Supplier Code of Conduct

Code of conduct for suppliers and business partners of Valiant TMS

This Supplier Code of Conduct articulates Valiant TMS expectations of the conduct of suppliers and business partners doing business with and on behalf of Valiant TMS. Suppliers and business partners are expected to understand and act consistently with the Valiant TMS approach to integrity, responsible sourcing, and supply chain management. Valiant TMS expects that its suppliers will cascade similar expectations through their own supply chains.

Valiant TMS expects to do business with suppliers that meet our standards and behave consistently with and positively reflect Valiant TMS values throughout the supply chain. Valiant TMS chooses its suppliers carefully and expects that they will satisfy contractual requirements, comply with laws, regulations, and act in a way consistent with the principles and values.

1. Value of Business Ethics
   
   1. Bribery and Corruption
      Valiant TMS expects suppliers not to condone the use of bribes, embezzlement, or fraud in any form or other illegal payments in the execution of business activities. No supplier shall accept personal gifts, payment, or favor, which may be believed to influence business transactions.
      
      
   2. Invitation and Gifts
      Valiant TMS employees will not offer or accept any gifts, entertainment, or anything else of significant value from a competitor, customer, supplier, or anyone else who conducts or seeks to conduct business with Valiant TMS. On occasion employees may accept advertising or promotional items of a nominal value up to $50.00 that are widely distributed by the supplier. Symbolic gifts and invitations may be a sign of courtesy or country-specific cultural situation and shall be of low value. Depending on this, no consideration may be paid or expected.
      
      
   3. Money Laundry
      At Valiant TMS, we expect our suppliers to comply with all applicable statutes governing the prevention of money laundering, and not to participate in any money laundering activities.
      
      
   4. Conflict of Interest
      Valiant TMS expects suppliers to avoid conflicts of interest and operate honestly and ethically throughout the supply chain and in accordance with applicable law. Valiant TMS and supplier employees shall not participate in any situation or business activity in which their personal or financial interests may conflict, or appear to conflict, with the goals and objectives of Valiant TMS.
      
      
   5. Fair Competition & Anti-Trust
      Valiant TMS operates within the principles laid down by the domestic and international rules put in place to protect free competition and therefore, in carrying out its business, operates by promoting fair competition. The company recognizes that fair and loyal competition is a key element for the development of the company and the market.

      For the purposes of complying with antitrust legislation, Valiant TMS holds to the following general principles:

      • It defines and pursues its commercial activity in total autonomy with respect to competitors in the marketplace
      • It operates exclusively on the basis of its own strategic and commercial decisions
      • It does not engage in any illicit behavior
   6. Freedom of Association and Collective Bargaining
      When and where applicable, Valiant TMS recognizes the right of External Providers for Freedom of Association and Collective Bargaining.
2. Value of Laws and Regulations
   
   1. Confidentiality of Data and Data Protection
      All Valiant TMS suppliers are required to make a commitment to hold information used or obtained in the course of their duties in strict confidence. The responsibility of maintaining confidentiality lies with the individual entrusted with the information. Implicit in this trust is the expectation that the individual will not divulge information, or gain access to information unless there is a necessity based on job requirements.
      
      
   2. Conflict Minerals
      Valiant TMS expects its suppliers to comply with all applicable legal regulations concerning conflict minerals. If the use of conflict minerals (tin, tantalum, tungsten, gold) cannot be avoided, Valiant TMS expects suppliers to ensure transparency in their supply chain upon request.
      
      
   3. Working Hours and Remuneration
      Valiant TMS expects its suppliers to comply with the applicable national legislation on working hours. It is also expected that the employees of suppliers receive remuneration that is in line with the applicable national laws.
      
      
   4. Counterfeit Parts
      Counterfeit Part is a Fraudulent material that has been confirmed to be a copy, imitation, or substitute that has been represented, identified, or marked as genuine, and/or altered by a source without legal right with intent to mislead, deceive or defraud (Ref: SAE Int’l AS6174A) Valiant TMS expects following from all External Providers (EP) while under contract:
      
      • External Provider shall not deliver Counterfeit Work or Suspect Counterfeit Work to Valiant TMS under Contract.
      • Where applicable under contract, External Provider shall only provide service or products to Valiant TMS directly from Original Component Manufacturer (OCM)/Original Equipment Manufacturer (OEM), or through an OCM/OEM. Other sources may be used only when OCM/OEM sources are not available and formal approval from a Valiant TMS representative has been obtained.
      • External Provider must notify Valiant TMS upon their (External Provider’s) awareness about delivery of counterfeit part/service (including suspected counterfeit part/service) to Valiant TMS and shall provide full cooperation to Valiant TMS for detailed investigation when requested.
      • In the event of counterfeit part/service delivered to Valiant TMS, the External Provider under the contract shall replace the part/service with OCM/OEM provided part/services or genuine part/services at External Provider’s own expenses (including removal, transportation, and replacement of counterfeit part/service).
3. Value of Human and Employee Rights
   
   1. Child Labor
      Valiant TMS expects its suppliers to prohibit and refrain from any form of child labor in their companies. Valiant TMS also follows this principle.
      
      
   2. Forced Labor
      Valiant TMS does not utilize practices involving the use of forced labor and we will not knowingly do business with companies that do. Valiant TMS requires that all employees entering into employment with the company or our suppliers do so of their own free will.
      
      
   3. Discrimination
      Valiant TMS expects suppliers not to discriminate on the basis of gender, color, race, national origin, religion, sexual orientation, age, veteran status, disability, or gender identity. Harassment or discrimination of any kind will not be tolerated.
      
      
   4. Occupational Health and Safety
      Valiant TMS expects suppliers to provide clean, healthy, and safe environments for their employees that meet or exceed legal standards, with safety procedures for their employees and a goal of zero workplace safety incidents.
      
      
   5. Whistle Blowing & Protection Against Retaliation
      External Provider Business Partners or Valiant TMS Team Members who report prohibited conduct as listed in Valiant TMS Global Business Ethics Policy and Supplier Code of Conduct will be protected from retaliation of any kind.

      Disciplinary action will be taken against anyone who attempts such retaliation. Full cooperation by all External Provider Business Partners and Valiant TMS Team Members is necessary for Valiant TMS to accomplish its goal of maximizing the safety and security of all personnel.

4. Value of Environmental Protection

Valiant TMS expects External Providers to fully commit themselves to protect the environment and continually strive to improve their operations (including responsible chemical management), products, and services to minimize impacts on the environment. Compliance with the applicable legal environmental regulations is considered mandatory. In addition, our suppliers are asked to increase efficiency throughout their companies and take measures to reduce their carbon footprint, energy use, water use, wastes, and other emissions.