Supply Chain Policy and Supplier Guidelines

Doing Business with SISTAR

SISTAR is committed to creating mutually beneficial supply base partnerships to assist in delivering to our customers excellence in product quality and service. SISTAR is focused on acquiring products and services from suppliers that share our commitment to quality, innovation, sustainability and customer satisfaction.

SISTAR’ Supplier Guidelines documents the principles, guidelines and expectations for establishing and maintaining a business relationship with SISTAR. SISTAR works within standards set by federal, state, and industry regulations, and is committed to having business relationships with suppliers who share the company’s dedication to conducting business in a legal and ethical manner. We also view our commitment to global citizenship not only as a business responsibility, but also as an opportunity to improve lives around the world. As an extension of our business, we have the same expectations of our suppliers.

Suppliers can contact us to learn more about our requirements, policies and procedures in this section and how to partner with us to meet our goals and fulfill our responsibilities.

Responsible Supply Chain

We strive to conduct our activities in a manner that reflects our Code of Conduct and general business values – which include being a good corporate citizen, dealing fairly in business, behaving ethically, supporting basic human rights and a safe and healthy workplace, doing business in an environmentally responsible manner, and complying with applicable law. We expect our suppliers to adhere to the same high standards and we are committed to ensuring that our supply chain reflects our values and beliefs through our supply chain policy and supplier guidelines. 

Supplier Code of Conduct

We expect all suppliers to comply with SISTAR’ Supplier Guidelines.

SISTAR Supplier Guidelines

Legal Compliance

SISTAR’ suppliers are expected to operate in compliance with all applicable laws and regulations of the countries, states and localities in which they operate. This includes but is not limited to business conduct, product quality, labor and employment practices, health and safety and environmental protection. They are expected to conform their practices to any published standards for their industry, obtain all applicable permits and to operate in accordance with permit limitations and requirements at all times.

Ethics and Business Conduct

SISTAR’ suppliers are expected to behave ethically and with integrity in all business transactions. As such, they shall:

  • Uphold standards for fair business practices including accurate and truthful advertising, fair competition, and antitrust.
  • Prohibit payment of bribes, illegal political contributions, or other illicit payments or methods for any reason, including the waiver of penalties or fines or the receipt of any other special benefits.
  • Safeguard against improper use of intellectual property, including disclosure of confidential or sensitive information, pricing, employee information or patient information.

Quality

SISTAR’ suppliers are expected to meet agreed upon product specifications and quality requirements in order to provide goods and services that consistently meet SISTAR’ needs, perform as intended and are safe for their intended use. These product specifications and quality requirements shall be defined in specification documents such as supply agreements, quality agreements and/or other quality documentation.

Human Rights, Labor and Employment

SISTAR’ suppliers are expected to treat people with dignity and respect. As such, they shall:

  • Not use forced, bonded, indentured or any other involuntary labor.
  • Not discriminate against or harass an individual on the basis of race, color, religion, gender, pregnancy, HIV status, health status, sexual orientation, national origin, age, disability, veteran’s status, marital status, or political affiliation.
  • Not treat or threaten to treat an individual harshly or inhumanely. Harsh or inhumane treatment includes sexual harassment or abuse, corporal punishment, coercion or verbal abuse.
  • Avoid unsafe working conditions by providing sufficient rest periods during the workday and honor agreed upon days off from work and maximum working hours.
  • Pay wages for all hours worked and clearly communicate the wages that employees are to be paid to them in advance of commencing work. Communicate to all employees if overtime is required and the wages to be paid for such overtime.
  • Respect workers’ rights to make informed decisions free of coercion, threat of reprisal or unlawful interference regarding their desire to join or not join organizations.
  • Implement policies and/or procedures to evaluate and address risks of human trafficking (as defined by the United Nations and generally thought of as the recruitment, transportation, transfer, harboring or receipt of persons by threat or use of force, coercion, abduction, fraud, deception, abuse of power or vulnerability, or giving payments or benefits to a person in control of the victim).
  • Take reasonable steps to address and improve the process for responsible sourcing of conflict minerals.

Health, Safety and Well-being of Employees

SISTAR’ suppliers are expected to maintain the workplace and any living quarters used to house employees in a clean, orderly and safe manner. As such they shall:

  • Implement programs to prevent or control employee exposures to workplace hazards including chemical, biological, and physical hazards.
  • Implement programs to manage processes safely and prevent illnesses or injuries.
  • Identify and encourage programs that promote access to health programs that positively impact the health of employees.
  • Identify potential emergency situations, implement preventative measures and be prepared to execute emergency response procedures.
  • Provide occupational health and safety training.

Sustainability and Environmental Responsibility

SISTAR’ suppliers are expected to operate in a sustainable and responsible manner. As such they shall:

  • Work to reduce the environmental impacts of their operations including natural resource consumption, materials sourcing, waste generation, wastewater discharges and air emissions.
  • Prevent accidental releases of hazardous materials into the environment and adverse environmental impacts on the local community.
  • Implement programs to ensure products do not contain restricted or banned materials.

Management Systems

SISTAR’ suppliers are expected to manage their activities systematically in order to maintain business continuity, meet the Guidelines set forth in this document and to improve their operations continually. As such they shall:

  • Demonstrate top management commitment and accountability through policies, objectives, and procedures.
  • Implement processes to control documents and records.
  • Provide resources, including competent personnel and appropriate infrastructure, to ensure conformance to these Guidelines.
  • Implement processes to control the production of SISTAR products and/or materials, manage change effectively and ensure customer requirements are satisfied.
  • Implement processes to manage nonconformity, incident response and emergency situations related to products, business operations/continuity and these Guidelines, including the reporting of certain events to applicable regulatory authorities and SISTAR as appropriate. Provide advance notification of facility/production changes, product changes and/or product discontinuance.
  • Identify and implement improvement actions, including effective complaint investigation, internal audit and corrective action processes.

Transparency and Disclosure

SISTAR’ suppliers are expected to make reasonable efforts to disclose (for example on a website or a publicly available report) topics and goals that are important to the organization’s impact on the environment and social issues. Among the issues that we encourage our suppliers to review and be transparent about are:

  • Energy, Waste and Water Use/Reductions.
  • Employee Health, Safety and Wellness Programs.
  • Community and Human Rights Investments.
  • Responsible Sourcing of Conflict Minerals.

Monitoring and Compliance

Suppliers shall review their operations to ensure their compliance to all applicable legal requirements and their conformance to these Guidelines and/or comparable industry approved standards.

If a regulatory agency, auditor, SISTAR representative or the supplier itself identifies areas of non-compliance, the supplier is expected to develop, document and implement plans to remedy any such non-compliance. SISTAR may engage in monitoring activities to confirm a supplier’s compliance to these Guidelines, including on-site assessments of facilities, use of questionnaires, review of available information or other measures necessary to review supplier’s performance. SISTAR reserves the right to disqualify any potential supplier or terminate any relationship with a current supplier that has failed to conform to these Guidelines.

SISTAR Code of Conduct

We require all employees and agents to comply with SISTAR’ Code of Business Conduct and Ethics. We investigate alleged violations of the Code of Business Conduct and Ethics and take the appropriate action, up to and including termination for employees, and termination of agreements with contractors.

Our policy and efforts

We have initiated a process to comply with the SEC rules.

In particular, we are taking steps to (1) conduct due diligence regarding the origin of any conflict minerals in our supply chain and enhance our supply chain internal controls; (2) strive to eliminate conflict minerals that may be supporting the conflict in the DRC; and (3) notify our suppliers of our policy on conflict minerals and encourage them to make similar commitments and take similar measures.

We are in the process of determining the exposure of our supply chain to conflict minerals mined in conditions of armed conflict and human rights abuses and following an internationally recognized due diligence framework to understand and minimize our risk. However, the global supply chain for these minerals is complex, and tracing these minerals to their sources is a challenge. To meet that challenge, we must rely on the cooperation of our suppliers.

To help us adhere to our policy, implement the tracking process and meet our SEC reporting obligations, we expect our suppliers to respond to our queries about purchased components on a timely basis, including assistance in reaching out to their suppliers when necessary to trace the source of minerals and regular communications with us about supplier’s conflict minerals tracking and tracing efforts.

In addition, we are taking steps to encourage our suppliers to commit to responsible “conflict-free” sourcing to prevent directly or indirectly contributing to armed conflicts and human rights abuses. If conflict minerals are identified in our supply chain, we plan to work with our suppliers to determine if practical conflict-free sources certified under the Electronic Industry Citizenship Coalition and the Global e-Sustainability Initiative (EICC/GeSI) Conflict-Free Smelter Program, are available and work to qualify those sources.

This policy will be regularly reviewed and updated as needed.

Procurement Resources

All suppliers are required to comply with the terms & conditions, standards, and guidelines included in the following documents: Purchase Order Terms and Conditions (US) and SISTAR Supply Agreement. We welcome all potential suppliers who can add value to SISTAR’ products and services and fulfill all requirements on a competitive basis.