also implement measures to address health and safety concerns that are particularly prevalent among women workers, including but not limited to, preventing sexual harassment, offering physical security, and providing reasonable accommodation for nursing mothers.

3. Legal compliance and integrity

Our business partners must comply with all applicable laws and regulations, in particular:

Price Fixing

Maintain and enforce a prohibition against entering cartels, engaging in price fixing, market sharing or bid rigging, or exchanging sensitive business data with competitors in order to restrict competition.

Corruption and Bribery:

Maintain and enforce a prohibition of any corruption or bribery. Payments will only be made to business partners, customers or other external third parties within the legally permissible framework and specified requirements. Suppliers shall refrain from giving or receiving anything of value, including money, gifts, or unlawful incentives to improperly influence negotiations or any other dealings with governments and government officials, customers, or any other third parties. Indications of corruption must be communicated immediately to Scantinel’s Legal Department at legal@scantinel.com. 

Competition and Antitrust Law:

Work in accordance with all applicable competition and antitrust laws. In particular, agreements and concerted practices between competitors that aim to prevent or restrict free competition are prohibited. It is also not permissible to abuse a dominant market position.

Conflict of Interest:

Avoid any conflict of interest or situation that could create the appearance of a potential conflict of interest in the business world. Keep Scantinel’s business, financial and technical information and business correspondence confidential; do not falsify the material or intellectual property of Scantinel or other companies.

4. Land rights

Scantinel is committed to following the principles of Free, Prior and Informed Consent of Indigenous Peoples for property or land negotiations. Scantinel strictly prohibits harassment, intimidation, criminalization or violence towards human rights, environmental and land defenders.

Our business partners must:
- Ensure that operations do not result in unlawful eviction from or taking of land, forest, or waters, and avoid illegal deforestation in accordance with international biodiversity regulations, including the IUCN Resolutions and Recommendations on biodiversity.
- Ensure that the land rights of individuals, indigenous people and local communities are respected as part of a company policy.
- Respect the land rights of individuals, indigenous people, and local communities in accordance with local laws, the ILO Indigenous and Tribal Peoples Convention (No. 169), and the United Nations Declaration on the Rights of Indigenous People.
- Respect the rights of local communities to decent living conditions, education, employment, social activities, and the right to Free, Prior, and Informed Consent (FPIC) to developments that affect them and the lands on which they live, with particular consideration for the presence of vulnerable groups.
- Implement, where applicable, a system for due diligence to uncover and disclose risks and impacts to communities related to land issues.

5. Environmental protection

Our business partners must:
- Comply with all applicable laws and regulations and international standards relating to the protection and preservation of the environment.
-Commit to continuous improvements of environmental protection and be transparent, accountable, and engaged.
- Use or set up a reasonable environmental management system.
- Contribute to the protection of the environment by helping to reduce the consumption of raw materials and energy, optimize natural resources and reduce waste discharges during the design, manufacture, distribution, use and recycling of all products.

6. Supply chain

Our business partners must undertake reasonable efforts to encourage suppliers and subcontractors to comply with the principles of this Supplier Code of Conduct.

7. Confidentiality

Our business partners must:
- Be extremely cautious as to the integrity and safety of information technology networks and devices as well as the exchange of information, be it directly, via IT systems, or on social media.
- Protect information, know how, IP rights and, generally, confidential and strategic information.
- Respect the intellectual property and confidential information of others as well as the confidentiality of their data, projects, trade secrets, copyrights, and other intellectual property, including software, images and publications.
- Respect confidentiality or rights and use information disclosed or rights provided for the sole purpose of fulfilling obligations.

8. Data protection

Our business partners must:
- Protect personal data and implement a detailed data protection compliance program.
- Collect, use, and store personal data for the sole purpose of managing business and/or contractual relationships.
- Comply with all applicable laws and regulations related to processing of personal data, including but not limited to the European General Data Protection Regulation (GDPR), the California Privacy Rights Act (CPRA), the Colorado Privacy Act (CPA), the Connecticut Data Privacy Act (CTDPA), and the Virginia Consumer Data Protection Act (VCDPA).
- Enter into and comply with a Data Processing Agreement (DPA) with Scantinel before accessing or processing any personal data (as defined in the GDPR or other applicable regulations) in connection with performance or services provided to Scantinel or its customer(s).

9. Information Security

Our business partners must:
- Comply with all applicable laws and regulations concerning data protection and information security.
- Handle data responsibly and with transparency, ensuring that any information provided, stored, or processed is protected against unauthorized access, disclosure, alteration, or destruction.
- Warrant that they maintain effective information security measures to safeguard Scantinel data and systems.

Any business partner with access to Scantinel’s global systems or sensitive information (as defined by the GDPR and TISAX), must maintain a recognized security certification, such as ISO 27001 or an equivalent standard. If such certification is not available, the business partner must complete and submit a completed security questionnaire demonstrating their information security controls and compliance measures.

Scantinel reserves the right to assess and audit the business partner’s security practices to ensure ongoing compliance.

10. Export/Import and economic sanctions restrictions

Our business partners must:
- Comply with applicable laws and regulations that govern the importing and exporting of goods, services, technologies, and information, including re-exports and parallel trade.
- Provide Scantinel, upon reasonable request, with information regarding international business dealings.
- Comply with all applicable economic sanctions, export controls, and import regulations.

11. Conflict minerals

Conflict minerals are certain types of raw materials that come from specific regions where human rights violations and violent conflicts are occurring. Typically, these conflict minerals are tin, tungsten, tantalum and gold from the Democratic Republic of the Congo and surrounding areas. Suppliers that use any of these raw materials in their products must identify and disclose all the smelters and refiners in their supply chains and assess whether they have conducted an OECD-compliant due diligence process. Suppliers shall ensure that the purchase of these materials is made exclusively from refineries and smelters that meet the requirements of the Responsible Minerals Assurance Process (RMAP) of the Responsible Minerals Initiative (RMI).

Suppliers are expected to provide a Conflict Minerals Reporting Template (CMRT) to Scantinel, annually by February 1. If a smelter or refinery used does not comply with the requested standard, Scantinel may require suppliers to remove refineries and smelters that are not RMAP-compliant from the Scantinel supply chains in the long term.

Scantinel and all our business partners must actively avoid acquiring, trading, possessing or otherwise furthering the use of these conflict minerals.

12. Audit and assessment

To ensure that suppliers comply with the minimum requirements and standards laid down in this code, Scantinel has a right to monitor and periodically review its business partners’ compliance with the code and applicable laws, including unannounced visits and inspections.

Scantinel requires its business partners to warrant the necessary transparency, in particular by fulfilling the following information and cooperation obligations:
- Upon request of Scantinel, Suppliers must provide information on the human rights and ESG standards due diligence processes established in its company. This will be done by means of a self-disclosure questionnaire provided by Scantinel which Suppliers answer completely and truthfully to the best of their knowledge by submitting relevant documents.
- Scantinel is entitled to inspect or audit the human rights and ESG standards due diligence processes established by Suppliers, including the due diligence measures taken by Suppliers, as well as the timely implementation of any corrective action plan, or to have them inspected or audited by a third party commissioned by Scantinel. Scantinel may use the information and findings from these inspections and audits to fulfil statutory obligations, such as those arising from reporting requirements, taking into account company and business secrets, as well as the confidentiality obligations of Suppliers.
- Suppliers will forward the content of this Code to their subcontractors, placing them under the corresponding obligations, and will monitor and check compliance with human rights standards in the supply chain. Suppliers are responsible for ensuring that their subcontractors also act in accordance with these human rights standards.

13. Help / contact / reporting policy

Suppliers can direct complaints and information within the framework of the existing company regulations to the competent authorities. If a Supplier discovers a possible violation of this Supplier Code of Conduct or other misconduct in our environment, it is their obligation to bring this matter to Scantinel’s attention immediately by reporting to our Legal Department at legal@scantinel.com.
 
Reports and investigations will be handled in accordance with Scantinel’s internal reporting policy. Scantinel expressly encourages Suppliers to report anonymously as there is no requirement to disclose your identity or any other personal data relating to you. Filing a report anonymously will have no negative consequences for the reporter.

Our business partners who have any questions or concerns regarding behavior in compliance with this Supplier Code of Conduct can contact Scantinel at Legal@scantinel.com at any time.