WETHJE Carbon Composites Corporate Guideline – Sustainability Standard for Suppliers URL Index 004 Revised: 12.01.2022
Sustainability Standard for Suppliers
As a subsidiary of Mitsubishi Chemical Europe GmbH (MCE), WETHJE Carbon Composites GmbH participates in implementing the KAITEKI vision of its ultimate parent company, Mitsubishi Chemical Holdings Corporation.
The innovative concept “KAITEKI” stands for “the sustainable well-being of people, society and our planet Earth”. KAITEKI guides everything we do. We focus entirely on meeting the many social and environmental requirements worldwide. This in turn creates new and sustainable value for all our stakeholders.
We promote and strengthen procurement activities in order to fulfil our social responsibility not only within our group but across the entire supply chain together with our business partners.
Wethje is committed to the principles of responsible and lawful conduct and asks its suppliers to respect these principles as well, to reflect them in their own corporate policy and to pass them on within their own supply chain.
The following guidelines represent the minimum requirements for all suppliers regarding:
- Business ethics and compliance
- Environmental protection and conservation of resources
- Conflict minerals
- Human rights and working conditions
- Privacy and data protection
- Intellectual property and counterfeit parts
- Whistleblowing and protection against retaliation
- Fair competition and antitrust law
- Integrity, bribery and corruption
- Avoidance of conflicts of interest
- Money laundering
- Export controls and economic sanctions
They are based on fundamental principles of economic, environmental and social responsibility, comply with applicable law and are aligned with international standards.
1. Business ethics and compliance
WETHJE expects all suppliers to act responsibly and lawfully, and to pass this expectation on throughout the entire supply chain. Business must be conducted by all companies in the supply chain in accordance with the respective applicable laws, with the highest integrity, truthfully and fairly.
2. Environmental protection and conservation of resources
WETHJE expects all suppliers and their supply chains to ensure the sustainable, responsible and careful use of resources and raw materials across the entire product life cycle, and to improve this appropriately and continuously. In their products and processes, suppliers shall ensure the efficient use of energy and resources as well as compliance with applicable environmental standards.
The following aspects are to be observed:
a. Reduction of energy consumption and emissions A proactive concept or strategy shall be pursued to reduce energy consumption and greenhouse gas emissions and to increase energy efficiency.
b. Use of natural resources and reduction of waste The use of natural resources and the generation of waste and emissions require monitoring and control. Negative environmental impacts are to be avoided, among other things through the use and further development of modern and efficient technologies and processes that reduce the consumption of water and energy sources as well as emissions, pollutants and waste, and that sustainably improve air and water quality.
c. Socially and environmentally responsible sourcing of raw materials Suppliers are called upon to promote and support the use of renewable, recycled and recyclable materials. See also point 3.
d. Sustainability, safety and quality of products All products and services must meet national and market-relevant environmental protection and safety standards. This includes the entire product life cycle and all materials used. On delivery, all products and services must meet the contractually agreed criteria for quality and safety and must be safe to use for their intended purpose. The requirements of the REACH Regulation (Registration, Evaluation, Authorisation and Restriction of Chemicals) are to be taken into account; where possible, affected products should be avoided or substituted.
e. Controlled handling of chemicals and hazardous substances Chemicals and hazardous substances that may pose a risk to nature and people if released into the environment must be identified in accordance with statutory guidelines. A systematic approach to documentation, safe handling and storage must be established. Reducing the use and substituting hazardous substances, or disposing of and reprocessing them in an environmentally sound manner, should be in the interest of every company.
f. Use of renewable technologies and resource sourcing Suppliers proactively promote the development and dissemination of environmentally friendly technologies within their market segment. Suppliers support all efforts to ensure responsible resource sourcing. The aim is to avoid the procurement and use of resources obtained unlawfully or through ethically objectionable or unacceptable practices.
3. Due diligence for responsible supply chains of minerals from conflict-affected and high-risk areas
WETHJE expects its suppliers to avoid any minerals originating from conflict-affected smelters. This applies in particular to raw materials mined in the eastern provinces of the Democratic Republic of the Congo (DRC). The Dodd–Frank Wall Street Reform and Consumer Protection Act, passed in the United States in July 2010, defines conflict minerals as tin, tungsten, tantalum and gold (3TG). Minerals are also classified as conflict-affected if their extraction, transport, trade, handling, processing or export directly or indirectly supports non-state armed groups.
Information on the smelters or refineries used by suppliers or sub-suppliers for conflict minerals must be submitted to WETHJE at first delivery, without prior request, by means of a Conflict Minerals Reporting Template (CMRT). WETHJE will not maintain any business relationship with suppliers that use conflict-affected smelters or refineries. WETHJE can provide information on options for using conflict-free smelters and refineries on request.
Our suppliers are required to fulfil their due diligence obligations along the entire supply chain, even if their own suppliers do not source minerals directly from the DRC. This includes implementing measures to ensure that the minerals used by suppliers – in particular tin, tungsten, tantalum and gold (3TG) – do not directly or indirectly promote or support armed conflict.
The due diligence requirements are an extension of the sustainability requirements named above concerning environmental protection, employee rights, transparent business relationships and fair market conduct, all of which are integral parts of exercising due diligence.
4. Human rights and working conditions
For WETHJE it is of paramount importance that business activities take account of social responsibility towards employees. This also applies to WETHJE’s suppliers and their sub-suppliers. WETHJE requires its suppliers to respect social standards, to reflect them in their own corporate policy and to ensure a commitment to social responsibility throughout their entire supply chain.
The following principles are of particular importance:
a. Respect for human rights b. No discrimination of any kind; equal opportunity and equal treatment c. Prohibition of child labour and forced labour d. Respect for positive and negative freedom of association e. Remuneration without regard to gender, in compliance with the minimum requirements of the applicable national laws f. Compliance with working hours in accordance with the respective country-specific statutory provisions g. Compliance with occupational safety and health protection requirements
5. Privacy and data protection
The supplier undertakes to meet the reasonable expectations of its client, sub-suppliers, customers, consumers and employees with regard to the protection of private information. When collecting, storing, processing, transmitting and disclosing personal information, the supplier must observe data protection and information security laws as well as regulatory requirements.
6. Intellectual property and counterfeit parts
Intellectual property rights in products must be respected; technology and know-how transfer must take place in such a way that intellectual property rights and customer information are protected. The use of counterfeit parts is expressly prohibited and will be strictly penalised.
7. Whistleblowing and protection against retaliation
We expect our suppliers to protect persons who submit a complaint report in good faith within the supplier’s organisation from threats, harassment or retaliation. Any form of retaliation, overt or subtle, against a person who has reported a concern is unacceptable. In addition, the personal data of both reporting and reported persons must be protected. Suppliers are expected to maintain the confidentiality of whistleblowers’ identities throughout all stages of the procedure.
8. Fair competition and antitrust law
All laws and regulations that promote and protect competition must be observed. The applicable antitrust laws must also be applied; in dealings with competitors these prohibit in particular agreements and other activities that influence prices or terms. These rules further prohibit agreements between customers and suppliers intended to restrict customers’ freedom to determine their resale prices and other terms autonomously. Our suppliers do not enter into any agreements or concerted practices with other companies that have as their object or effect the prevention, restriction or distortion of competition under the applicable antitrust rules, and do not unlawfully exploit any dominant market position.
9. Integrity, bribery and corruption
Our company upholds the principle of strict legality for all actions, measures and contracts. Accordingly, we expect our suppliers to comply with the respective applicable laws, the fundamental principles of the United Nations Global Compact and this code of conduct in the course of their business activities with WETHJE, and to work towards compliance with this code of conduct by third parties engaged in the performance of contracts with WETHJE. The highest standards of integrity must underpin all business activities.
There is an absolute prohibition on all forms of bribery, corruption, extortion and embezzlement. Procedures for monitoring and enforcing the standards must be applied to ensure compliance with anti-corruption laws. The supplier must review the effectiveness of the rules in place at regular intervals.
10. Avoidance of conflicts of interest
Suppliers make decisions on the basis of objective considerations and do not allow themselves to be improperly guided by personal interests.
11. Money laundering
Suppliers observe the relevant statutory provisions on the prevention of money laundering.
12. Export controls and economic sanctions
Numerous countries have enacted laws on the export control of strategic products, technology and software. Suppliers undertake to comply with these laws and regulations. Non-compliance may result in civil or criminal sanctions, including fines, imprisonment, loss of export licences, debarment, revocation of previously granted licences, and seizure and forfeiture of goods. Given the enormous importance of complying with all applicable export control regulations, suppliers and their sub-suppliers who knowingly contravene such controls expose themselves to corresponding disciplinary measures.
