Supplier Code of Conduct

At Electrosonic, we are committed to a standard of excellence in every aspect of our business, to ethical and responsible conduct in all our operations, to the respect of the rights of all individuals, and to respect for the environment. We expect suppliers, as well as subcontractors, who do business with us to share these same commitments. Electrosonic and its affiliates strongly encourage you (“Supplier”) to meet the following standards in all activities that relate directly or indirectly to us. We will evaluate your compliance with these standards in determining whether to grant or continue your preferred status. Suppliers that do not conform to these standards may be disqualified from preferred status and/or have their business relationship with Electrosonic terminated.


Supplier will comply with all applicable wage and hour laws and regulations, including those relating to minimum wages, overtime, and other elements of compensation, and will provide all legally mandated benefits.

Hours of Work

Supplier will maintain work hours in compliance with all applicable wage and hour laws and regulations. Supplier will not require employees to work more than any limits on regular and overtime hours allowed by any applicable local law.

Forced Labour

Supplier will not use forced or involuntary labour, including prison, bonded, indentured, or otherwise. Supplier will comply with the provisions of the UK Modern Slavery Act 2015 where applicable and will take adequate steps to ensure that human trafficking and slavery does not occur in its organisation and supply chain. In the event of any non-compliance, Supplier will notify Electrosonic immediately.

Child Labour

Supplier will not use child labour. “Child” is any person who is either (1) younger than 16, or (2) younger than the minimum age required for the employment under applicable law. Supplier will comply with all applicable laws and regulations regarding the employment of minors.

Coercion and Harassment

Supplier will treat each employee with respect, and will not engage in or permit corporal punishment, threats of violence, or other forms of harassment whether based on age, physical or mental disability, gender, marriage or civil partnership, pregnancy and maternity, race (including colour, nationality, ethnic or national origin), religion/belief or lack of religion/belief, sexual orientation, or any other legally protected characteristic.

Data Protection

Supplier will handle personally identifiable data in accordance with all applicable data protection laws, including maintaining data security, and where processing such data on behalf of Electrosonic will comply with Electrosonic’s lawful instructions.


Supplier will not discriminate in hiring practices or any other condition of work on the basis of age, physical or mental disability, gender, marriage or civil partnership, pregnancy and maternity, race (including colour, nationality, ethnic or national origin), religion/belief or lack of religion/belief, sexual orientation, or any other legally protected characteristic.

Workplace Safety and Emergency Planning

Supplier will provide a safe and healthy workplace for employees by endeavouring to meet or exceed international safety standards. Supplier must have a comprehensive business continuity plan, including procedures in place for handling emergencies such as data loss, fire, and natural disasters.

Environmental Protection

Supplier will comply fully with all applicable environmental laws, and seek ways to conserve natural resources and energy, reduce waste and the use of hazardous substances, and minimize any adverse impacts on the environment.

Compliance with Applicable Laws

 Supplier will comply with all laws and regulations applicable to their business, as well as the standards of its industry, including those relating to the manufacture, pricing, sale, distribution, labelling, import, and export of merchandise. Without limiting this requirement, Supplier will not: (A) violate, misappropriate or infringe upon the intellectual property rights of Electrosonic and its affiliates or any third party; or (B) engage in any activities which would violate any applicable laws and regulations relating to (1) bribery or illegal payments (including the UK Bribery Act and the US FCPA), (2) laws against unfair competition, (3) unfair and deceptive trade practices, (4) the environment, (5) health and safety, (6) international trade, including exports and imports, (7) data protection, (8) money laundering, (9) employment, or (10) contracting with governmental entities.

Commercial Bribery

Supplier will not bribe or offer a bribe to any officer, director, manager, employee, representative or agent of Electrosonic, its affiliates, or any other person, organisation or entity in Electrosonic’s name or on its behalf, including without limitation, by offering or giving kickbacks or by offering or giving gifts of more than nominal value with the intention of securing an unwarranted business advantage.

Accounting Records

Supplier’s accounting records must (1) be kept and presented according to the laws of each applicable jurisdiction, (2) in reasonable detail, accurately and fairly reflect transactions, assets, liabilities, revenues and expenses, and (3) not contain any false or misleading entries.

Conflicts of Interest

Supplier must immediately report to Electrosonic any "conflict of interest" of which they become aware. A “conflict of interest” is any circumstance, transaction or relationship directly or indirectly involving the Supplier in which the private interest of any employee of Electrosonic or any of its affiliates improperly interferes, or even appears to improperly interfere, with the interests of Electrosonic and its affiliates.


In addition to any restrictions on the use of subcontractors that are otherwise agreed to between the Supplier and Electrosonic or its affiliates, Supplier will not use any subcontractor in connection with any Electrosonic or affiliate business unless the subcontractor has received a copy of this Code of Conduct and agreed to comply with its terms.

Monitoring and Compliance

Supplier understands that Electrosonic, its affiliates, or our designated agents (including third parties) may engage in monitoring activities to assess compliance with this Code of Conduct including on-site inspection of facilities and review of books and records. Notwithstanding this fact, Supplier understands that Supplier is solely responsible for full compliance with this Code of Conduct by its officers, directors, managers, employees, representatives and agents.

Management System and Communication

Supplier must establish and maintain processes that are reasonably designed to ensure compliance with, mitigate the risks identified in, and facilitate continuous improvement with respect to, this Code of Conduct. Supplier must ensure that this Code of Conduct is adequately communicated to all employees. Supplier should immediately notify Electrosonic upon learning of any known or suspected improper behaviour by Supplier or Supplier’s subcontractors or by employees of Electrosonic or its affiliates.


Last updated: December 9, 2022