Conflict Materials

Conflict Minerals Policy - Effective 1st May 2018

As a socially responsible company, Connectors & Switchgear Ltd has concern for the well-being of people and communities. We conduct business fairly and ethically, respect human rights, comply with laws and regulations, and follow a rigorous code of conduct.
Connectors & Switchgear Ltd supports the efforts of human rights organisations to end violence and atrocities in Central Africa (the Democratic Republic of Congo (DRC) and adjoining countries.

It has been widely reported that the major driver of this violence is the natural abundance of the minerals, tin, tungsten, tantalum and gold, now referred to as “conflict minerals.” Armed groups fight for control of mines in this region and use forced labour to mine and sell minerals, which in turn funds ongoing violence.

In August 2012, the United States Securities and Exchange Commission (SEC) approved the final rule regarding the sourcing of conflict minerals as defined in the Dodd-Frank Wall Street Reform & Consumer Protection Act, Section 1502. As a result, many companies are now focusing on whether and to what extent their products contain Conflict Minerals and whether such Conflict Minerals come from the Democratic Republic of Congo and the adjoining countries named in the Act.

In support of Connectors & Switchgear Ltd ‘s policy on conflict minerals, suppliers are expected to supply material to Connectors & Switchgear Ltd that are “DRC Conflict-Free”.
Suppliers are expected to adopt policies and management systems with respect to conflict minerals and to require their suppliers to adopt similar policies and systems. We also expect them to establish their own due diligence program to ensure conflict-free supply chains. We will be engaging with our suppliers so that they respond in a timely manner to our request for evidence of compliance.

In the future, our supplier’s willingness to comply with this initiative will be a factor in our sourcing decisions.

In the event Connectors & Switchgear Ltd determines that a supplier’s efforts to comply with this policy have been deficient and the supplier fails to cooperate in developing and implementing reasonable remedial steps, Connectors & Switchgear Ltd reserves the right to take appropriate actions up to and including discontinuing purchases from the supplier.

Anti-Bribery & Corruption Policy

Connectors & Switchgear Ltd is committed to conducting business in an ethical and honest manner, and is committed to implementing and enforcing systems that ensure bribery is prevented. Connectors & Switchgear Ltd has a zero-tolerance for bribery and corrupt activities. We are committed to acting professionally, fairly and with integrity in all business dealings and relationships; wherever we operate in the world.

Connectors & Switchgear Ltd will constantly uphold all laws relating to anti-bribery and corruption in all the jurisdictions in which we operate. We are bound by the laws of the UK, including the Bribery Act 2010, in regards to our conduct both at home and abroad.

We are committed to preventing bribery & corruption within our business and take our legal responsibilities seriously. This anti-bribery policy applies to all employees, consultants, contractors, trainees, agency staff or any other persons associated with us including third parties. Bribery refers to the act of offering, giving, promising, asking, agreeing, receiving, accepting or soliciting something of value or of an advance so to induce or influence and action or decision. Bribery is not limited to the act of offering a bribe. If an individual is on the receiving end of a bribe and they accept it, they are also breaking the law.

Bribery is illegal. Employees must not engage in any form of bribery, whether it is directly, passively or through a third party. They must not accept bribes in any degree and if they are uncertain about whether something is a bribe, gift or act of hospitality they must seek further advice from a Company Director.

Gifts & Hospitality
Connectors & Switchgear Ltd recognises that giving & receiving gifts of hospitality can be part of building normal business relationships or maintaining cordial relations.
The problem arises when the gifts or hospitality are considered to be disproportionate, unduly lavish, extravagant, or can be seen as an inducement or reward for preferential treatment. To avoid any uncertainty all gifts and hospitality (except low value items such as corporate promotional items), including any offers which are declined are entered into a register and regularly reviewed.

Sponsorships & Donations
Connectors & Switchgear Ltd only makes charitable donations, which are ethical and legal under local laws and practices. We do not make payments to political parties, organisations or their representatives. Additionally, no sponsorship or charitable donation will be made if it could be perceived to be a bribe and we have similar expectations of our business partners.
We encourage all employees & associated persons to be vigilant and report any unlawful conduct, suspicions or concerns promptly and without delay so that an investigation may proceed. Confidentiality will be maintained during the investigation to the extent that is practical and appropriate.

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