Supplier Code of Conduct

Introduction

Kyocera Document Solutions (U.K.) Limited, Annodata Limited and Midshire Communications Ltd, hereby referred to as “Kyocera Document Solutions UK”, believe that the relationships formed with its suppliers are built on a foundation of mutual trust and respect.

Our philosophy and values help us strive to live the right way and act responsibly, change things for the better, respect people, and help to protect our precious environment. These are all values that we strive to share with our business partners.

Throughout this Supplier Code of Conduct we have outlined a number of commitments that we expect our suppliers to adhere to when working with, or on behalf of Kyocera Document Solutions UK and its customers. These shall be considered contractual obligations in addendum to both existing and future agreements. Failure to adhere to the requirements may constitute a contractual breach and could lead to termination of the agreement.

This Supplier Code of Conduct shall extend to any sub-contracted work or use of contingency workers by suppliers for work being performed for, or on behalf of Kyocera Document Solutions UK and its customers.

Social Responsibility:

Organisations have a legal obligation and a moral expectation to operate in a socially responsible manner, ensuring the most vulnerable in society are protected from exploitation and that business transactions are with parties that comply with legislative requirements. This is also a requirement for our suppliers.

In order to comply with this code of conduct, suppliers are expected to:

• Ensure that the minimum wage (in line with relevant current legislation) is provided to employees and contractors.
• Ensure that they are not complicit in human trafficking or modern slavery.
• Undertake steps to ensure no child labour is utilised within its activities or supply chain. This should be in accordance with UK legal requirements.
• Ensure that no conflict minerals are used in the supply chain as part of the provision of goods and/or services to Kyocera Document Solutions UK or its customers.
• Ensure that they do not engage with any prohibited or sanctioned parties in contravention to applicable local legal requirements.

Diversity & Inclusion:

It is expected that personal freedoms and human rights are respected by all suppliers that work with Kyocera Document Solutions UK. Discrimination on the grounds of gender, race, religious beliefs or sexual orientation (amongst others) is contrary to our values, how modern businesses work and will not be accepted.

In order to comply with this code of conduct, suppliers are expected to:

• Where appropriate, establish governing policies and procedures that a) ensures that discrimination based on gender, race, religious beliefs, cultural background or sexual orientation is prohibited and b) that allegations of discrimination are investigated without prejudice.
• Comply with governing regulation and legislation around diversity and inclusion (e.g. Equality Act 2010).

Anti-bribery, Corruption, Anti-trust and Competition:

Modern business is predicated on the principles of transparency and a fair and level playing field for all, not impropriety and unscrupulous actions designed to provide an unfair advantage. Failure to act with integrity can not only lead to significant punitive actions, but also cause significant reputational damage, and destroy trust with customers.

In order to comply with this code of conduct, suppliers are expected to:

• Identify potential conflicts of interest arising from working with Kyocera Document Solutions UK and its customers. These should be disclosed to compliance@duk.kyocera.com without undue delay.
• Behave in a manner that is fair to the consumer / customer, avoiding practices that are contrary to anti-trust and competition principles (e.g. no price fixing or cartel behaviour).
• Ensure compliance to appropriate legislation in relation to money-laundering, anti-corruption and competition law.
• Provide whistleblowers reporting criminal acts in good faith with the necessary protections in accordance with relevant laws, and ensure they are not subject to punitive actions.
• Not offer inducements, incentives or hospitality to any Kyocera Document Solutions UK staff without the prior written approval by a Director of Kyocera Document Solutions UK.

Information Security & Data Protection:

It is a reasonable expectation that suppliers will have appropriate measures in place to protect information assets belonging to Kyocera Document Solutions UK or its customers.

Failure to protect information, leading to a potential data breach may lead to not only serious punitive damages but also have a detrimental impact on the reputation of not only the supplier but also to Kyocera Document Solutions UK and its customers.

In order to comply with this code of conduct, suppliers are expected to:

• Ensure that any significant security vulnerabilities that potentially exposes or compromises the data of Kyocera Document Solutions UK or its customers shall be notified in writing to Kyocera Document Solutions UK within 48 hours of identification to Compliance@duk.kyocera.com
• Ensure that any breach of data belonging to Kyocera Document Solutions UK or its customers shall be notified in writing to Kyocera Document Solutions UK within 48 hours of identification to compliance@duk.kyocera.com.

Health and safety:

Suppliers are obliged by law to comply with applicable health & safety legislation (e.g., Health & Safety at Work Act 1974) and take necessary action to ensure that all persons (employees, contractors, and members of the public etc) are protected from unsafe working practices.

In order to comply with this code of conduct, suppliers are expected to:

• Ensure that all staff and contractors are provided with necessary training and equipment (e.g. Personal Protective Equipment) to perform their activities safely.
• Ensure that appropriate risks are identified and communicated to relevant staff and contractors.
• Notify any reportable health & safety incidents (based on local regulations) that have arisen whilst performing activities for, or on behalf of Kyocera Document Solutions UK.

Environmental:

Sustainability and protecting the environment is a key priority for Kyocera Document Solutions UK, which requires the support of its suppliers in order to minimise its direct and indirect CO₂ emissions which harm the environment.

In order to comply with this code of conduct, suppliers are expected to:

• Have implemented activities that mitigate environmental impact and production of CO₂ and other harmful emissions (e.g. recycling, certification to ISO 14001 standard).
• Where possible, assist with identification of emissions for activities relating to Kyocera Document Solutions UK (scope 3 emissions as outlined by the Greenhouse Gas protocol).
• Notify Compliance@duk.kyocera.com of any enforcements placed on the supplier by the Environment Agency or other similar body and authorities.

General Compliance to Applicable Legislation:

Whilst the above stated requirements are specific focuses to Kyocera Document Solutions UK, there is an expectation that our suppliers are compliant to relevant legislation applicable to them. These may range from financial management and taxation (e.g. Corporate Criminal Offences Act) through to other requirements that guide the conduct of the supplier and its employees.

It is expected that the supplier shall notify Kyocera Document Solutions UK in the event of prosecution or other punitive actions taken against the supplier as a result of non-compliance to applicable legislation / regulation.

Audits of Supplier Code of Conduct:

In the event of suspected violations to the terms outlined in this Supplier Code of Conduct or associated legal requirements, Kyocera Document Solutions UK reserves the right to audit suppliers to ensure compliance. This may be held remotely or at the supplier’s premises during normal business hours. The scope of the audit may include any sub-contractors used to perform tasks for, or on behalf of Kyocera Document Solutions UK or its customers.

Kyocera Document Solutions UK shall provide written notice of at least 30 days of the intention to perform an audit. Costs of time and resources used to facilitate the audit by the supplier shall not be borne by Kyocera Document Solutions.

Additional References: