TRANSPARENCY IN SUPPLY CHAINS DISCLOSURE AND MODERN SLAVERY ACT STATEMENT
At TWG, a subsidiary of Dover Corporation (“Dover”), we are strongly opposed to the use of forced, bonded, involuntary, prison, or indentured labor. At TWG, we are constantly evaluating our business and supply chain to identify, assess, and mitigate various compliance risks, including those related to slavery and human trafficking.
STEPS TO ASSESS AND MANAGE RISKS
The following information describes our company’s efforts to date and our future plans to eradicate slavery and human trafficking from our business and supply chain:
- Training: Our employees are required to complete a range of compliance training programs, including but not limited to mandatory new hire and regular training on Dover’s Code of Business Conduct and Ethics, which addresses the need to abide by wage and hour laws in the jurisdictions in which we do business, and not tolerating employment of children or forced labor, and to refuse to do business with suppliers or third parties who engage in such practices, among other things. We also provide annual training to our employees who have direct responsibility for supply chain management, including employees who work with our suppliers, which focuses specifically on slavery and human trafficking issues and ways to identify, assess, and mitigate, to the greatest extent possible, these risks in our supply chain.
- Supplier Code of Conduct: We have the Dover Supplier Code of Conduct, which addresses our commitment to seek out business partners who share our values, and which specifically requires that our suppliers (a) do not use forced, bonded, involuntary, prison, or indentured labor, (b) do not intentionally source materials from supply chains associated with human trafficking, and (c) take reasonable efforts to assure that their own suppliers do not intentionally source material from supply chains associated with human trafficking. Suppliers are not required to submit certification of their compliance.
- Code of Business Conduct and Ethics: Dover’s Code of Business Conduct and Ethics requires our employees to comply with employment-related laws, including those related to wages, hours, and minimum age requirements. It specifically instructs employees not to tolerate the employment of children or forced labor and to refuse to do business with any suppliers or third parties who do so.
- Accountability and Reporting Mechanisms: We take violations of our Codes very seriously. For example, violations of the Supplier Code may result in termination of the supplier relationship, while violations of the Code of Business Conduct and Ethics may result in termination of employment with Dover. We provide mechanisms for reporting concerns relating to known and suspected violations of the Supplier Code and the Code of Business Conduct and Ethics, which can be used by our employees, suppliers, and others, and anonymously where permitted by local law.
- Diligence, Verification, and Audit: We often require our suppliers to confirm that they adhere and will continue to adhere to our Supplier Code of Conduct. The requirement that our suppliers comply with our Supplier Code of Conduct is included in the terms and conditions of our supplier contracts. Prior to engaging a supplier and periodically during a relationship with a supplier, we conduct diligence from publicly available information (such as checking government watchlists and adverse media) to assess their compliance with applicable laws, regulations and our Supplier Code of Conduct. This verification process is generally conducted by our supply chain team. As discussed in our Supplier Code of Conduct, we require suppliers to coordinate with our requests for inspections, audits and investigations, which we may perform to assess quality and compliance with the Supplier Code of Conduct. These announced audits are generally conducted by our supply chain team. While we are not currently verifying or auditing that all our suppliers comply with local laws regarding slavery and human trafficking, we will continue to assess our supply chain for areas of improvement in eradicating slavery and human trafficking, and will continue to require our suppliers to do the same.
DOVER CORPORATION CONFLICT MINERALS POLICY
Dover Corporation and its Operating Companies (“Dover”) are committed to sourcing components and materials from companies that share our values regarding human rights and social responsibility.
Dover intends to comply with the requirements of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Act”), which aims to prevent the use of Conflict Minerals that directly or indirectly finance or benefit armed groups in The Democratic Republic of the Congo (DRC) or an adjoining country as defined in the Act. “Conflict Minerals” include: columbite-tantalite (coltan) (i.e., tantalum), cassiterite (i.e., tin), gold, wolframite (i.e., tungsten) or their derivatives. The Act requires Dover to perform due diligence with respect to the sourcing of Conflict Minerals and to report annually on its use of Conflict Minerals and origin of such minerals.
Dover suppliers are required to comply with Dover’s Supplier Code of Conduct, which includes requirements relating to Conflict Minerals and responsible sourcing. Relevant suppliers are responsible for passing these same requirements on to their suppliers. We expect our suppliers to implement a process to reasonably assure that the Conflict Minerals contained in the products provided to Dover do not perpetrate human rights abuses in the DRC or an adjoining country.
DOVER CORPORATION SUPPLIER CODE OF CONDUCT
Dover Corporation, its segments, platforms, operating companies and subsidiaries worldwide (collectively, “Dover”) understand that our success depends on our reputation for ethical business performance and performing our jobs honestly, diligently and with integrity, in compliance with all applicable laws and regulations. Consistent with our commitment to conduct business fairly and honestly, we seek out business partners who share in our culture, values and business practices. This Supplier Code of Conduct (this “Supplier Code”) is an extension of the Dover Corporation Code of Business Conduct and Ethics (the “Dover Code,” and establishes the standards for conducting business with Dover.
For the purposes of this Supplier Code, “Supplier” means any company, corporation or other entity or person that sells, or seeks to sell, goods or services to Dover, including the Supplier’s employees, agents, subcontractors and other sub-tier sources.
Supplier is responsible for communicating the contents of this Supplier Code of Conduct to its officers, directors, employees, agents, subcontractors and sub-tier sources who are involved in the procurement and production process related to products and services provided to Dover.
COMPLIANCE WITH LAWS AND REGULATIONS
Dover companies do business throughout the world. Because of Dover’s global presence, a Supplier must comply with all laws and regulations applicable to its business in the countries where it does business, including all laws and regulations relating to each subject matter below. The Supplier must recognize that Dover’s obligations and requirements extend to all countries where Dover does business, and that in some cases, Dover – and its suppliers – are required to conduct business in accordance with the laws of other countries in which Dover operates.
CHILD LABOR AND FORCED LABOR
Supplier will not intentionally source materials from supply chains associated with human trafficking and will take reasonable efforts to assure that its own suppliers comply with this requirement. Supplier must comply with all applicable local laws with respect to child labor. In the absence of such laws or in the event existing laws permit the hiring of a person younger than 15 years of age, the minimum age for employment or work by Supplier will be 15 years of age or the age for completing compulsory education in that country, whichever is higher. Supplier must not use forced, bonded, involuntary, prison or indentured labor.
WAGES AND WORKING HOURS
Supplier must comply with all applicable local laws with respect to wage and hour laws, including those relating to minimum wages, overtime hours, and other elements of compensation, and will provide all legally mandated benefits. Supplier will not require employees to work more than the maximum number of hours permitted under applicable laws.
FREEDOM OF ASSOCIATION
Supplier must respect workers’ rights to associate freely, in compliance with existing local laws and without intimidation, reprisal or harassment. Workers’ rights under local laws to join labor unions, seek representation and/or join worker’s councils should be acknowledged by Supplier.
Supplier must not discriminate against any worker in its hiring and employment practices based on race, color, religion, disability, national origin, gender, sexual orientation, marital status, age or other characteristic protected by local law. Supplier must not discriminate against any worker based on political affiliation or union membership in its hiring and employment practices. Supplier will not require a pregnancy test prior to employment or otherwise require workers or potential workers to undergo medical tests that could be used in a discriminatory way, except where required by applicable laws, or where prudent for workplace safety.
Supplier will treat its workers with dignity and respect. Supplier will maintain a workplace free of harassment and discrimination and shall not threaten workers or subject them to harsh or inhumane treatment, including sexual harassment, sexual abuse, corporal punishment, mental or physical coercion or verbal abuse.
HEALTH AND SAFETY
Supplier will conduct its operations in compliance with applicable health and safety laws and regulations and provide its workers with a safe and healthy work environment. Where Supplier also provides accommodations for its workers, such accommodations shall be appropriate for its location and be clean, safe and, at a minimum, meet the basic needs of its workers.
Supplier will comply with all applicable environmental laws, regulations and standards and minimize any adverse impact on the environment. Supplier must endeavor to conserve natural resources and energy, and reduce or eliminate waste and the use of hazardous substances.
WARNING: This product contains chemicals known to the State of California to cause cancer and birth defects or other reproductive harm.
For more information: www.P65Warnings.ca.gov
Supplier will cooperate in due diligence requests made by Dover with respect to the origin of intermediaries associated with the purchases of materials or products containing Conflict Minerals, whether or not those materials or products may have been mined or produced in the Covered Countries or obtained from recycled sources, in compliance with Dover’s reporting requirements under the US Dodd-Frank Section 1502. Where specified in a purchase order or supply agreement, Supplier will comply with any Dover requirement to provide products, components, parts and materials which are free of Conflict Minerals mined or produced in the Covered Countries in support of armed conflict in the region.
“Conflict Minerals” are tin (Cassiterite), tungsten (Wolframite), tantalum (Columbite-tantalite or coltan) and gold, and the derivative metals from these minerals.
The “Covered Countries” are the Democratic Republic of the Congo, Angola, Burundi, Central African Republic, The Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda and Zambia.
FAIR DEALING AND COMPETITION LAWS
Supplier will not engage in collusive bidding, price fixing, price discrimination or other unfair trade practices in violation of applicable antitrust or competition laws. Supplier will uphold fair business standards in advertising, sales and competition.
PROTECTION OF INTELLECTUAL PROPERTY
Supplier must respect intellectual property rights, including patents, trademarks, copyrights and process designs, and safeguard Dover’s confidential and proprietary information. Any transfer or sharing of technology or know-how must be done in a manner that protects intellectual property rights and is in compliance with local laws, including export laws, concerning data privacy and security.
DATA PRIVACY AND SECURITY
Supplier will comply with all local laws concerning data security and privacy, and will protect and safeguard data provided by Dover, which may include private and sensitive personal information. Any transfer or sharing of data must be done in a manner that protects such information from inadvertent or unauthorized disclosure and any disclosure must be in compliance with local laws.
Supplier is prohibited from engaging in any corruption, extortion or embezzlement, in any form. Supplier must comply with all applicable anti-corruption laws and regulations of the countries in which they operate, the U.S. Foreign Corrupt Practices Act, the UK Anti-Bribery Act, the OECD Anti-Bribery Convention and any international anti-corruption conventions. Supplier will not offer or accept bribes or employ other means to obtain an undue or improper advantage. Bribes, kickbacks, facilitating payments and similar payments to government officials or to Dover employees or agents acting on Dover’s behalf are prohibited. Dover employees are discouraged from accepting gifts or entertainment from suppliers, including gifts or entertainment of nominal value. When business meals are appropriate to further business relationships, those meals may not be extravagant in nature.
Each Dover business is required to maintain a register of gifts and hospitality received and offered.
MONITORING AND RECORD KEEPING
Supplier must maintain all documentation necessary to demonstrate its compliance with this Supplier Code and provide Dover with access to those documents upon Dover’s request for review. Neither Dover nor any of its affiliates or authorized agents assumes any obligation or duty to monitor or ensure compliance with this Supplier Code. Supplier is solely responsible for compliance with this Supplier Code by its officers, directors, managers, employees, representatives and agents.
VIOLATION OF THIS SUPPLIER CODE
If a Supplier violates any of the requirements contained in this Supplier Code, Dover may immediately terminate its supply relationship with that Supplier. Violations of this Supplier Code should be reported to one of the following two confidential options:
- By Telephone: 1-800-495-1775 (within the United States). For telephone instructions from locations outside the United States, visit www.thedoverhotline.com for a list of available telephone numbers;
- By Internet: www.thedoverhotline.com
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