Mesco Manufacturing is driven to improve the lives of our customers and the vitality of our communities in all that we do. We are committed to safety, diversity, environmental leadership, social responsibility and ethical business practices in an environment where collaboration, trust and accountability thrive. These fundamental values ensure that the decisions we make today are the right decisions for tomorrow. We expect our suppliers of goods and services to share and adhere to these same fundamental values and apply them to how they do business in the United States and around the world.
This Supplier Code of Conduct describes our expectations in more detail. Suppliers should educate their employees, agents and subcontractors so that they understand and comply with this code as well as their own ethics and compliance guidelines. Noncompliance can alter and potentially lead to termination of Mesco’s business relationship with a supplier.
I thank each of our suppliers for their commitment to these values. The work we do together is critical to our customers and reﬂects directly on Mesco Manufacturing and its commitments. Upholding the highest standards of ethical, social and sustainable conduct is at the core of our relationship.
Mesco Supplier Self Assessment Form
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STANDARDS OF THE SUPPLIER CODE OF CONDUCT
Health and Safety
Safety is our ﬁrst priority. Suppliers must share Mesco’s commitment to providing a safe and healthy workplace by exercising good judgment in work decisions and applying safe work practices (including regulatory and contract-speciﬁc requirements) to all activities. Suppliers must ensure that employees working on Mesco property adhere too general and site-speciﬁc safety requirements, including prohibitions on the use and possession of illegal drugs and alcohol, restrictions on the possession of weapons and support for a violence-free environment.
Environmental Protection and Sustainability
Mesco aspires to be an industry leader in protecting our environment. We are committed to meeting or surpassing all applicable regulatory requirements and enhancing the communities we serve. We actively seek suppliers that share our commitment to protecting the environment. Suppliers must abide by the letter and the spirit of all federal, state and local environmental laws, as well as applicable Mesco policies and procedures.
Legal and Regulatory Compliance
Suppliers must comply with the letter and spirit of applicable legal requirements including those prohibiting bribery, kickbacks, corruption and other unethical business practices intended for the purpose of obtaining an improper advantage. Suppliers must comply with antitrust and fair trade practices laws including the Foreign Corrupt Practices Act. Federal and state commissions have speciﬁc codes and standards of conduct that address discrimination and preferential treatment between companies and their afﬁliates. Mesco and its suppliers must ensure compliance with these codes and standards.
Business Gifts and Courtesies
Whenever a gift or entertainment is offered in the context of a business relationship, there is a risk that it may inﬂuence, or appear to inﬂuence, a business decision. Exchanging modest gifts and courtesies may be acceptable under certain conditions; however, it is never required for doing business with Mesco. Suppliers must never offer or provide personal incentives or rewards to Mesco employees in an effort to inﬂuence a business decision such as a procurement award. Providing cash or a cash equivalent of any kind to a Mesco employee is strictly prohibited.
Conﬂict of Interest
A conﬂict of interest exists when a supplier faces a choice between what is in its best interests (ﬁnancial or otherwise) and what is in the interest of Mesco. A conﬂict may arise if a supplier:
• Employs a Mesco employee or someone with a close personal relationship to a Mesco employee
• Is partially or fully owned or controlled by a Mesco employee or family member
• Has access to Mesco’s proprietary information while providing goods and services to Mesco’s competitors
• Is involved in developing a Request for Proposal (RFP) and seeks to bid on the work covered by the RFP
Suppliers must promptly disclose any potential conﬂict of interest to Mesco for review prior to entering into any business transaction. If a potential conﬂict arises during the business relationship, it must be disclosed promptly after it becomes known.
Child and Forced Labor
• All work must be voluntary and workers shall have the freedom to terminate their employment at any time without penalty, given notice of reasonable length. Workers shall not be subject to any form of slavery or practices similar to slavery, such as the sale and trafficking of children or adults, debt bondage and serfdom and forced or compulsory labor. Please review Mesco’s Child Labor Policy on company website https://mescomfg.com
Migrant Worker Contract of Employment
Written contracts of employment shall be provided to migrant workers in a language they understand, clearly indicating their rights and responsibilities with regard to wages, working hours and other working and employment conditions. Migrant workers shall be provided with their employment contract prior to deployment. The use of supplemental agreements and the practice of contract substitution (the replacement of an original contract or any of its provisions with those that are less favorable) are strictly prohibited.
Accurate, reliable information and records are critical to meeting Mesco’s ﬁnancial, legal and management obligations. Suppliers must comply with generally accepted accounting principles including a system of internal controls to promptly, completely and accurately prepare required reports, vouchers, reimbursement requests and invoices. Suppliers must follow all applicable laws and contractual requirements in creating, maintaining and disposing of records reﬂecting their business dealings with Mesco.
Suppliers must conduct their operations in a socially responsible and nondiscriminatory manner. Suppliers must ensure that their workers who represent Mesco, are assigned to Mesco facilities and interact with Mesco employees do not engage in behavior that intimidates or harasses others. All Mesco suppliers must comply with the letter and spirit of applicable
U.S. and international labor and employment laws including those associated with equal opportunity, immigration, child labor, forced or compulsory labor, working hours, wages and beneﬁts, freedom of association and a harassment-free work environment.
Suppliers must use Mesco resources responsibly and only for legitimate business purposes. Mesco resources include company facilities, equipment, systems, technology assets, information and ofﬁce and ﬁeld supplies. Suppliers cannot use Mesco’s name or logo, trademarks or other intellectual property without the express written consent of the company.
Intellectual property rights of third parties will always be honored. Suppliers and their employees also are prohibited from using Mesco resources or facilities to solicit or distribute information or materials not connected with regular Mesco work.
Any information provided to suppliers by Mesco, including employee and customer information, must be managed in compliance with Mesco’s policies and requirements, particularly privacy and IT security requirements, as well as applicable laws and regulations. Conﬁdential information can only be shared within your company on a need-to-know basis. Suppliers cannot share Mesco’s conﬁdential information with third parties without express written permission.
Supplier Selection and Diversity
Mesco is committed to fair and ethical dealings in bid evaluation, negotiation, award decisions and the administration of purchasing and sourcing activities. The company recognizes that a strong, diverse supplier community is essential to economic vitality and proactively seeks opportunities to conduct business with competitive, diverse suppliers. We expect our business partners to seek, use and develop diverse suppliers while performing work on our behalf.
Compliance with this code is mandatory for suppliers, their subcontractors and all non-employee workers providing services for or on behalf of Mesco.
We reserve the right to conduct investigations and audits, including supplier site visits, to verify that a supplier’s business operations meet the expectations outlined in this code. Suppliers and their employees must cooperate in the event of an audit or investigation. Deﬁciencies may result in a request to remove a worker from a Mesco site, a remediation plan or termination of the business relationship.
Suppliers, their employees or their subcontractors must report actual or suspected noncompliance with this code by Mesco employees or suppliers. Reports may be made by:
• Notifying your Mesco representative
• Sending a letter to the Mesco Manufacturing, 900 Randall Street, Greensburg, IN 47240
• Sending an email to Mesco’s Ethics Ofﬁce at ethicsofﬁcer@mescomfg.com
• Mesco’s Whistleblower reporting at http://mescomfg.com/whistleblower.html
• We encourage open discussion regarding any questions or concerns about this code or in our business relationship. Suppliers may direct any questions or concerns to the contacts listed above.
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