Code of Conduct | SBPLINDIA

SUPPLIER CODE OF CONDUCT

1. Scope

This Supplier Code of Conduct defines how Sundarban Chemicals Pvt. Ltd. (SBPL) and its affiliated companies expect suppliers to conduct themselves ethically and responsibly. For the purposes of this Code, the term “Supplier” includes all natural and legal persons that provide goods and/or services to SBPL.

The principles in this Code are binding for all SBPL suppliers. We expect suppliers to take appropriate measures to ensure their subcontractors and partners also comply with these principles.

2. Lawful Behavior

Compliance with all applicable laws and regulations is of the highest priority for SBPL. Suppliers must comply with the legal and regulatory requirements of the countries in which they operate when conducting business activities.

3. Corruption and Bribery

SBPL maintains a zero-tolerance policy towards corruption, bribery, kickbacks, or facilitation payments. Suppliers must not grant, request, or accept inappropriate or unlawful benefits, regardless of the form. Influence on decision-making through improper advantages is strictly prohibited.

4. Human Rights

Suppliers must respect the dignity and rights of every human being and uphold internationally recognised human rights and labour rights as set out in UN treaties and ILO conventions. Suppliers must not engage in forced labour, human trafficking, modern slavery, or child labour. If violations are identified in their supply chain, suppliers must act promptly to address and end them.

5. Labour and Social Standards

SBPL places the highest importance on occupational health and safety. Suppliers must provide safe and healthy working conditions, prevent workplace hazards, and comply with local labour laws, including those on wages, working hours, and benefits. Suppliers must ensure a respectful, inclusive, and non-discriminatory workplace.

a) Women’s Protection and POSH Compliance

Suppliers must comply with the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 (POSH Act) and ensure that women are protected against any form of harassment, discrimination, or unsafe conditions in the workplace. They must establish an Internal Complaints Committee (ICC), provide awareness training, and guarantee fair and confidential grievance handling.

b) Equal Opportunity and Equal Pay

Suppliers must ensure equal opportunity in recruitment, training, promotion, and all other employment practices. Discrimination based on gender, caste, religion, age, disability, or marital status is prohibited. Suppliers must provide equal pay for equal work regardless of gender or any other protected characteristic, in compliance with the Equal Remuneration Act, 1976 and relevant labour laws.

c) Inclusive and Respectful Work Environment

Suppliers must promote diversity, inclusion, and dignity of all employees, ensuring policies and practices are aligned with the principles of fairness, respect, and non-discrimination.

6. Money Laundering, Tax Evasion, and Financing of Terrorism

Suppliers must ensure that their business activities fully comply with laws combating money laundering, tax evasion, and financing of terrorism. Suppliers must verify the integrity of their business partners and only accept funds from legitimate and traceable sources.

7. Foreign Trade and Customs Regulations

Suppliers must comply with all applicable export control laws, embargoes, sanctions, and customs regulations. Suppliers must ensure that their managers and employees understand and follow these obligations.

8. Conflict of Interest

Suppliers must avoid conflicts of interest or situations that could create the perception of a conflict in their dealings with SBPL. Any unavoidable conflict of interest must be disclosed transparently to SBPL.

9. Environment and Sustainability

Suppliers must strive to reduce their environmental impact and adopt sustainable practices. This includes efficient use of resources, minimising waste and emissions, and ensuring environmentally responsible production methods. SBPL encourages suppliers to continually improve their environmental performance.

10. Antitrust, Competition, and Intellectual Property

Suppliers must comply with all competition and antitrust laws. They must not engage in anti-competitive agreements such as price fixing, market sharing, or bid rigging. Suppliers must also respect intellectual property rights and must not participate in infringement of third-party IP.

11. Protection of Trade Secrets, Data Protection, and Data Security

Suppliers must protect SBPL’s confidential information and trade secrets against unauthorised disclosure or misuse. Personal data must be handled responsibly, securely, and only for lawful purposes.

12. Keeping of Records

Suppliers must maintain accurate, complete, and transparent business records in line with applicable laws. All statutory retention obligations must be observed.

13. Audit Rights vis-à-vis Suppliers

SBPL reserves the right to conduct audits—announced or unannounced—of its suppliers to verify compliance with this Code. Audits may include reviewing production, labour, and environmental practices. Suppliers are expected to cooperate fully and transparently.

In case of non-compliance, SBPL will work with the supplier to implement corrective measures. Persistent or severe violations may lead to termination of the business relationship.

14. Whistleblower Protection

Suppliers must provide employees and stakeholders with access to secure and confidential reporting mechanisms for legal or ethical concerns. Suppliers must ensure that whistleblowers are protected from retaliation.