Maintaining the highest standard of ethics is Technimark’s corporate policy and has always been an integral part of the Technimark culture. Our reputation for ethical business practices is one of our most valued assets. We build our business based on the core principles of honesty, integrity and loyalty. We also expect our business partners to operate under the same principles.

Our Supplier Social Responsibility Policy sets forth the specific standard of business conduct that we require of our business partners.

1. Compliance With Applicable Laws
Suppliers must comply with all applicable laws and regulations of the jurisdictions in which the suppliers are doing business, including but not limited to those related to labor, immigration, health and safety, the environment and any other applicable U.S. laws. In particular, suppliers will adhere to the laws and regulations of the countries of manufacture and distribution pertaining to product design, manufacture, packaging, labeling, and importation. Commercial invoices and other necessary documentation must be provided in compliance with applicable laws.

2. No Forced Labor
Suppliers must not use forced labor in any form – prison labor, indentured labor, bonded labor or otherwise. Suppliers shall not use slave labor or permit human trafficking at any time.

3. No Child Labor
Suppliers should not employ any persons younger than 15 years of age, or age specified by the local law, whichever age is higher. It is Technimark’s policy that it will not knowingly do business with suppliers that illegally or improperly employ underage workers.

4. Wages and Benefits
Suppliers must compensate all workers with wages, overtime premiums, and benefits that meet or exceed local legal standards, local industry standards, or collective agreements, whichever are higher. Suppliers are encouraged to provide wages and benefits that are sufficient to meet workers’ basic needs and provide some discretionary income for workers and their families.

5. Working Hours
Except in extraordinary business circumstances, workers shall not be required to work (inclusive of overtime) more than the legally prescribed limits. Suppliers shall comply with applicable laws that entitle workers to vacation time, leave periods and holidays.

6. No Harassment and Abuse
Suppliers should treat each employee with respect and dignity and will not subject any employee to any physical, sexual, psychological, verbal, or any other form of harassment or abuse.

7. Non-Discrimination
Suppliers shall protect against unlawful discrimination in hiring, salary, benefits, training, advancement, discipline, termination or retirement based on gender, race, religion, age, disability, sexual orientation, genetic information, nationality, political opinion, social or ethnic origin, or any other applicable prohibited basis.

8. Health, Safety and Environment
Suppliers shall provide a safe and healthy working environment, including any provided residential and/or dining facilities. Suppliers must take reasonable proactive measures to prevent workplace hazards.

Suppliers should, in all respects, comply with local environmental laws and regulations, including all laws related to waste disposal, air emissions, discharges, toxic substances and hazardous waste disposal. Suppliers should take steps to minimize the negative impact their business might have on the environment particularly concerning material selection and the handling and disposal of hazardous material and other waste.

9. Conflicts of Interest
Suppliers must not enter into transactions with Technimark associates that create a conflict of interest.

10. Anti-Corruption
Suppliers must not tolerate, permit, or engage in bribery, corruption, or unethical practices whether in dealings with public officials or individuals in the private sector.

Violations of these Standards can be anonymously reported by contacting Technimark. Click here to send email.

Statement Under the California Transparency in Supply Chains Act of 2010 (SB 657)

Maintaining the highest standard of ethics is Technimark’s corporate policy and has always been an integral part of the Technimark culture. Our reputation for ethical business practices is one of our most valued assets. We build our business based on the core principles of honesty, integrity and loyalty. We also expect our business partners to operate on the same principles. As part of our commitment to global corporate stewardship, Technimark complies with the California Transparency in Supply Chains Act of 2010 (Senate Bill No. 657), which seeks to completely eradicate slavery and human trafficking in the supply chain. This disclosure covers the five major areas identified as below:

Verification: Technimark may conduct on-site social compliance supplier audits or require our suppliers to complete facility self-assessment questionnaires. Certain high-risk suppliers, which are identified based on country location and other risk parameters, may be subject to social compliance audits conducted by an independent third party to evaluate and address risks of human trafficking and slavery.

Auditing: Technimark may conduct on-site audits, either announced or unannounced, to verify that our suppliers do not violate our Technimark Supplier Social Responsibility Policy, including our prohibition on human trafficking and the use of forced labor in any form.

Certification: Critical suppliers may be required to certify that materials incorporated into the product comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business. New suppliers are required to provide a self-assessment prior to being approved as a supplier. In addition, social responsibility requirements may be included within our contracts with suppliers. Suppliers failing to meet our Supplier Social Responsibility Requirements or failing to comply with the terms of our contracts would be in breach of our agreement.

Internal Accountability: Technimark requires all of its employees, regardless of position, seniority or geographic location, to comply with applicable foreign, federal and state laws, including those relating to the use of forced labor, human trafficking and other prohibited employment and labor practices. Employees that violate these provisions are subject to disciplinary action up to and including termination.

Training: Technimark offers training on the Technimark Supplier Social Responsibility Policy to all employees and management who have direct responsibility for supply chain management. This training addresses, among other things, Technimark’s policies on legal compliance, prohibition on forced labor and human trafficking, prohibition on child labor and worker compensation and working hour limitations.

I. COMMITMENT 

We commit to the following principles and practices: 

• Meeting or exceeding all applicable federal, state and local regulations and standards to protect the environment and the health and safety of our workforce and communities. 
• Minimizing our use of energy, water and raw materials by always prioritizing efficiency in how we build, manage and operate our facilities. 
• Limiting our impact on the planet and climate change by reducing our greenhouse gas (GHG) emissions through resource efficiency and investments in renewable energy. 
• Monitoring and measuring air emissions and wastewater discharges to prevent local air and water pollution. 
• Encouraging a Zero Waste mindset with our associates and business partners, always looking for ways to reduce, reuse, recycle and compost materials so we avoid waste to landfill, incineration or the environment. We strive to eliminate plastic resin pellet, powder and flake loss in operations. 
• Replacing or eliminating the use of hazardous substances. Where hazardous substances must be used, we will prevent accidental pollution by implementing best practices and ensuring disposal meets regulatory requirements. 
• Partnering with our customers to design products for recyclability and reuse, incorporate recycled and renewable resins, and minimize the amount of plastic resin in molded parts. Every year, we increase our use of recycled materials in our manufacturing facilities. Through our subsidiary, Wellmark, we are a leader in plastics recycling. 
• Recognizing the value of nature and the importance of conserving biodiversity – the variety of all living things – for the well-being of people and our planet. Through our environmental management system, we will address and limit any identified impacts. 
• Creating a culture of environmental awareness and responsibility through training, educational opportunities, and forums where green ideas are sought, shared, and rewarded. 
• Setting ambitious targets and implementing a global program to effectively track performance and enable continuous improvement toward our sustainability goals. 
• Engaging with our suppliers on environmental issues and assessing their compliance with our Global Supplier Standards. 

II. OUR 2030 AMBITION 

Our commitment to the above principles and practices will advance the goals set across the People, Planet and Product pillars of our sustainability strategy: 

Climate Impact: We strive to reduce operational (Scope 1 and 2) emissions 42% by 2030 as compared to a 2021 baseline. This is aligned with the reductions required to limit global warming to 1.5°C. Because electricity is the most significant source of our operational emissions, our manufacturing sites will work to reduce electricity use 2% per year. 

Waste Reduction: We aim to minimize waste generation and utilize the most sustainable treatment methods for waste disposal. Our goal is to promote zero waste initiatives and achieve Zero Waste to Landfill certification at the majority of sites globally by 2030. 

Recycled Resins: We aim to increase Wellmark’s production of post-consumer resin by 30% by 2030 as compared to a 2021 baseline. 

Product Content: Our goal is that greater than 75% of the solutions in our consumer packaging and proprietary lines are recycled, refillable, reusable and/or contain recycled content. 

Product Design: We will lead sustainable design in healthcare by offering sustainable solutions for the products and packaging we manufacture. 

Substances of Concern: We aim to eliminate substances of concern in our products and manufacturing process where possible. 

III. GOVERNANCE AND REVIEW 

Technimark’s Chief Sustainability Officer is responsible for administering and amending this policy. If you have any questions related to this policy, please contact Katie Distler, Chief Sustainability Officer (katie.distler@technimark.com; 336-799-3932). 

 Technimark Holdings LLC (together with its subsidiaries and all entities controlled, controlling, or under common control with Technimark Holdings LLC, “Technimark” or the “Company”) operates in a wide range of legal and business environments, many of which pose challenges to our ability to conduct our business operations with integrity. As a company, we strive to conduct ourselves according to the highest standards of ethical conduct. Throughout our operations, the Technimark seeks to avoid even the appearance of impropriety in the actions of our directors, officers, employees, and Representatives (as defined below). 

This Global Anti-Corruption Policy (this “Policy”) provides guidance and establishes procedures to avoid corruption. Violations of this Policy may expose Technimark and its Representatives (as defined below) to potential civil and criminal liability under the U.S. Foreign Corrupt Practices Act (“FCPA”), as well as foreign laws such as the U.K. Bribery Act 2010, the Criminal Justice (Corruption Offences) Act 2018 of Ireland, The Anti- Unfair Competition Law of the PRC (Competition Law 2019), The Amendment to the Criminal Law of the PRC (12), the Mexico Anti-Corruption Amendments of 2015, and the Mexico National Anti-Corruption Systems Laws (2017) (collectively, and together with all other laws regulating bribery or corruption in any jurisdiction where Technimark is organized, has a location, or conducts business, including provisions of the criminal law of each such jurisdiction, “Applicable Law”). Technimark takes a zero-tolerance approach to bribery and corruption. You must comply with this Policy, all Applicable Law, and related procedures at all times. Accordingly, failure to do so will be treated as a disciplinary matter and may result in the immediate termination of your employment for cause (or termination of any other contractual relationship with Technimark for breach), to the extent permitted under the applicable laws. In order to help Technimark meet its commitment to integrity and ethics, we expect each employee to review the content of this policy during their on-boarding process as part of the Code of Conduct training and execute the Certification attached hereto. Annual re-certifications will also be required for certain positions designated by senior management with signed Certifications in the form attached hereto. 

This Policy contains information intended to reduce the risk of corruption and bribery from occurring in the Company’s activities. The Company strictly prohibits all forms of corruption and bribery and will take all necessary steps to ensure that corruption and bribery do not occur in its business activities. 

I. SCOPE OF POLICY 

This Policy is applicable to all of Technimark’s operations worldwide. This Policy applies to all officers, directors and employees of Technimark (“Company personnel”), together with any agents, consultants, joint venture partners, contractors, vendors, attorneys, accountants, advisors, or other third-party representatives acting for, on behalf of, or at the direction of Technimark (collectively, “Agents” and together with Company personnel, “Representatives”). 

II. ANTI-BRIBERY: U.S. AND FOREIGN GOVERNMENT OFFICIALS 

Various U.S. laws, including the FCPA, regulate gifts to U.S. and foreign government officials. These statutes strictly prohibit bribery of foreign officials. Accordingly, you may not offer or give anything of value to any government official, unless you have received approval from the Chief People Officer and General Counsel. Prior approval is necessary because violations of laws regulating such gifts can result in civil and criminal liability for Technimark and you. 

A. General Principles 

This Policy prohibits any bribery or related conduct that may violate these laws or others intended to combat corruption. In short, this Policy prohibits any Representative of Technimark from directly or indirectly making, promising, authorizing, or offering anything of value to any U.S. government or foreign official to obtain or retain business, direct business to another entity, or to obtain an improper business advantage. This prohibition applies regardless of whether the employee or agent seeks reimbursement for, or uses Company funds for, the gift or payment in question. Even payments out of your personal funds may result in criminal liability. 

B. Definitions 

1. “Anything of Value” 

Technimark forbids what you may traditionally think of as bribes, as well as conduct you may not think of as a bribe or even improper, but that fits a legal definition of corruption. For example, buying an expensive dinner for a tax official during a tax audit may be considered a bribe or raise the appearance of improper dealings. 

“Anything of value” is meant to be very broad. It includes, for example: (i) cash or cash equivalents (e.g., gift cards), (ii) gifts, (iii) gratuities, (iv) goods, (v) loans, (vi) entertainment or tickets, (vii) meals or drinks, (viii) travel or lodging, (ix) political or charitable contributions, (x) personal favors, (xi) paying bills for others, (xii) forbearances (i.e., abstaining from the enforcement of a right), (xiii) hiring someone’s friend or relative and (xiv) anything else valuable to the recipient, even if not valuable to anyone else. 

This Policy also prohibits Technimark personnel from giving anything of value to any person, including third parties, while knowing, or having reason to suspect, that all or some portion of the thing of value will be offered, given, or promised to a U.S. government or foreign official to corruptly influence that official. 

On occasion, a government official may attempt to solicit or extort improper payments or anything of value from Company personnel or other Agents. Such Company personnel or other Agent must inform the government official that Technimark does not engage in such conduct and immediately contact the General Counsel of the Company. 

2. “U.S. Government Official” and “Foreign Official” 

As noted above, providing anything of value to a U.S. government official or foreign official may be bribery. For the purposes of this Policy, a U.S. government official or a foreign official shall include: 

• any elected or appointed official or other officer or employee in executive, legislative, or judicial branches of the U.S. federal government, a foreign national government, or a state, provincial, municipal, or other local government, or any department, agency, or instrumentality thereof, 
• any officers or employees of a company or business owned in whole or in part or controlled by a government (a state owned or controlled enterprises), 
• any foreign political party or political party official, 
• any candidate for political office, 
• any official or employee of certain public international organizations (such as the United Nations, NATO, World Bank, or European Union), and 
• anyone acting on behalf of any of the above. 

C. Guidance For Determining Whether Gifts or Payments Are Permitted 

The key to whether a particular gift or payment is improper is whether it is made “corruptly.” A gift or payment is only corrupt if it is intended to induce the recipient to misuse his official position by, for example, overlooking a violation or tolerating non-compliance with the law (e.g., environmental or worker safety laws), not performing a required task (e.g., not conducting a required inspection prior to issuing a permit), or directing business to Technimark or another entity (e.g., accepting a bid from Technimark or an affiliate for any reason other than a good faith business evaluation of all bids). 

Many utility companies or other vendors in other highly regulated industries are owned or controlled, in whole or in part, by a local governmental agency or instrumentality. In such circumstances, ordinary course payments for provision of goods or services supported by an invoice from the vendor and specifically detailing the goods or services provided, which shall be at reasonable market rates, are generally not prohibited by this Policy. 

The FCPA recognizes that there are also some legitimate circumstances in which a company may offer something of value to a government official. Thus, the FCPA permits companies to provide reasonable and bona fide expenses to government officials, if those expenses are directly related to either the promotion, demonstration or explanation of products or services or to the performance of a contract. Consistent with these principles, the following are examples of permitted expenses: 

• Travel and lodging to visit company facilities or operations or associated with training on company products or services. 
  Note: Such travel expenses must be reasonably related to these purposes. Thus, plane fare to and from company facilities would be appropriate. Payment for a side trip to Las Vegas would not be. 
• Product demonstrations or promotional activities, including moderately valued promotional, Technimark branded items, such as a pen or umbrella with a Technimark logo, and sample products that are not excessively valued. 
  Note: What is “excessively valued” will depend on the particular facts and circumstances of the product and the need for the official to sample it. 
• Business meals 
  Note: The FCPA does not prohibit all forms of hospitality to government officials. Thus, reasonably priced business meals that are intended to allow the participants to get to know each other or to have business discussions in a more relaxed atmosphere are permissible. 

To the extent that you have questions regarding whether a particular expense is permitted, you must consult with your manager. 

D. Extortion Payments 

Extortion payments are payments that are necessary to ensure the health or safety of Technimark personnel. Payments to avoid the possibility of imminent physical harm or illegitimate or unauthorized detention are considered necessary to ensure health or safety. Threats of purely economic harm, with no accompanying threat of physical harm, are not considered necessary to ensure health or safety. Demands for such payments must be reported to the CEO and General Counsel immediately and no such payments may be made unless approved in writing by the CEO. Extortion payments must be accurately reflected as extortion payments in Technimark’s books and records. 

E. Facilitating Payments Are Prohibited 

A facilitating payment is a payment of small value made to low level or clerical government employees to obtain the performance of a non-discretionary, routine governmental action to which Technimark is legally entitled, such as clearing customs, processing visas/permits/licenses, providing police protection, and providing utility services. Technimark does not permit facilitating payments under any circumstances. 

To the extent you have any questions regarding facilitating payments, contact your manager before making any payment. If, contrary to this Policy, a facilitating payment is made, the 

In the case of proposing to renew a contract with an existing third-party vendor, the New Vendor Set-Up procedure must be repeated if the prior contract was approved prior to October 1, 2014. 

The New Vendor Set-Up procedure may be updated from time to time. SharePoint will contain the most recent documents and procedures and it is the responsibility of the Representative proposing the relationship to ensure that the procedures are followed. 

B. Contracts 

Representatives can only be retained via written agreement. The written agreement between Technimark and the third party should include the anti-corruption language below. Any variations from the below language require the approval of the General Counsel. 

[Third-Party Company] (“Vendor”) has been provided Technimark’s Anti-Corruption Policy and will comply with the provisions thereof as they relate to Vendor or the goods or services provided thereby. In carrying out the responsibilities described in this Agreement, Vendor agrees to comply fully with and to cause any person acting on its behalf to comply fully with all applicable laws and regulations, including without limitation the anti-bribery laws and regulations in all relevant jurisdictions, such as the U.S. Foreign Corrupt Practices Act, and similar laws in other jurisdictions. 

Technimark shall have the right to terminate this contract for cause upon any Vendor violation of the above provision. Vendor shall indemnify and hold Technimark, its affiliated companies, and their respective officers, directors, and employees harmless from any claim, liability, fine, penalty, loss, or damage that arises as a result of Vendor’s failure to comply with the obligations set forth in the foregoing provisions. 

C. Red Flags 

“Red flags” of corruption risk include suspicious payment requests (e.g., requests for payment in cash) and a lack of detailed information from third-party agents regarding services provided. If you suspect that a transaction might involve corrupt payments, you must immediately report that information to your manager and the People Department. 

V. RECORDKEEPING 

All Technimark personnel must record and report information in Technimark’s financial books and record keeping systems timely, accurately, and honestly, including, but not limited to, costs, revenues, business expenses, payments to third-parties, time worked, services performed, product delivered, and any other information necessary to fairly reflect transactions. These accounting entries and the supporting documentation must be periodically reviewed to identify and correct discrepancies, errors, and omissions. No person may make any entry in Technimark’s books and records that conceals or disguises the true nature of any transaction and no “slush funds” or “off-book” accounts shall be maintained. Any violations of these obligations or any inaccurate entry must be reported to the Chief Financial Officer immediately. 

In particular: 

• all transactions involving the provision of anything of value to a government official must occur only with appropriate Company authorization, 
• all transactions involving the provision of anything of value to a government official must be recorded in accordance with generally accepted accounting principles, and 
• all transactions involving the provision of anything of value to a government official must be tracked in a separate log or record, with supporting documentation identifying (i)the name and position of the employee requesting and authorizing the transaction, (ii) the name and position of the government official involved in the transaction, and (iii) a description, including the value, of the payment or provision of anything of value, and where applicable, a description of the Company’s products or services being promoted or the relevant contractual provision if the payment was made pursuant to a contract. 

Expense report records must accurately reflect all business expenses provided to people outside Technimark. Reports must accurately state the amount and purpose of expenditures and identify each individual receiving gifts, meals, or entertainment. Vague generalities about the nature of expenses – or the recipients – are not sufficient and will not be reimbursed or otherwise paid for by Technimark. 

Cash payments of any kind to a third party, other than documented petty cash disbursements or other valid and approved payments, are prohibited. Company checks shall not be written to “cash,” “bearer,” or anyone other than the party entitled to payment except to replenish properly used petty cash funds. 

V. TRAINING 

The Chief People Officer in consultation with the General Counsel will identify personnel who interact with government officials or who are involved in international business development, marketing and sales, contracts, finance, and other international activities who will be required to complete anti-corruption training on an annual basis. 

VII. REPORTING AND COOPERATION 

Anyone who violates this Policy, the FCPA, the U.K. Bribery Act, or other Applicable Law, or suspects any such violation must report the violation immediately to their manager, the local People Department, Technimark’s General Counsel and the Chief People Officer. Technimark strictly prohibits retaliatory actions against employees for reporting potential violations in good faith and any retaliation will be treated as a disciplinary matter and may result in the immediate termination of the retaliating Company personnel for cause. Representatives should report suspected violations to their manager, the People Department, the Legal Department, or by emailing Compliance@Technimark.com. When in doubt about the appropriateness of any conduct, Technimark requires that you seek additional guidance before taking any action that may violate this Policy. 

Technimark has also established an independent and confidential whistleblower hotline through Lighthouse Services, Inc. (“Lighthouse”) for all Technimark employees. The purpose is to report fraud and unlawful, unethical, and other types of improper behavior in the event that a Representative is uncomfortable reporting through the methods above. Filing a concern with Lighthouse can be done at www.lighthouse-services.com/technimark or via email at reports@lighthouse-services.com with the name “Technimark” in the subject line of the email. 

Technimark may at times undertake a more detailed review of certain transactions. As part of these reviews, Technimark requires all employees, agents, and third-party representatives to cooperate with Technimark, outside legal counsel, outside auditors, or other similar parties. Failure to cooperate in an internal review will be viewed as a breach of your obligations to Technimark and will be treated as a disciplinary matter and may result in the immediate termination of your employment for cause (or termination of any other contractual relationship with Technimark for breach), to the extent permitted under the applicable laws. 

Our commitment to respecting internationally recognized labor and human rights standards 

At Technimark, we responsibly design and manufacture innovative solutions that enhance and improve life. We adhere to the principles of honesty, integrity, quality, dependability and safety for our stakeholders, and always let our actions speak louder than our words. Our values of excellence, respect, service and positivity are the foundation of our sustainable business. 

Commitment 

Respect for human rights is fundamental to our mission and long-held belief that, as a company, we should strive to move past “doing no harm” to also becoming a force for good. Technimark is committed to ensuring all people are treated with dignity and respect and supporting their fundamental rights at work. We are committed to identifying, preventing and remediating adverse human rights impacts that result from or are caused by our business activities and complying with the laws of the countries in which we do business. 

The Technimark Code of Conduct provides the ethical and behavioral framework to guide our employees in everyday business decisions. This Global Human Rights Policy builds upon our Code and is based on international human rights principles encompassed in the International Bill of Human Rights, the International Labor Organization’s Declaration on Fundamental Principles and Rights at Work, the United Nations Global Compact and the United Nations Guiding Principles on Business and Human Rights. 

Scope 

It is both a business and moral imperative to ensure that human rights are upheld across our operations and supply chain. This Global Human Rights Policy extends to all employees of Technimark and its affiliated companies. Our Code of Conduct, Global Courtesy and Respect Policy, Global Social Responsibility Policy, General Work Policy, Workplace Violence Prevention Policy and Equal Employment Opportunity Policy reinforce our commitment. Consultants, contractors, subcontractors, agents, suppliers, and temporary employees who serve as an extension of Technimark are also expected to act in accordance with our commitment, as well as any applicable contractual provisions. Our Global Supplier Social Responsibility Policy makes clear our expectations for suppliers. 

Human Rights Focus 

Technimark respects all internationally recognized human rights, and we operate our business with the following principles: 

Respecting the Dignity and Diversity of All People 

Technimark is passionate about our people, and we are committed to a work environment that supports and celebrates diversity. Our colleagues, applicants, and business partners are entitled to respect. We are committed to ensuring they feel welcomed and valued and giving them opportunities to grow, contribute, and develop. Technimark supports laws prohibiting discrimination and provides equal opportunity for employment, income, and advancement. This means we base employment decisions solely on qualifications, demonstrated skills, and achievements – and never on gender, race, color, religion, age, disability, sex (including pregnancy, sexual orientation, or gender identity), genetic information, nationality, citizenship, veteran status, political opinion, social or ethnic origin, or any other legally protected category. 

Harassment based on these factors, including sexual, physical, psychological, verbal, or any other form of abuse, is not tolerated. Technimark’s commitment is to treat everyone fairly and maintain a work environment free of bias and retaliation. We require the same commitment from our suppliers. Our goal is to train 100 percent of Technimark associates annually in anti-discrimination and harassment to further our commitment to respecting the dignity and diversity of all people. 

No Forced Labor or Human Trafficking 

Technimark prohibits the use of all forms of forced or compulsory labor including prison labor, indentured labor, bonded labor, and all forms of modern slavery and human trafficking. 

As communicated in our Global Supplier Social Responsibility Policy, we also prohibit such practices in our global supply chain, ensuring that: 

• No worker pays for their job; 
• Workers receive a timely refund of fees and costs paid to obtain or maintain their job; 
• Workers have control of their travel documents and full freedom of movement; and 
• All workers are informed, in a language they understand, of the basic terms of their employment before leaving their country of origin. 

No Child Labor 

Neither Technimark nor its suppliers will employ any persons younger than 16 years of age, or the age specified by local law, whichever is higher. It is Technimark’s policy that it will not knowingly do business with suppliers that illegally or improperly employ underage workers. 

External Stakeholder Engagement and Human Rights 

Technimark respects the rights of local communities and is committed to engaging with relevant stakeholders to consider their views on human rights issues. We respect the ownership rights of external stakeholders to property/land; their rights to self-determination (which is the right to freely determine their political affiliation and freely pursue their economic, cultural and social development); their right to determine their own destiny; and their rights to their own safety and security. 

Fair Labor Practices 

All Technimark employment practices are required to comply with all applicable laws and regulations, including those concerning hours, compensation, opportunity and working conditions. 

Safe and Healthy Workplace 

Technimark is committed to providing a safe and healthy working environment and complying with applicable safety and health laws, regulations and our own internal requirements. We prohibit the use of mental or physical disciplinary practices and take proactive measures to minimize the risk of accidents, injury and exposure to health risks. Technimark values the importance of prompt identification and remediation of health and safety issues. Our goal is a workplace free from accidents, injury and exposure to health risks. Workplace violence is not tolerated, and all threats are taken seriously. We depend on every employee to help maintain a positive environment by using care in their interactions and staying alert for potential violence. 

Freedom of Association and Collective Bargaining 

Technimark respects the right of our employees, and those of our suppliers, to join, form (or not join or form) a labor union. We protect the free exercise of those rights without fear of reprisal of any kind. When employees are represented by a union, we are committed to establishing a constructive dialogue with their freely chosen representatives and to bargaining collectively in good faith with them. 

Guidance and Reporting Opportunities 

At Technimark, open and honest communication is valued and respected. We are committed to investigating, addressing and responding to any human rights concerns raised and taking appropriate corrective action. If an employee believes someone is violating our Code, our human rights commitment or the law, they should raise concerns immediately to their supervisor or manager. The independent and confidential Lighthouse Hotline, located at lighthouse-services.com/Technimark (together with other reporting channels identified in our publicly available Code of Conduct) are the grievance mechanisms available to all employees and business partners. We will not tolerate retaliation or reprisal against any human rights defenders, and we expect the same from our suppliers. 

Governance and Commitment to Ongoing Due Diligence 

Technimark’s Chief Executive Officer and executive leadership team have ultimate oversight of human rights. Technimark’s Chief People Officer, General Counsel and Chief Sustainability Officer are responsible for administering and amending this policy. Human rights due diligence is a continuous process, and the Code of Conduct and Global Human Rights Policy will be supplemented as needed to address any new areas of vulnerability. Technimark uses policies, training and development programs, monitoring and reporting systems and audits to ensure compliance. 

The Lighthouse Hotline is an independent ethics monitoring service where Technimark employees and partners can raise anonymous concerns and feedback.

This third-party watchdog empowers employees and partners to report any issues that may adversely affect how we operate, serve customers, and look after our colleagues.

This provision is included in the Technimark Global Anti-Corruption Policy and can be viewed here. For those wishing to report fraud and unlawful, unethical, and other types of improper behavior, Lighthouse concerns can be filed www.lighthouse-services.com.