HECA GLOBAL SUPPLIER AND BUSINESS PARTNER CODE OF CONDUCT

OBJECT

HECA GLOBAL has made a commitment to its shareholders, customers, employees and the community at large. It is important that HECA GLOBAL honors its core values of meritocracy, precision, diversity, humility, initiative, proactivity and adaptability and that Suppliers and Business Partners comply with applicable legislation, identify with the principles established in HECA Code of Ethics and operate in accordance with the values on which this Supplier and Business Partner Code of Conduct is based. This Code of Conduct sets out specific obligations for Suppliers and Business Partners in relation to the following aspects: responsible conduct in business, ethical practices in business and employment, corporate social responsibility, and raising concerns and reporting violations.

RESPONSIBLE CONDUCT IN BUSINESS

  1. Compliance with laws

Suppliers and Business Partners must ensure that and conduct their business activities in compliance with all respective laws, rules and regulations in the jurisdictions where they operate.

2. Conflicts of interest

Suppliers and Business Partners must act in accordance with HECA GLOBAL’s corporate principles to avoid any situation in which a conflict of interest may exist in their dealings with HECA GLOBAL. Priority will be given to the parameters of usefulness, quality and budgets of HECA GLOBAL. Suppliers and Business Partners may be evaluated and controlled according to HECA GLOBAL’s policies and processes. In the event of detecting a current or potential situation of conflict of interest, HECA GLOBAL will be notified so that appropriate measures can be taken.

3. Gifts and invitations

Current or potential Suppliers and Business Partners must not offer HECA GLOBAL or its staff gifts or invitations that, due to their quality or quantity or the timing of the offer, are intended to obtain a preferential benefit or treatment with HECA GLOBAL or to influence HECA GLOBAL’s purchasing or business activities in which the Supplier and/or Business Partner participates. Gifts or invitations offered must comply with the rules set out in the HECA GLOBAL Code of Ethics and be modest in value, infrequent, reasonable in scope, lawful and compatible with generally accepted ethical standards.

4. Fight against bribery and corruption

HECA GLOBAL has zero tolerance for bribery and corruption and will not do business with Suppliers and Business Partners who demonstrate such conduct. This type of behavior could constitute grounds for termination of contract, suspension, dismissal, or rejection of any current or potential business relationship with HECA GLOBAL. Suppliers and Business Partners must commit to the prevention of bribery and corruption and the implementation of controls to mitigate such risks. Suppliers and Business Partners must not engage in any conduct that could put HECA GLOBAL at risk of violating applicable laws and regulations regarding bribery and corruption, including offering, promising, authorizing, soliciting, demanding, or accepting anything of value, directly or indirectly, to or from any person in order to obtain or retain a business advantage or other favorable consideration. Suppliers and Business Partners must comply with all applicable bribery and corruption laws and regulations in the jurisdictions where they operate. Suppliers and Business Partners must notify HECA GLOBAL if they become aware of any ongoing action or investigation by any government or regulatory agency that constitutes a threat against the Supplier and/or Business Partner in connection with a violation of such laws and regulations.

5. Prevention of money laundering, terrorist financing and sanctions

Suppliers and Business Partners must not engage in any money laundering-related activity, directly or indirectly, or demonstrate any conduct that violates anti-money laundering laws, by accepting, transferring, converting or concealing money obtained from criminal or terrorist financing activities. Suppliers and Business Partners must commit to comply with all applicable laws, regulations and penalties.

6. Data protection

Suppliers and Business Partners must protect HECA GLOBAL’s confidential information. Suppliers and Business Partners must also protect the personal information of HECA GLOBAL’s customers and employees to comply with applicable laws and HECA GLOBAL’s policies. Unauthorized use or disclosure of personal or confidential information is not permitted and, if such unauthorized access occurs, it must be promptly notified to HECA GLOBAL after the Provider and/or Business Partner becomes aware of it.

7. Subcontracting

Suppliers and Business Partners must not assign all or any part of a contract to a subcontractor without the written consent of HECA GLOBAL. If such assignment is approved, Suppliers and Business Partners must ensure that the subcontracting agreement complies with their contractual obligations to HECA GLOBAL and this Supplier and Business Partner Code of Conduct.

8. Insider information

Suppliers and Business Partners may become aware, by reason of their dealings with HECA GLOBAL, of relevant public information (“Inside Information”) about HECA GLOBAL, its affiliated companies or associated entities or its customers. Suppliers and Business Partners must have appropriate policies and procedures in place to ensure compliance with applicable laws and regulatory requirements regarding the handling of Inside Information (such as information barriers or “ethical walls”) and must prevent inappropriate access to or disclosure of Inside Information.

9. Advertising

Suppliers must not make public statements (on company websites, via social media, or otherwise), issue press releases, or distribute marketing materials that refer to HECA GLOBAL, or the trademarks or logos that HECA GLOBAL represents, unless HECA GLOBAL has previously approved each proposed use, or such use is expressly permitted in an existing agreement with HECA GLOBAL.

ETHICAL PRACTICES IN BUSINESS AND EMPLOYMENT

  1. Human rights

HECA GLOBAL is committed to respecting human rights. This commitment is defined in its Code of Ethics. HECA GLOBAL requires its Suppliers and Business Partners to conduct business and maintain policies and practices that are also consistent with respect for human rights. Suppliers and Business Partners must not tolerate harassment, discrimination, violence, or other illegal and inappropriate behavior.

2. Diversity and equity

HECA GLOBAL is committed to providing equal opportunities to all Suppliers and Business Partners. HECA GLOBAL is committed to respecting diversity and inclusion, as defined in Principles 6.2.2 and 6.2.3 of the HECA GLOBAL Code of Ethics. The standards and expectations related to these principles also apply to our Suppliers and Business Partners.

CORPORATE SOCIAL RESPONSIBILITY

1. WORK PRACTICES

1.1 Wages and working hours

Suppliers and Business Partners must comply with applicable employment laws/labor standards and provide wages and rights that meet or exceed the requirements of the legislation of the country where they operate. Working hours, overtime and the number of working days per week must not exceed the relevant legal limits and must be documented in a transparent and accessible manner for workers.

1.2 Prohibition of forced labour

Suppliers and Business Partners must not use forced, involuntary, compulsory, or bonded labor in any of their operations or business activities. Suppliers and Business Partners must comply with applicable laws regarding modern slavery, forced labor, and human trafficking, and must not use practices related to forced labor, withholding wages, withholding identity documents, or restricting the free movement of persons.

1.3 Prohibition of child labour

Suppliers and Business Partners must not employ persons who are not yet of legal age to work in the jurisdiction where they operate or conduct business. Suppliers and Business Partners must operate in accordance with national legislation and comply with the International Labour Organization’s (“ILO”) core standards regarding child labour, such as ILO Convention No. 182 on the Worst Forms of Child Labour.

1.4 Discrimination, harassment and violence.

Los Proveedores y Socios de Negocio deben contar con políticas y procedimientos que prohíban y aborden la discriminación, el acoso y la violencia en el lugar de trabajo.

1.5 Resolution of labor concerns

Suppliers and Business Partners must maintain a process that allows their workers to raise their concerns without fear of retaliation and that is transparent and ensures the confidentiality and protection of individuals who may raise their concerns.

1.6 Occupational Health and Safety

Suppliers and Business Partners must ensure that their offices and facilities comply with applicable occupational health and safety laws. Suppliers and Business Partners must implement and maintain appropriate safety procedures, provide employees with the required training, and provide the necessary protective equipment to ensure a safe and healthy work environment.

2. RECORD KEEPING AND COMPLIANCE:

2.1 Record keeping

Suppliers and Business Partners must maintain accurate, detailed and complete books, accounts and records to verify compliance with applicable laws, as well as this Supplier and Business Partners Code of Conduct and their contractual obligations to HECA GLOBAL. Suppliers and Business Partners must not destroy records that may be relevant with respect to pending or imminent legal or regulatory proceedings.

2.2 Compliance

In the event of non-compliance with this Supplier and Business Partner Code of Conduct, corrective action shall be implemented without undue delay. Any material breach of this Supplier and Business Partner Code of Conduct may result in the termination of the Supplier’s and/or Business Partners’ relationship with HECA GLOBAL, as provided for in the applicable agreement between HECA GLOBAL and the Supplier or Business Partner.

RAISING CONCERNS AND REPORTING VIOLATIONS

  1. All Suppliers and Business Partners must be aware that it is mandatory to report illicit, illegal or fraudulent conduct in their relationship with HECA GLOBAL, which comes to their knowledge. HECA GLOBAL will protect with all its means the Supplier or Business Partner that makes this type of situation known, and will not hesitate to sanction those who, due to laziness, comfort or false spirit of loyalty, refrain from reporting situations of this nature.


Any fact that, in the opinion of a Supplier or Business Partner, violates this Code of Conduct, or that in any way may be filed as an act against HECA GLOBAL, fraudulent or illegal, must be reported through HECA GLOBAL’s Whistleblower Channel, available on its website: https://www.hecaglobal.com

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