Supplier Code of Conduct

The purpose of Wescon Controls’ Code of Conduct (“The Code”) for its valued suppliers is to align our business with human rights, labor, environmental, and anti-corruption principles and to go beyond compliance. The Code cannot foresee every situation that might arise; rather, it identifies guiding principles to help you make decisions consistent with Wescon Controls’ core values and reputation.

A Message from Wescon’s President and CEO

Wescon Controls, LLC is committed to conducting business in a fair and ethical manner with a clear focus on our core values. We have a reputation of being honest and fair in the way we conduct ourselves that spans more than 70 years. We seek long-term relationships with all our stakeholders. By applying the Wescon Controls’ “Code of Ethics and Business Conduct”* in our daily work, we help ensure that our business is conducted in a responsible and sustainable way.

I rely on you to ask questions anytime you are navigating an ethical or legal dilemma and to share your concerns anytime you see or suspect a violation of our code. Thank you for committing to act with the highest standards of integrity.

Michael Bright, President and CEO

Our Business Principles

Fairness in All Business Relations

Wescon Controls is committed to fairness in all dealings with business partners and stakeholders. Wescon Controls does not tolerate corruption or bribery in and form. Business decisions are based on the best interests of Wescon Controls without regard to personal relationships or considerations. Employees must not accept gifts, benefits, reimbursements or entertainment, whether directly or through intermediaries, that could affect or even appear to affect, the objectivity and professional judgment of the employee. Likewise, Wescon Controls will not offer rewards or benefits, whether directly or through intermediaries, to any business party or stakeholder, which is, or appears to be, in violation of applicable laws. Wescon Controls competes in a manner that is both ethical and fair, without engaging in any inappropriate activities or unfair trade practices.

Accuracy in Accounting and Reporting

All corporate records must be true, accurate, and complete. Company data must be promptly and accurately entered in our books in accordance with Wescon Controls and other applicable accounting principles.

We will not improperly influence, manipulate, or mislead any unauthorized audit nor interfere with any auditor engaged to perform an internal independent audit of Wescon Controls books, records, processes, or internal controls.

Personal Financial Interest

Employees must never use the association with Wescon Controls for personal gain and shall avoid engaging in external financial interests that might conflict with Wescon Controls interests. Interests to be avoided include personal or family financial interests in any operation of company that has a business relationship with Wescon Controls.

Conflict of Interest

We must avoid any relationship or activity that might impair, or even appear to impair, our ability to make objective and fair decisions when performing our jobs. At times, we may be faced with situations where the business actions we take on behalf of Wescon Controls may conflict with our own personal or family interests because of the course of action that is best for us personally but not also the best course of action for Wescon Controls. We owe a duty to Wescon Controls to advance its legitimate interests when the opportunity to do so arises. We must never use Wescon Controls property or information for personal gain or personally take for ourselves any opportunity that is discovered through our position with Wescon Controls. Employees may not engage themselves, with or without compensation, in activities that might conflict or appear to conflict with Wescon Controls interests, without approval from the employee’s manager

Political and Religious Involvement

Wescon Controls observes strict neutrality with regard to religion, political parties and candidates. Neither the names nor resources of Wescon Controls shall be used to promote the interests of political parties or candidates. Neither the names nor resources of Wescon Controls shall be used to promote the interests of religions, political parties or candidates. Participation in the political process or religion outside of work and during non-working time is admirable. You can make lawful contributions to religious or political activities; however, Wescon Controls will not reimburse you for those activities unless required by law.

Dealing with Confidential Information

Integral to Wescon Controls’ business success is our protection of confidential company information, as well as nonpublic information entrusted to us by employees, customers, and other business partners. Confidential and proprietary information includes such things as pricing and financial data, customer names/addresses, and/or nonpublic information about other companies, including current or potential suppliers and vendors. We will not disclose confidential and nonpublic information without a valid business purpose and proper authorization. Such confidential information must not be passed on to any unauthorized natural or legal person, and this includes family members. This obligation continues even after termination of employment. Employees are not allowed to trade in Suprajit shares or any other kind of property on the basis of so called insider information, i.e. information accessed through work at Wescon Controls and which is not made public.

Human rights and Workplace practices

Respect for the individual

Wescon Controls shall provide equal employment opportunities to all individuals without regard to gender, race, religion, disability, age, sexual orientation, nationality, social or ethnic origin, union affiliation, citizenship, political opinions or any other characteristics protected by applicable law. Physical, psychological, sexual or verbal harassment against any colleague or business partner will never be tolerated.

Health and Safety

Wescon Controls is committed to the health and safety of our employees, customers, team members, communities, and all stakeholders – because we care for one another. Conducting our business in compliance with the health and safety laws is crucial to protecting each other from harm. As a team member of Wescon Controls, always comply with all relevant health and safety laws and policies. By following these, we can create and maintain a safe working environment for our employees, customers, team members, community, and all stakeholders.

Fair employment conditions

Employment terms and wages shall be fair and reasonable. Wescon Controls complies with applicable laws and industry standards on working hours. All employees, including those temporarily employed, should have their employment terms in writing and be made aware of their employment conditions.

Freedom of association

All employees are free to exercise the right to form, join or refrain from joining unions or similar organizations and to bargain collectively or individually.

Forced or child labor

Wescon Controls does not tolerate underage labor in its operations or in the operations of any supplier or other party with whom we cooperate. The minimum employment age is 15 years, or the lawful age for working in the country in question. We do not allow illegal or forced labor in our operations of any parties with whom we cooperate.

The Environment

We are committed to environmental protection and preservation of our natural resources. We’re also responsible for complying with all applicable environmental laws and regulations. This responsibility is one of our core foundations for our environmental sustainability commitment. Our policy is to conduct our business in a socially responsible and ethical manner that protects the environment of our customers, team members and communities.

Where to go for Help and Report Concerns

If you suspect or become aware of unethical or illegal conduct, you are expected to report your concerns to:

The Chief Financial Officer of Wescon Controls

Direct Phone: +1 316-239-3264

Reported violations of the law, our code, and our policies – and the facts and circumstances surrounding such reports – will be reviewed, investigated if appropriate, and treated confidentially to the extent possible under the law and as determined by Wescon Controls. When legally required or otherwise appropriate as determined by Wescon Controls, the Company may report compliance matters, facts and circumstances to applicable government authorities and cooperate with any legal proceedings.

All suppliers must agree to comply with the Wescon Controls Code of Conduct. It is the responsibility of the supplier to require that their suppliers or sub-suppliers also comply with this code of conduct.

Wescon Controls’ “Code of Ethics and Business Conduct” is available upon request




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