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Supplier Code of Conduct

  1. Introduction
    1. Alterra’s vision is to make responsible choices every day. Achieving this vision includes providing responsible solutions to customers as well as carrying out our business with integrity and according to ethical standards expressed in our Code of Conduct. Responsible sourcing plays a significant role in realizing our vision. Our commitment to responsible and ethical business practices depends not only extends to on our own people but also to our relationships with business partners with common goals.
    2. This Supplier Code of Conduct (this “Code”) outlines requirements for Alterra’s suppliers (our “Suppliers”) while not only transacting business with Alterra, but also while managing their own employees, suppliers and other stakeholders.
    3. In this Code, our “Suppliers” means any individual or legal entity which provides Alterra with products, components, materials or services. The definition of our “Suppliers” also includes our Supplier’s own first tier suppliers, contractors and other business partners participating in the delivery of products, components, materials or services to Alterra (our Suppliers’ “Affiliates”).
    4. Our Suppliers take reasonable efforts to encourage their Affiliates comply with the minimum requirements set out in this Code, and that this Code is communicated to them.
    5. This Code can be amended from time to time. The most recent version of the Code is available on Alterra’s website at [insert web address].
  2. Compliance with laws and regulations
    Our Suppliers agree to comply with all local, state, federal and international laws and regulations applicable to its operations (the “Laws”). Should a requirement of this Code contradict or augment Laws, our Suppliers agree to comply with whichever is more stringent.
  3. Business Conduct
    1. Zero Tolerance for Corruption
      Alterra expects our Suppliers to have zero tolerance towards bribery and corruption. Our Suppliers will have standards and procedures in place to ensure that their directors, employees and third parties acting on their behalf do not offer, promise, give or accept any bribes, or make or accept improper payments (such as facilitation payments or kickbacks) to obtain new business, retain existing business, or secure any other improper advantage. Our Suppliers will not provide Alterra employees with any gifts or hospitality in any situation in which said gifts or hospitality might influence, or appear to influence, our employee’s decision in relation to our Suppliers.
    2. Competing Fairly
      Our Suppliers will compete in a fair manner in compliance with all Laws, including without limitation the Sherman Antitrust Act and, and must have standards and procedures in place to ensure that its directors and employees do not engage in any restrictive or other anti-competitive practices (including, but not limited to, cartels, pricing, resale pricing, market sharing, bid rigging, terms of trading, purchase or supply and joint ventures), dominant or monopoly market positions (whether held individually or collectively) and the control of acquisitions or mergers.
    3. Compliance with anti-money laundering and privacy rules and trade sanctions
      Our Suppliers will comply with all Laws relating to anti-money laundering (including, but no limited to the Bank Secrecy Act and The Anti-Money Laundering Act of 2020) and privacy and on all applicable economic and trade sanctions.
    4. Avoiding Conflicts of Interests
      Our Suppliers will avoid situations where a conflict of interest between such Supplier and Alterra, including interactions with an Alterra employee that could create a conflict of interest relating to our employee’s duty to act in the best interest of Alterra. Our Suppliers must disclose to Alterra any current or potential future conflict of interest relating to Alterra and our employees.
  4. Human and labor rights
    Alterra respects the rights enshrined in the Universal Declaration of Human Rights and the fundamental rights in the eight core conventions of the International Labor Organization which form the basis for Alterra’s Human Rights Commitment. Our Suppliers are expected to respect the same rights and, at a minimum, our Suppliers agree to:
    1. adhere to Laws regarding working hours, minimum wages, overtime, and mandatory benefits (e.g. social security), and maintain related, appropriate records;
    2. ensure that all employees are made aware of the key terms of their employment prior to commitment to work;
    3. comply with all Laws relating to minimum working age requirements and avoid employment, which by its nature and the age of such employee, is likely to harm their health, safety or morals, and establish systems to ensure fulfilment of and follow-up on these requirements;
    4. not use any compulsory or forced labor;
    5. provide equal opportunity and treatment in employment, without regard to race, color, religion, sex, political opinion, national extraction, social origin, creed or any other similar distinction which is not based on the inherent requirements of the work;
    6. not tolerate any type of harassment of its employees whether direct or indirect, physical or verbal.
  5. Occupational Health, Safety and Security
    Our Suppliers will provide their employees with a healthy, safe and secure workplace in compliance with all Laws, including the Occupational Safety and Health Act of 1970 (OSHA). At a minimum, our Supplies will:
    1. comply with Alterra’s Safety Rules when working at Alterra premises;
    2. comply with health and safety requirements if, and to the extent, separately agreed with Alterra;
    3. ensure that appropriate health and safety information and equipment are provided to its employees and contractors; and
    4. in compliance with OSHA, provide employees and contractors with drinking water, clean toilets, adequate ventilation, emergency exits, proper lighting and access to first aid supplies or other provision for emergency care.
  6. Environmental Impact and Climate Change
    Our Suppliers agree to support a precautionary approach to environmental challenges and undertake initiatives to promote greater environmental responsibility. Our Suppliers are encouraged to establish and implement procedures to minimize the adverse impact of their operations on the environment and to demonstrate continuous improvements therein. At a minimum, our Suppliers will:
    1. abide by all Laws relating to environmental requirements (including without limitation those promulgated by the United States Environmental Protection Agency and similar state and local agencies); and
    2. consider the climate impact of its operations and undertake greenhouse gas reduction measures where reasonable.
  7. Reporting
    1. Our Suppliers will report any non-compliance with this Code to Alterra Chief Finance Officer, 222 Main St Akron, OH 44308.
    2. Alterra’s business partners and other stakeholders may report suspected violations (anonymously and confidentially) by using the form found at the bottom of this page.

 

 SUPPLIER CODE OF CONDUCT 3.1.2023
4859-4367-9834, v. 4

Report Suspected Violations to Alterra Supplier Code of Conduct

Please fill out the form as completely as possible. This report will only be seen by Alterra Leadership. You will receive an email confirmation to acknowledge receipt of your report.

Suspected Non-Compliance Details

Please provide information about the suspected non-compliance you are reporting.
Please list names and titles of those who were directly involved in the suspected non-compliance. Please exclude witnesses from this list.
Please list the names and titles of those who witnessed the suspected non-compliance.
Please provide as much detail as possible, including relevant events that led up to the suspected non-compliance.
Please cite specific information from the Alterra Supplier Code of Conduct if at all possible.
I submit this form and confirm that everything on it is true and complete to the best of my knowledge.