Smidt-imex Group (hereinafter “the Company”), has agreed to abide by moral and ethical values in the management of the company, based on the fairness, honesty, transparency and in respect with the standards in force at national and international level. The Company, therefore, expects its third party suppliers to respect and adhere to the same philosophy in the management of their own companies.

The present Code of Conduct (hereinafter “the Code”), expression of the Company’s principles and values, requires strict compliance with these standards by all its suppliers, manufacturers and their subcontractors (hereinafter “Suppliers”).

Any breach of conduct or any violation of this code of conduct by Suppliers or their subcontractors will result in a review and possible termination of the business relationship.



The Company has decided to follow and require its suppliers to follow the Code described in this document. Suppliers shall comply with the laws, regulations and usual practices in terms of work in force in their own countries, and in particular, the following rules considered by the Company as fundamentally important:

Child Labor: Work by children under the age of 16 is strictly prohibited. In countries where local laws set a higher age for child labor or impose mandatory education beyond the age of 16, this higher age shall apply.

Forced and Compulsory Labor: The use of labor with no work permit or the use of labor in another social and occupational group or in another geographical zone than the one mentioned on the work permit, is strictly prohibited. The use of forced labor by Suppliers, whether obtained under the threat of punishment, withholding identity papers, requiring workers to deposit a bond or any other constraint is strictly prohibited.

Health and Safety: Based on the specific risks present in their industrial sector, Suppliers shall provide a safe and healthy workplace to avoid accidents or bodily injuries which may be caused by, associated with, or result from the work or from handling the equipment. They shall set up systems to detect, avoid or neutralize any threat to their employees' health and safety and comply with local and international regulations and laws currently in effect. The same principles shall apply to suppliers who provide housing to employees.

Freedom of Association and Right to Collective Bargaining: The Company expects Suppliers to respect and recognize the right of each employee to negotiate collectively, to create or join the union organization of their choice and without penalty, discrimination or harassment.

Discrimination: The Company expects Suppliers to treat all employees equally and fairly. Suppliers shall not practice any kind of discrimination in relation to hiring, access to training, promotion, or dismissal based on gender, race, religion, age, disability, sexual orientation, political opinions, nationality, or social or ethnic origin.

Disciplinary Practices: The Company expects Suppliers to treat their employees with respect and dignity. Suppliers shall not allow or engage in any kind of corporal punishment, psychological or physical harassment or any other kind of abuse.

Working Hours: In relation to working hours and overtime, Suppliers shall comply with the limits set by the laws of the country of manufacture. Suppliers may not impose excessive overtime.

Remuneration: As a minimum, Suppliers shall pay regular wages and pay for overtime at the legal rate imposed by the country of original manufacture and provide their workers with the benefits the law currently requires. If there is no legal minimum wage or overtime pay in the country of origin, Suppliers shall ensure that the wages are at least equal to the average minimum in the industrial sector in question and that overtime pay is at least the same as the usual rate of pay. Deductions from wages are not to be made for disciplinary purposes without consensus.



Suppliers shall conduct their activity in a loyal manner, in all sincerity, with diligence, efficiency and rectitude. Suppliers shall particularly pay attention to the following aspects:

Legal Requirements: The Company expects Suppliers to act in full compliance with the law. Suppliers shall abide by all national, local and international laws relating to the management of their businesses.

Administration and balance sheet: Balance sheet preparation and any other accounting documentation shall respect the laws and regulations in force, comply with the accounting practices and principles the most advanced, and be transparent to represent the management acts in a reliable manner, and based on criteria of clarity, accuracy and rectitude, in respect with the internal procedures.

Relations with the public administration: Suppliers shall not offer, directly or through an intermediary, money or any other advantages of any kind to a public agent, to his/her family or any other person related to him/her, and shall not seek or establish personal relationship of favor, influence, intrusion with the objective to condition directly or indirectly the business activity.

Subcontractors: Suppliers shall receive Company’s approval before subcontracting any part of the manufacturing process. The Company’s approval is subject to acceptance by the subcontractors of this Code and all other applicable conditions.

Customs and Security Authorities: Suppliers shall comply with applicable customs laws, including those relating to imports and the ban on the transshipment of merchandise into the country of import.

Anti-corruption: Suppliers shall agree to condemn and act against corruption in all its forms, including extortion and kickbacks. Suppliers shall not offer, directly or through an intermediary, money or any other advantages of any kind to the Company’s employees with the objective to condition directly or indirectly the business activity.


Any information – project, document, sample, prototype, etc. - brought to the vendor’s knowledge in the course of the fulfillment of its contractual obligations, shall be considered as confidential and treated as such.

All brands and distinctive signs belonging to Company or used by it in the course of its activity shall not be used for any other purpose but the identification of products in accordance with the instructions received from the Company.

The service fulfilled by Suppliers for the benefit of the Company shall not give the Suppliers any kind of intellectual property rights on the distinctive signs and creations of the Company, specifically but not limited to drawings, products, prototypes, samples, projects, plans, equipment, pictures, norms and tools that are used by or belong to the Company. The use of such elements out of the strict frame defined by the Company would constitute an offense of infringement of patent and give rise to civil and/or criminal proceedings.

Suppliers commit to destroy in accordance with the Company’s instructions, any finished or semi-finished products specifically manufactured for the company, carrying the distinctive signs belonging to or used by the Company and/or its Customer or committing the Company’s image, in case they were not ordered or did not pass the Company’s quality controls.



The Company expects Suppliers to share their commitment to a clean and safe environment. The Company encourages initiatives to reduce the impact on the environment, particularly through the use of environmentally-friendly technologies. Suppliers shall agree to respect local and international environmental laws.

Suppliers shall adopt proper waste management with special attention to hazardous wastes and emissions, which may not be dumped or discharged in an unlawful manner. Suppliers’ employees whose work has a direct impact on the environment shall be trained, competent and having the necessary resources to do their jobs.



The Company reserves the right to check adherence to these principles and to arrange system audits at any time. Suppliers shall provide the necessary information and allow access for the Company’s representatives who seek to verify compliance with the requirements of this Code. They shall agree to improve and correct any non-compliances discovered.

Suppliers shall keep proper records to prove compliance with this Code. Suppliers shall provide access to complete, original, and accurate files to the Company’s representatives.





Smidt-imex Group生柏有限公司/ 广州柏铿进出口贸易有限公司(以下简称『本公司』)同意,基于公正、诚实、公开,依照国内和国际标准遵守公司管理道德规范。本公司亦要求供货商以相同标准管理公司。






















反贪污: 供货商应谴责并反对贪污,包括敲诈与回扣。供货商不应直接或透过中间人提供金钱或其他好处给本公司员工以换取直接或间接商业利益。