ST DIGITAL AFRICA including its subsidiaries ("ST DIGITAL") acts in accordance with the ST DIGITAL Group's Code of Ethics and Anti-Corruption Policy and in accordance with its "Commitments on Responsible Purchasing"

On the basis of these fundamental values of ST Digital addressing business ethics, social and environmental commitments, ST Digital requires the Supplier to uphold the principles defined below (hereinafter the "Principles").

The Supplier shall make every effort to implement the said Principles across its entire supply chain.

Legal Principles 

In addition to complying with the provisions described in articles 1 to 6 below, the Supplier must at all times comply with applicable laws and regulations, and contractual obligations as agreed between the Parties. This includes the US Foreign Corrupt Practices Act and the UK Bribery Act where applicable. The Supplier must furthermore comply with          any     international economic              sanctions (including embargoes, trade and financial restrictions), which includes any sanctions that may be in force as a result of a resolution adopted under Chapter VII of the United Nations Charter by the United Nations Security Council, as well as in particular any sanctions that may have been imposed by the European Union. 

The Supplier must commit its agents, suppliers, partners, subcontractors, and the representatives of each of them (hereinafter collectively referred to as "Third Parties") to uphold the principles of the Supplier Code of Conduct insofar as they are directly or indirectly involved in the supply of products or services under the Contract.  

The Supplier must respect internationally defined human rights and must not be complicit in any human rights violation whatsoever. The Supplier must respect the dignity of the person, privacy and the rights of every individual. Slavery in all its forms is prohibited. Furthermore, the Supplier shall make every effort to comply with all standards established by the International Labour Organization (ILO).  

Principles of Social Responsibility

Freedom of association and the right to collective bargaining

The Supplier must strive to implement internationally recognised standards, such as ILO conventions, without breaching applicable national law. It must ensure that its employees and representatives, including temporary workers, are able to openly express themselves within their organisation on any matter relating to their working conditions.

Child labour

The Supplier prohibits the use of labour by persons under the age of 15 or below the age of completion of compulsory education, or who have not reached the legal working age in the country, whichever is higher.

It must take all necessary measures to enforce this prohibition throughout its supply chain. If a child is found working on the premises of the Supplier or one of its subcontractors, the Supplier must immediately take steps to remedy the situation in order to best serve the interest of the child.

Non-discrimination and diversity The Supplier must treat all employees with respect and must not inflict corporal punishment, use physical or moral coercion, engage in any form of abuse, harassment or threats.  The Supplier must combat all forms of discrimination based on criteria related in particular to ethnic origin, skin colour, gender, sexual orientation, language, disability, religion, political and other opinions, national or social origin, age. It must ensure respect for professional equality between women and men and promote diversity, equal opportunities and equal treatment in employment and work. 

Inclusion 

The Supplier must facilitate the implementation of inclusive practices, and prioritise the use of the integration sector, the sector adapted to persons with disabilities, and collaborations with social and solidarity economy stakeholders.

No recourse to slavery and forced labour

The Supplier must comply with the United Nations Universal Declaration of Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, and all applicable regulations prohibiting slavery, including modern slavery, human trafficking, and all forms of forced or compulsory labour within the meaning of the ILO Convention on Forced Labour.   

In particular, all work must be voluntary and workers must be free to leave their jobs or terminate their employment with reasonable notice. 

The Supplier shall not retain, destroy, conceal or confiscate the identity documents and immigration papers — such as work permits — of their employees, nor deny them access thereto, unless required by law.

 Furthermore, the Supplier must work to eliminate the risk of modern slavery within its supply chain.

Compensation

The Supplier must provide remuneration in compliance with national regulations on minimum wages. In the absence of national regulations, remuneration must be sufficient to cover basic needs such as housing, food, and healthcare, and must meet the standards of ILO Convention C131 on minimum wage fixing. The basis on which workers are paid must be clearly communicated to them. The Supplier must not resort to wage deductions as disciplinary measures. 

Working time

Working time, including overtime, must comply with applicable national laws. In the absence of national law, ILO standards shall apply. In particular, the normal working week must not exceed 48 hours, excluding overtime which may not exceed 12 hours. Workers must be entitled to at least one day of rest per 7-day period.  The Supplier must ensure that all workers benefit from paid leave.

Health and safety

The Supplier must provide its workers with a working environment that ensures the protection of their health and safety, particularly with regard to fire protection and premises hygiene. 

The Supplier must take the necessary measures to prevent occupational accidents and diseases. 

The Supplier must regularly organise appropriate training to ensure that workers have sufficient knowledge of health and safety matters. This includes the provision of appropriate personal and collective protective equipment and instructions regarding their use. 

The Supplier, when providing accommodation, must ensure that it is clean and safe, that it meets the essential needs of workers and, where applicable, those of their families. 

The Supplier is encouraged to implement an Occupational Health and Safety Management System, established on the basis of international standards such as ISO 45001 or an equivalent standard. 

Principle of Sustainable Development and Environmental Protection 

Climate change mitigation and environmental protection  

The Supplier complies with environmental laws and regulations and also implements measures contributing to environmental protection: combating climate change and preserving natural resources and biodiversity.  The Supplier must minimise the negative environmental impacts of its products and services throughout their entire life cycle.

The Supplier is encouraged to implement an Environmental Management System based on international standards such as ISO 14001 or equivalent.

Reduction in greenhouse gas emissions 

ST Digital has committed to following an emission trajectory compatible with the Paris Agreement Ambition    1.5°C     and           recommends     that             its suppliers follow a similar trajectory. The Supplier must track and document greenhouse gas emissions for scopes 1, 2, and if required by ST Digital scope 3, in application of the GHG Protocol or other equivalent standards and endeavour to establish an emission reduction target. These elements, along with other information relating to the greenhouse gas emissions of the Supplier's products / services, will be communicated to ST Digital upon request. The use of carbon offsets must under no circumstances substitute for actions to reduce greenhouse gas emissions.

Energy Consumption The Supplier must commit to maintaining its own energy consumption at the lowest possible level. It must also offer products and services that generate the lowest possible  energy consumption and greenhouse gas emissions throughout their lifecycle.

Circular economy

The Supplier must develop the use of eco-design and implement the principles of the circular economy throughout the product or service lifecycle: extraction of raw materials, manufacturing, transport, distribution, use, repair, reuse, recycling, and ultimate waste treatment. 

The Supplier must endeavour to offer refurbished equipment and spare parts sourced from the circular economy.

Raw materials

The Supplier must reduce the use of raw materials in its procurement and in the manufacturing of products and packaging. It must promote the use of recycled raw materials. The Supplier shall endeavour to ensure the traceability of minerals and must promote transparency within its supply chain. Where minerals originating from conflict zones are identified, the Supplier must take all necessary measures to limit negative social and environmental impacts and help create responsible trade within the mineral extraction sector. 

The use of critical raw materials — as defined in particular by the European Union — must be avoided or limited as much as possible. The Supplier must promote their substitution or the use of recycled resources.

Information relating to raw materials must be provided upon request by ST Digital.

Product Composition The Supplier must comply with all applicable laws and regulations regarding product composition information, including those relating to hazardous substances and chemical substances such as the REACH regulation, and those relating to electrical and electronic equipment such as the RoHS regulation. It being understood that for the RoHS regulation, the Supplier must apply it regardless of the country of delivery, including in countries outside the European Union.

Waste Management

The Supplier must identify, monitor, and manage waste generated by all of its activities in accordance with applicable regulations. It must minimise the volume of such waste in order to reduce environmental impact. 

It must also comply with ST Digital rules communicated by ST Digital regarding the collection and processing of ST Digital waste, in particular those relating to electrical and electronic equipment (WEEE).

Pollution prevention

The Supplier must avoid all hazardous discharges to the greatest extent possible. The Supplier shall characterise, monitor, control, and treat air, water, and soil pollutants prior to their release.

Environmental permits and reporting

All permits (for example for monitoring discharges), environmental authorisations and registrations must be obtained, maintained, and kept up to date by the Supplier, who must comply with their operational and reporting requirements.

Biodiversity preservation

The Supplier must endeavour to identify and reduce the negative impacts of its activities and the products and services it provides to ST Digital on biodiversity, defined as the diversity of all living organisms, their genes, the ecosystems in which they live, and the interactions between species and with their environments.

Principles relating to Compliance, Ethics and Anti-Corruption   

Corruption and Influence Peddling

The Supplier must refrain from all forms of corruption and influence peddling, or even from actions that could potentially be interpreted as such.

The Supplier may not, directly or indirectly, offer, promise or grant unlawful benefits to national or international public officials or agents, nor to national or international decision-makers operating in the private sector, in order to obtain preferential treatment or a favourable decision in the public or private sector. The same applies to donations, gifts or invitations to business meals or commercial events. The Supplier may not allow itself to be promised or offered benefits and may not accept any if this gives, or is likely to give, the party granting the benefits the impression that it can thereby be influenced in its commercial decisions. Likewise, the Supplier may not solicit benefits.

The Supplier must avoid conflicts of interest that could give rise to corruption risks. 

If the Supplier is also a customer of ST Digital, they must not unfairly benefit from this and must keep purchases and sales strictly separate.   

The Supplier undertakes to, and also requires  its directors, officers, employees, subsidiaries, controlled companies and Third Parties to do likewise, comply with all applicable laws as well as the Compliance Rules and the commitments defined in the "Compliance" article of the Agreement.

The Supplier further undertakes to ensure that the necessary means used for the performance of the Contract by itself, its subsidiaries and Third Parties comply with applicable laws and the aforementioned Compliance Rules.  In order to guarantee compliance with these  laws, Compliance Rules and Principles throughout the term of the Contract, the Supplier shall provide, upon request and at any time, to ST Digital all necessary elements to establish such compliance, and shall immediately inform ST Digital when it becomes aware, or has reason to believe, that it has itself failed, or that a Third Party has failed, to comply with these laws, Principles and Compliance Rules, and of the corrective measures adopted in order to restore compliance with these laws and Compliance Rules.   A significant failure to comply with these laws, Principles and Compliance Rules may result in the suspension and/or termination of the Contract in accordance with its provisions.

Principle of Free Competition 

The Supplier must comply with the rules of free and fair competition in all commercial relationships and must, in particular, not act in contravention of any competition law and/or any antitrust law (law relating to cartels). 

Partnership

All partnership-related measures must comply with applicable legislation.

Political Contributions

The Supplier may not make monetary donations or grant pecuniary benefits to parties beyond what is permitted by law. 

Money laundering

The Supplier must take all necessary measures to prevent money laundering within its sphere of influence.

Confidentiality and  Data Security and Protection The Supplier must comply with all applicable laws relating to data protection, as well as all specific requirements relating to data protection and security set out in the Agreement.

Principle of Auditability and Oversight 

In order to ensure compliance with the Principles throughout the term of the Agreement, the Supplier shall provide ST Digital, upon request and at any time, with all elements enabling such compliance to be established. It shall immediately notify ST Digital when it becomes aware, or has reason to believe, that it has itself failed, or that one of its subcontractors has failed, to comply with its obligation to respect the Principles. It shall take appropriate corrective measures and implement and monitor an improvement plan within the prescribed timeframes, in order to restore compliance with the Principles. 

If not covered by the Agreement, the following shall apply with respect to social, environmental and compliance audits: ST Digital and/or its authorised representative shall have the right to carry out monitoring activities of the Supplier and its subcontractors in order to assess the compliance of the Supplier and the relevant subcontractors with the Principles.

This includes the right for ST Digital and/or its authorised representative to carry out audits including on-site inspections, to conduct questionnaires and interviews with freely chosen workers on the Supplier's premises, at manufacturing sites and/or at other locations where work is performed on behalf of the Supplier. The Supplier acknowledges that ST Digital has the right to request and receive further information (e.g., external or internal CSR maturity assessments) if it deems this necessary. Upon request from ST Digital, the Supplier shall inform ST Digital of the measures taken to ensure compliance with the Principles.

 Free whistleblowing principle 

7-    Whistleblowing Mechanism The ST Digital Group has established a whistleblowing mechanism. This mechanism covers corruption, influence peddling, and violations or fraud in the areas of accounting, internal control and audit, as well as serious harm to the environment, human rights and fundamental freedoms, and the health and safety of individuals.