This Code of Conduct (“Code”) applies to all current and future suppliers of Cuscaden Peak Investments Private Limited and its subsidiaries and related corporations (“CPI Group”), and conveys the expectation for suppliers to adhere to the highest ethical standards when conducting business.
A supplier refers to any individual or business that supplies goods or services to any part of the CPI Group’s business, and includes all persons employed by the supplier, as well as sub-contractors and service providers engaged by the supplier.
It is the responsibility of the supplier to ensure its employees and representatives understand and comply with this Code. Failure to adhere to the Code may be grounds for the CPI Group to terminate the supplier relationship, depending on the circumstances and the seriousness of the violation.
1. Compliance with Laws and Regulations
Suppliers undertake that they will comply with all laws and regulations that apply to them in the countries that their operations are based, and where they provide goods and services to the CPI Group.
2. Ethical Dealings
Suppliers commit that all their business dealings are handled with integrity, transparency and honesty. No form of fraud, corruption, bribery, extortion or other behaviour involving improper benefits will be tolerated. Any situation that has actual, perceived or potential conflicts of interest must be disclosed to the CPI Group.
Suppliers will not offer to any employee of the CPI Group any gifts, inducement or reward that may influence business decision or create the appearance of influencing any business decision other than that specifically documented in a signed contract or terms and conditions of the business arrangement.
Suppliers and those acting on their behalf will remain free from conflicts of interest that may adversely influence their business relationship with the CPI Group. Suppliers commit to disclose any potential conflicts of interest promptly to the CPI Group.
Suppliers must respect the CPI Group’s intellectual property, trade secrets and all other confidential, proprietary or sensitive information, and may not use or disclose any such information except in accordance with the terms of their contract with the CPI Group, and for the benefit of the CPI Group.
4. Competition / Anti-trust
Suppliers commit to conduct their business in compliance with all competition laws (known as antitrust laws in the U.S.) applicable to them.
Suppliers shall apply fair standards in their treatment of all their employees, and this entails not subjecting any employee to discrimination based on race, national origin, ethnicity, religion, gender, age, marital status, sexual orientation, disability, or any other reason. Suppliers will comply with all national laws on wages and working hours as well as international standards regarding child labour and minimum age.
6. Health and Safety
Suppliers are required to provide a safe and healthy working environment for all their employees and are encouraged to have in place policies that are designed to promote the general health of employees and prevent work-related injuries and illness.
Suppliers shall comply strictly with local environmental laws and practices, such as those pertaining to waste disposal, air emissions and pollution. Suppliers must endeavour to minimize the impact of their operations on the environment.
8. Industry Practices
The CPI Group will only do business with suppliers that produce, package, store and deliver products in accordance with good manufacturing practices prevailing in their respective industries. Suppliers are expected to provide goods and services that consistently meet required specifications.
9. Personal Data Protection
Suppliers shall comply with the Personal Data Protection Act in Singapore and/or applicable data protection laws in the relevant jurisdiction when collecting, using, disclosing, transferring, storing and/or processing any personal data information that is controlled or owned by CPI Group and to ensure they have equivalent data protection policies and controls in place. In the event of any data breach, Suppliers shall inform CPI Group within 24 hours of discovering the breach.
Suppliers are expected to actively monitor their day-to-day management processes with respect to this Code, as may be amended from time to time.
This Code does not create any binding obligations on the CPI Group.