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Standards of Conduct
Standards of Business Conduct
This document sets out Tropix Capital Management LLP’s (D.B.A. Tropical Research Services) and its affiliated entities’ Standards of Business Conduct.
Specifically, in this document, ‘we’ refers to the affiliated entities of Tropical Research Services, which includes all controlled entities and businesses (including, but not limited to, Tropical Commodity Analysts Ltd, Tropix Capital Management (UK) LTD, Tropix Capital Management LLC and TRS’ network of exclusive consultants). These Standards of Business Conduct apply to all Tropical Research Services’ partners, officers, employees, our exclusive consultants, their employees and consultants, (together our “People”), around the world.
Tropix Capital Management LLP,
D.B.A Tropical Research Services,
8, Woodland Way,
Purley, CR8 2HU,
UK.
01 MAY 19 Standards of Business Conduct | Tropical Research Services
Message from the Partners
Tropical Research Services is committed to sustainable and ethical business practices.
Our Standards of Business Conduct policy aims to support responsible growth. It helps us to act decisively to limit the impact of our operations on the environment, to provide our clients with research and data of consistently high quality and to embed ethical principles within our operations worldwide.
The program has four areas of focus: Environment, the Integrity of our research and data, Workplace, and Society. Each of these is key to running our business in a responsible fashion.
The foundation of these Standards of Business Conduct lies within our culture and values. We are committed to doing business ethically, and we will not compromise on our obligations to our clients, our People, the environment and the communities in which we work.
Sean Diffley Partner
Steve Wateridge Partner
Message from the Partners 2
Table of contents 3
Our values 4
Interaction with stakeholders 5
How we make decisions 6
Our Standards of Business Conduct 7
PEOPLE, PRODUCTS & SAFETY
Protecting the Environment 8 Sustainability 8 8
Workplace Environment 8 Compensation &
Benefits 8 Equal Employment Opportunity 8 Privacy of our People 9 Development of our People 9
9 Labor Standards 9 Human Rights 9 Child Labor 9 Community Support 9
FAIR OPERATING PRACTICES 10
Competition Laws 10 Corruption 10 Conflicts of Interest 10 Gifts and Entertainment 11
Involvement in The Political Process 11 National & Local Laws 11
(INTER)NATIONAL OPERATIONS 12
Marketing & Selling 12 The Integrity of our Research and Data 12 Partners & Suppliers 12
Representatives & Agents 12
PROTECTING INFORMATION & ASSETS 13
Protecting Information of Others 13 Protecting our Assets 13 Accuracy of Records 13
COMMUNICATIONS 14
External Communications 14 Internal Communications 14 Internet, Email & Computer Networks 14
Notes 15
How we comply 16
Index 17
Contact information 18
Our values define who we are. They are the fundamental beliefs that determine our actions and guide our behavior. They influence the way we communicate and collaborate, and define the way we engage with our clients, partners and communities.
Respect
We recognize each other’s differences, valuing the rich diversity of our workforce and our clients. We seek out alternative views and value all contributions, aiming to build positive and long- lasting partnerships based on trust and respect.
We seek to protect the environment and enhance the prosperity and wellbeing of the communities in which we work. We collaborate and communicate openly and honestly.
Integrity
We create partnerships built on teamwork, trust and reliability. We challenge what we believe to be wrong and champion fair, honest and ethical business practices.
We operate robust risk management and we keep our social and environmental responsibilities at the core of what we do.
Meritocracy
We believe that we will be successful if we have motivated People who receive fair rewards for their efforts. Our People have an equal opportunity to build a long-term career at Tropical Research Services. An individual’s progression and reward are based on achievements and ability, not position or status. Leadership is selected based on track record and the capacity to develop others.
Client focus
We strive to build lasting partnerships with our clients and aim to exceed their expectations by creating additional value.
We are a reliable, innovative and flexible counter party wherever our clients choose to work with us.
We are ‘as good as our word’ and can be trusted to provide our research and data deliverables, timely.
Our capacity to provide research and data of high quality, based on deep commodities and economical expertise, is valuable to our clients as they seek to maximize their own profitability and mitigate complex and global risk factors.
Entrepreneurship
We act upon opportunities, creating and championing new research ideas and hold ourselves accountable for their success.
We constantly seek ways to be more efficient and competitive, challenging the status quo. We create new ideas and build solutions that inspire others to do the same.
We take responsibility for turning our ideas into reality, we learn from our mistakes and are determined to improve and succeed.
Tropical Research Services exists because of its stakeholders. We engage in dialogue with our stakeholders on a variety of subjects and are informed by their needs.
Our clients
We provide research and data of consistently high- quality at competitive prices. We will deal lawfully and ethically with our customers.
Our People
We will treat our People fairly and with respect. We are committed to providing safe and healthy working conditions and an atmosphere of open communication.
We are an equal opportunities employer.
Our suppliers and partners
We will deal fairly with our suppliers and partners and will strive to build long-lasting business relationships based on mutual trust and respect.
Our shareholders
We will work to provide a consistent return to our shareholders. We will protect the value of their investment through careful use of corporate resources, and by meeting the highest standard of legal and ethical conduct in all our business dealings.
Our competitors
We will compete fairly, based on the merits of our competitive products and services.
Our communities
We will be a responsible business in the communities in which we work around the world.
We will comply with all national and local laws and will work to improve the well-being of the communities where we work.
These Standards of Business Conduct apply to all Tropical Research Services’ partners, officers, consultants and employees (together our “People”) around the world.
Each of our People is personally responsible for complying with these standards.
Our reputation and profitability ultimately depend on the actions of our People and our representatives all over the world.
As well as setting out rules that govern our actions, these Standards of Business Conduct express our values and represent a framework for decision-making.
The principles that govern our actions are:
• We will obey the law
• We will act in good faith
• We will consider the impact our decisions have on our stakeholders
• We will communicate openly with stakeholders
• We will act with integrity
If any individual is in doubt of what constitutes acceptable practice or behavior, they should refer the matter to their direct supervisor or any senior manager.
We are committed to being a responsible member of the communities in which we work and to engage in dialogue with our various stakeholders.
We respect the United Nations’ Universal Declaration of Human Rights and International Labor Standards. This means that we strive to ensure that all our People experience a healthy and safe workplace. We do not discriminate in our employment practices, do not use child or forced labor, and we respect the rights of all our People.
Where we operate around the world, we actively work to protect the environment by providing guidance regarding good crop husbandry to farmers in a wide variety of territories.
We comply with the law and have a policy of zero tolerance towards corrupt practices. As well as our own commitments, we also expect direct suppliers to comply with our Standards of Business Conduct.
Tropical Research Services’ Standards of Business Conduct set out our minimum expectations for ethical behavior and provide guidance on what is and what is not acceptable.
*Note - Minimum legal requirements relating to conduct, finance and working practices, including provisions of the US Foreign Corrupt Practices Act of 1997 and the UK Bribery Act of 2010, apply to us. Although the exact details of similar national and international laws may differ from country to country, in these Standards of Business Conduct we provide the overarching principles to ensure our People comply with relevant laws and regulations.
People, products and safety
1 Protecting the environment
We will perform our work around the world in a way that protects the natural environment.
We aim to meet local environmental regulations and industry best practice and will monitor whether we are doing so. We will get all the permits we need and comply with the terms of those permits. If there are no relevant environmental regulations or the ones that apply are of a lower standard than our environmental policy, we will comply with our environmental policy.
We will take a preventative approach to environmental challenges. We will do the following;
• Assess environmental risks and ensure they are eliminated or reduced to an acceptable level.
• Encourage the adoption of environmentally friendly technologies.
• Support new projects or products which are environmentally sustainable.
2 Sustainability
When appropriate we participate in social and environmental sustainability initiatives around the world.
3 Workplace environment
We are committed to providing a workplace that is free from known health and safety risks, and a work environment that is free from discrimination, harassment and unethical behavior.
All parts of our business will aim to make sure that our People comply with all relevant laws and regulations on possessing or using alcohol, drugs, and other controlled substances.
4 Compensation and benefits
We attract, motivate and retain competent, dedicated People, by providing competitive compensation and benefits.
We believe that people engagement and a positive work environment are equally as important as reward.
We are committed to being a meritocratic organization and strive to provide opportunities to talented people throughout the network, rewarding those who deliver results and contribute constructively to our distinctive culture and values.
5 Equal employment opportunity
We support initiatives that promote a diverse workforce.
We treat our People with respect at all levels of the organization.
We respect our Peoples’ interests and will provide equal opportunities for all our People without discrimination, regardless of race, color, national origin, gender, marital status, disability, religious or political beliefs, age or sexuality.
*These Standards of Business Conduct are not designed to replicate all Human Resource policies. For full information on all policies and procedures that relate to your employment speak to your manager.
6 People privacy
We respect the privacy of our people and comply with relevant laws that apply in all locations where we collect, process, or lawfully release personal information regarding our People.
We are not concerned about the behavior of our People outside work unless their behavior affects their performance at work or affects our corporate reputation or legitimate business interests.
7 People development
We promote development of our people by helping people improve their work-related skills.
We offer a variety of training and development opportunities.
8 Labor standards
We support and respect the principles of the ILO Declaration of Philadelphia (the principles) that labor is not a commodity.
The need to protect workers’ basic rights is reflected in the Universal Declaration of Human Rights and the International Covenant on Economic, Social and Cultural Rights.
The principles include the right to earn a living by freely chosen work, and the right to fair and favorable conditions of work.
Although labor laws and practices will vary from country to country, we support the principles by:
• complying with national, state and local laws relating to labor
• making sure working hours are reasonable and comply with national working-time regulations
• providing clear terms of employment
• paying at least local minimum wages
• developing our Peoples’ skills through education and training programmes
• making sure there is an effective grievance procedure in place; and
• ending agreements with suppliers who abuse the business’s labor standards.
9 Human rights
We support and respect the human rights of both our People and local communities who may be affected by our businesses.
We ensure we are not involved in human-rights abuses. We do not tolerate corporal punishment and physical oppression. When we rely on security staff, we have appropriate standards of conduct and controls in place for them. In addition, we make sure we consult so that local communities can express any concerns.
We allow freedom of association (a person’s right to join or leave a group) and recognize the right to collective bargaining (allowing a group of employees to negotiate wages and other employment terms).
We will ensure that all our People are employed of their own free will.
10 Child labor
We respect the ILO convention on child labor and children’s right to an education. We also support the ending of harmful child labor. The following applies to all the People in our organization.
11 Community support
We support organizations helping communities in which we work. We also support community and charitable projects and encourage our People to get directly involved.
Fair operating practices
12 Competition laws
We comply with competition laws (also known as antitrust laws) of every country in which we operate. We also avoid communicating with our competitors about marketing and selling products and services. For example, we will not exchange or discuss prices or any other commercially sensitive information such as costs, profits or marketing strategies
13 Corruption
Corruption is the abuse of power for gain. Corruption can take many forms. Examples include: bribery (asking for, offering or accepting a bribe in money or for anything of value) involving an executive, official, or employee of any customer, government, or its agency, political party (including candidates for political office), or other organization intended to influence Tropical Research Services’ business; conflict of interest; fraud; money laundering; embezzlement (stealing or misusing money held by the company); concealment and obstruction of justice; and trading in influence.
We believe that corruption damages our effectiveness and reputation and can lead to us being prosecuted. It can also distort fair competition, distribution of wealth and economic growth.
Tropical Research Services works against corruption in all its forms, including extortion and bribery and operates a strict policy of zero tolerance. There are significant personal consequences, including civil and criminal penalties, associated with violating a country’s anti-corruption laws.
Civil penalties for violations of the U.S. Foreign Corrupt Practices Act can include fines up to
$500,000.00. Criminal penalties can exceed
$200,000.00 and may include imprisonment for up to five years. Penalties for violating the UK Bribery Act include an unlimited fine, imprisonment for up to ten years, and debarment from U.K. and EU government contracts.
We will not accept, offer or pay any bribe. We comply with our rules on gifts and entertainment, support a clear, honest system of payment and operate a clear whistle-blowing policy.
Note: Also see SBC Supplement ‘Whistle-Blowing Policy’
As part of our preventative program of bribery and corruption, training to our People is provided and mandatory. People with questions about this, or any other section of the TRS Standards of Business Conduct and its supplementary materials may also contact compliance@tropicalresearch.com, at any time. To ensure compliance with relevant laws, Tropical Research Services may conduct internal audits or arrange for them to be conducted by a third party.
14 Conflicts of interest
Our People must be loyal to us and deal with suppliers, clients and others in a way that avoids even the appearance of a conflict between personal interests and our interests. Possible conflicts of interest include the following;
• Having a financial stake in our suppliers, customers, or competitors
• Asking for, or accepting gifts or any form of compensation, from suppliers, customers or others doing business, or wanting to do business, with us (see clause 15, “Gifts and entertainment”)
• Being a director of, being employed by or doing voluntary work for another company or organisation (unless approved in writing)
• A transaction between us and one of our board members, executive officers or significant shareowners, or a transaction between us and an immediate family member of one of our board members, executive officers or significant shareowners
• The personal use of corporate assets (including, for example, property, business information, private information or business opportunities)
Actual and potential conflicts of interest must be reported to one of the Partners. If you are not sure whether there is a conflict of interest, you can get advice from one of the Partners.
15 Gifts and entertainment
Business gifts that are customary and reasonable in value and frequency are generally allowed.
Our policy is as follows.
• You must not accept any gifts which are or might appear to be excessive in the circumstances.
• You must take reasonable steps to make sure you do not offer or receive business at more favourable rates
in return for any kind of inducement, reward or benefit.
• You must make sure you do not offer any gifts, entertainment, or anything of value which are or might appear to be excessive.
• What is or what appears to be “excessive”, in this context, depends upon the circumstances. But you should consult with your Manager, in writing, before offering or accepting any gift which has, or appears to have, a value exceeding $US200.
• You must make sure that you do not offer gifts, of any kind, to government or public officials, their families, or to political candidates or representatives, of any kind.
You must never offer or accept a gift in exchange for favorable treatment or if the policies of the person receiving the gift, or their employer, prohibit it.
We will not offer or pay any bribe.
Involvement in the political process
We will comply with all national, state and local laws regulating our involvement in political affairs, including limits on contributions to political parties, national political committees, and individual candidates.
Those who contact political parties, candidates, elected officials or governmental officials on our behalf must comply with all laws and Tropical Research Services policies that apply.
We will maintain honest and open relationships with local government officials and political representatives, free from bribery or improper influence.
We encourage our People to be informed voters and to be involved in the political process. Getting involved in political activities, including contributing time or financial support, is a personal decision and will not be influenced by the company. In no way do we discourage employees from participating in the political process in their personal capacity, including the making of voluntary contributions to candidates or parties of their choosing; provided, however, that such political contributions are never conditioned upon any agreement or understanding to take or refrain from taking any governmental action on behalf of Tropical Research Services. Any employee involvement must be on an individual basis on an employee’s own time and expense, and an employee may not use the company’s facilities in connection with political activities, candidates, or parties.
As a matter of policy, Tropical Research Services will not make political contributions domestically or in foreign countries. No political donations are permitted without written approval of the Partners.
16 National and local laws
We are an international network serving global markets conducting business under laws, customs and social standards that differ widely.
We comply with the national, state and local laws of the countries in which we operate. If there is a conflict between the laws of different countries, one of the Partners will provide guidance.
We will not knowingly allow or aid illegal conduct or fraud by others, regardless of local customs.
(Inter)national operations
17 Marketing and selling
We compete in markets around the world based on the quality of our research and data services. We sell our services honestly and will not do business that would require us to act unlawfully or in breach of our Standards of Business Conduct.
When comparing ourselves with competitors, we will avoid making inaccurate statements to criticize a competitor.
Marketing and sales activities, including contractual practices, must comply with local laws. Information about products and services will be accurate and communicated in a way that customers and consumers can understand.
18 The integrity of our research and data
Our reputation is built on the integrity of our research and data. Research and data integrity means conducting research and using data in a way which allows others to have trust and confidence in the methods used and the findings that result.
Within Tropical Research Services, conducting research with integrity also means meeting the professional standards expected of our People; the key elements of which are honesty, rigour, transparency and the care and respect of all participants.
We strive to ensure that our research and data is of a consistently high-quality; delivered timely and accurately to our clients.
19 Partners and suppliers
We buy equipment, products and services based on their quality. We will treat our partners, suppliers, vendors and subcontractors fairly and will not discriminate.
When interacting with local communities we aim to provide opportunities for local businesses to be suppliers and subcontractors, where they meet requirements on safety, environment, quality and human rights.
We only work with suppliers who share our commitment to protecting basic human rights and who understand their social and environmental responsibilities. We ask our suppliers to review and sign our “Suppliers Code of Conduct”
*Note: Also see SBC Supplement ‘Suppliers Code of Conduct’
20 Representatives and agents
All representatives and agents (as well as managers, officers, or employees) working for us, or on our behalf, must comply with these Standards of Business Conduct. We will not use any representative or agent to circumvent our Standards of Business Conduct.
Protecting information and assets
21 Protecting the information of others We respect the legitimate proprietary rights and trade secrets of our customers, suppliers, and third parties. We will not communicate sensitive information garnered from our clients to others, absent their express consent, in writing.
22 Protecting our assets
We have to make sure that our assets, including tangible assets (such as vehicles, money, equipment, GPS and information-technology systems) and intangible assets (such as intellectual property, trade secrets, sensitive research and technical information, proprietary data, and business know-how) are being used properly and as authorized by management. Our assets must not be used for personal gain. All business transactions must follow our processes for internal review and approval.
23 Accuracy of records
All assets, liabilities, revenues, expenses and business transactions must be fully and accurately recorded in our books, records and systems, in good time and in line with relevant laws, accepted accounting principles and our established control standards, financial policies and procedures.
We will never create records that are inaccurate or misleading.
Budget proposals and economic evaluations must fairly represent all information relevant to the decision being asked for or recommended. We will not set up or maintain secret or unrecorded cash funds or other assets for any purpose.
We will inform clients and suppliers if we make any mistakes and promptly correct the matter.
All records maintained by Tropical Research Services will be retained for at least five years from the time a respective transaction ends. The records will be retained in a complete, legible, orderly, and accessible manner. In addition, any record implicated by a pending government request, internal investigation, or contract dispute will not be destroyed without written authorization from legal counsel.
Communications
24 Communications with our clients
We comply with all laws, rules and regulations relating to releasing research information, including communications to our clients. All research reports and other communications with clients, whether spoken or written, must be full, fair, accurate and understandable. They must also be released in good time. No Tropical Research Services communications will contain investment advice or material non-public information regarding the securities of publicly traded companies.
25 Communications with our People We are committed to communicating with all our People in an open and honest way. We will communicate with our People in ways that encourage them to voice their opinions, ideas and concerns.
27 Internet, email and computer networks
We provide email facilities to our People. We realize that People will occasionally use the email system for personal use, but this privilege must not be abused. Personal use must be kept to a minimum.
Personal use of the internet and email facilities provided must not affect our productivity or resources. We have policies that ban certain types of use of our internet and email facilities. Things that are banned include viewing or transmitting pornographic, offensive or discriminatory information, and downloading or transmitting information that is protected by copyright, such as music and movies. Any material or on-line behavior that is likely to be considered inappropriate or compromise our reputation is prohibited and may be subject to disciplinary action.
These Standards of Business Conduct have been approved by the Partners and apply to all Tropical Research Services’ partners, officers, employees, our exclusive consultants, their employees and consultants, (together our “People”), around the world.
Why our Standards of Business Conduct are important?
We have an enviable reputation within our chosen markets which we are determined to maintain. Tropical Research Services consider these Standards of Business Conduct – as being central to our culture and business strategy.
Potential clients, People and investors value businesses that are ethical, prudent and that demonstrate sound compliance. We consider our Standards of Business Conduct to be vital to this.
We have a culture of openness and respect for our People. We will make sure that our People who raise genuine concerns do not suffer as a result, regardless of the outcome of any investigation.
Complying with these Standards of Business Conduct
These Standards of Business Conduct set out our policies and related procedures, as well as the relevant legal and regulatory framework Tropical Research Services works within.
We will take all reasonable steps to comply with the Standards of Business Conduct and to act ethically. All our People are required to comply with these Standards of Business Conduct.
Managers at all levels are responsible for creating and promoting a culture that supports ethical business practices, encouraging open communication and raising awareness of and commitment to these Standards of Business Conduct.
As a member of the Tropical Research Services’ network, you are required to familiarize yourself with these Standards of Business Conduct and to comply with them, always. These standards provide guidance to help you perform your duties.
You must sign and date the last page of this standard and return it to your Manager.
What happens if I don’t comply with the standards?
Not complying with these standards is considered a serious matter.
• You could be breaking your consultancy agreement or employment contract with us. This could result in disciplinary action being taken against you, Disciplinary action will be agreed and communicated by the Partners.
• Breaches of certain aspects of this code may result in criminal prosecutions against you and other People.
Asking questions and raising concerns
If you have any questions about these standards or how they apply in specific circumstances, ask your manager, or one of the Partners.
If you know or suspect that these standards have been broken, or that there are irregularities in company accounting, internal controls, report this by sending an email to compliance@tropical-services.com. This email address is monitored only by the Partners. If you do this your report will be investigated independently, in a fair and unbiased way. You may also communicate your concerns, anonymously, by writing to the Partners at the registered address of the company, outlined on page 1 of these Standards.
This email address cannot be used for concerns relating to a collective bargaining agreement or concerns restricted by law.
Your identity will be protected unless we must reveal it by law or there appears to be an imminent risk of serious harm.
*Note: Also see SBC Supplement ‘Whistle-Blowing Policy’
Tropical Research Services contact information
Sean Diffley, Partner,
Tropix Capital Management (UK) LLP, 8 Woodland Way,
Purley, CR8 2HU.
Tel: +12036656535/Cell: +19175747073
Steve Wateridge, Partner,
Tropical Commodity Analysts Ltd, 8 Woodland Way,
Purley, CR8 2HU.
Tel: +442086606493/Cell: +447810807024
In all cases an email can be directed to compliance@tropical-services.com This email address is only monitored by the Partners.
By signing below, it is confirmed that you have familiarized yourself with our Standards of Business Conduct and agree to perform your duties in conformity with our Standards.
Company: Date:
Completed By: Signature:
Return to: compliance@tropicalresearch.com
Whistleblowing
Standards of Business Conduct
Whistleblowing
This supplement Whistleblowing is an integral part of Tropical Research Services Standards of Business Conduct
Tropix Capital Management LLP,
B.A. Tropical Research Services,
8 Woodland Way,
Purley, CR8 2HU,
UK.
What is Whistleblowing?
'Whistleblowing' refers to cases where an individual exposes fraud, waste, or abuse within an organization.
For the purposes of this policy, 'fraud, waste, or abuse' is defined as an action that is either;
• Illegal.
• Contrary to policy, regulation, procedure or instructions.
• Likely to endanger service users, members of the public and/ or colleagues.
For example, an action that is in breach of the regulations of the US Foreign Corrupt Practices Act of 1977, or of the UK Bribery Act of 2010, would be considered fraud, waste, or abuse in terms of legality, internal regulation, and procedure, and would also be included in this definition.
We believe in an open, dynamic and responsible culture within the business. We, therefore, welcome the voicing of genuine and serious grievances on actual or perceived breaches of our Standards of Business Conduct. We always expect our People to act within the law, applicable codes of practice and to apply the highest possible operating/business ethics in all areas of their activities.
No employee, manager or consultant in any unit will be criticized for loss of business resulting from complying with our Standards of Business Conduct.
How do I report fraud, waste, or abuse?
In the first instance, you should raise any concerns regarding fraud, waste, or abuse with your line manager or the appropriate manager within the business. If the matter is not resolved through this route, or if you do not feel that this route is appropriate, you should report any suspected fraud, waste, or abuse, in writing, either of the Partners. You may also communicate your concerns, anonymously, by writing to the Partners at the registered address of the company, outlined on page 1 of this supplement to the Standards of Business Conduct.
When is it appropriate to use the Whistleblowing policy?
The Whistleblowing policy is primarily for concerns where the interests of others or of the organization itself are at risk.
Any personal grievance should be reported to your manager, or if you do not feel that this route is appropriate, to one of the Partners.
What will happen next?
The Partner will open an investigation into the issue, involving people appropriate to the allegations. For example, specialized external legal counsel may be involved for an, allegation relating to bribery.
The investigation will be undertaken as swiftly as possible, and corrective action will be taken if fraud, waste, or abuse is uncovered. You will be informed of the findings of the investigation and of any action taken as a result, in as far as confidentiality permits.
Supplier Code of Conduct
Standards of Business Conduct
Supplier Code of Conduct
Tropical Research Services works hard to maintain high standards of business conduct. Our Standards of Business Conduct policy ensures that we comply with the law, but it also demonstrates our core values, our commitment to act in good faith and to hold ourselves accountable.
We are a global business, so we understand that local customs, conditions and business practices may vary – but we must uphold our core values and ethical principles wherever we operate. Our own clients demand this too.
We only work with suppliers who share our commitment to protecting basic human rights and who understand their social and environmental responsibilities. We outline some of our key principles below.
Legal Compliance:
In providing products and/or services to Tropical Research Services supplier complies with all laws, rules and regulations applicable to its activities including, but not limited to (1) the United States Foreign Corrupt Trade Practices Act of 1977, as amended, (2) U.S. Export Administration Regulations, (3) International Traffic in Arms Regulation, (4) USA Patriot Act, as amended, (5) U.S. Treasury regulations, (6) anti-dumping laws, (7) all other U.S., Republic of Germany, and European Union laws and regulations relating to international trade and investment activities, and (8) all relevant national, state and local laws. Supplier shall have in effect all licenses, permits and authorizations that are legally necessary or commercially advisable to its performance hereunder. If Supplier is provided notice, correspondence, subpoena, or other contact that a governmental investigation has been initiated related to its relationship with Tropical Research Services, Supplier shall immediately notify Tropical Research Services in writing of the investigation or inquiry. Supplier agrees to assist Tropical Research Services in responding to or defending against any governmental inquiry into compliance with the applicable laws.
Basic Human Rights:
Supplier complies with the United Nations Universal Declaration of Human Rights, the International Labor Organization core labor standards, Conventions and all applicable laws governing child labor, forced or compulsory labor, human trafficking, discrimination, harassment, freedom of association, and the right to collective bargaining.
Supplier complies with local working time and/or overtime regulations and pays its staff (employees including migrant, seasonal and other contract labor) fair wages and benefits in compliance with local laws and the local labor market
Health & Safety:
Supplier adheres to local health and safety laws, provides a safe and healthy working environment (safe workplaces, safe equipment, hygienic conditions, and continuous access to fresh water and sanitary facilities) and actively minimizes the risks of accidents or injury.
Environment:
Supplier operates in compliance with local environmental laws and regulations. Further, holds, as applicable, all required permits for ensuring a legal operation. If and where applicable, supplier can demonstrate clear title to land and water in accordance with national practice and applicable law.
Ethical Compliance:
Supplier operates in an ethical way, in compliance with antitrust laws and applicable sanction regimes, and is not engaged in bribery, corruption, money laundering or other fraudulent practices. To this end, Supplier will not perform any of the following acts on-behalf of Tropical Research Services: offer or promise to pay, or authorize the payment of, any money, or give or promise to give, or authorize the giving of, any services or anything else of value, either directly or through a third party, to any person, or to any political party,. or official for the purpose of (i) influencing any act or decision of that person in his official capacity, including a decision to fail to perform his or her official functions, (ii) inducing such person to use his influence to affect or influence any act or decision or (iii) securing any improper advantage.
By signing below, it is confirmed that supplier complies with above basic human rights and ethical principles and has in place internal processes and controls to ensure compliance. Tropical Research Services reserves the right to - themselves or via independent third parties - verify compliance at some point.
Supplier: Date:
Completed By: Signature:
Return to: compliance@tropicalresearch.com
1 01 May 2019 Supplier Code of Conduct | Tropical Research Services
Copyright © 2023 Tropical Research Services - All Rights Reserved.
