A. PURPOSE

Viega LLC (“Viega”) is committed to conducting its business in accordance with the highest ethical standards, maintaining integrity, acting responsibly and sustainably, and complying with applicable laws in all aspects of its business operations. Further, Viega believes that achieving economic success and upholding its company values are not mutually exclusive: organizations that operate ethically and with integrity build value over time and have the best chance for long-term success. Therefore, Viega requires that its “Suppliers” and “Third Parties” (each defined below) not only understand its high ethical standards but conduct their businesses with the same level of care.

B. SCOPE 

This Supplier Code of Conduct (this “Code”) describes the fundamental social and ecological principles and values that Viega requires its business partners to observe and applies to all Suppliers and Third Parties that desire to do business with Viega. Failure to comply with this Code may result in corrective action up to and including termination of all existing and future business.

“Supplier” means any business, company, organization, entity, or person that: (i) sells or seeks to sell any kind of goods or services to Viega, or (ii) performs or seeks to perform services for on behalf of Viega. A Supplier includes a Supplier’s affiliates, sub-suppliers (i.e., a Supplier’s supplier), and contract manufacturers or agents.

“Third Party” means any Supplier, as well as any business or individual that acts as an agent, sales representative, distributor, or reseller for Viega.

C. APPLICATION

1. Compliance with Laws

Viega expects its Third Parties to comply with all applicable laws, rules, and regulations while conducting its business, including when doing so on behalf of Viega. Further, Third Parties should implement effective systems and controls in order to ensure such compliance and foster a culture that values ethics and integrity in its business dealings.

2. Child and Forced Labor

All persons performing work for a Third Party must meet minimum age limits in accordance with applicable law, international treaties, and domestic regulations.  Child Labor is strictly prohibited. Third Parties must not engage in forced, bonded, or indentured labor, slavery or servitude, human trafficking, compulsory labor, or involuntary prison labor. All work must be voluntary.  If any shipment is stopped by US Customs on suspicion of materials derived by forced labor, Supplier shall provide necessary evidence to Viega within 15 days of the detention date.

3. Human Rights and Working Conditions

Harassment, including sexual harassment, sexual abuse, mental or physical coercion, or verbal abuse of workers by Third Parties is prohibited. Third Parties must also treat its employees and agents with dignity and respect and shall not violate any other rights if any such group. Third Parties must set work times, and wages, including overtime wages, and working conditions in accordance with applicable laws.  Viega values the diversity of employees and expects its Third Parties to act similarly by maintaining policies that encourage workplace respect and that seek to hire and retain the best employees at all levels of the company without regard to race, color, religion, sex, sexual orientation, national origin, disability, or veteran status.

4. Environmental, Health and Safety

Viega expects Third Parties to comply with all applicable environmental laws and regulations, as well as provide a workplace environment that is safe, secure, and in compliance with all applicable health and safety standards.

5. Anti-Bribery and Corruption

Viega expects Third Parties to prohibit all forms of corruption including the paying or accepting of bribes and other forms of improper payments in the course of any business dealings. Third Parties shall also cause each of its subcontractors and/or suppliers and the agents and employees of each of them to comply with applicable anti-bribery and corruption laws. In particular, the U.S. Foreign Corrupt Practices Act (“FCPA”) prohibits offering or paying any money or other item of value, directly or indirectly, to any government official, candidate for political office, or political party for the purpose of improperly obtaining or maintaining business or influencing favorable governmental action. Further, Third Parties are prohibited from offering, promising, or providing anything of value in connection with any transaction involving Viega. Third Parties are expected to have adequate procedures in place to prevent their employees from engaging in such actions, including training employees on the requirements of applicable anti-bribery and corruption laws.

6. Competition

Viega is committed to following both the letter and spirit of law when it comes to promoting free and open competition. These concepts generally address the following areas: relations with competitors, pricing practices (including price discrimination), discounting terms of sale, promotional allowances, secret rebates, and product bundling, among others. As a result, Third Parties are prohibited from engaging in any misappropriation of confidential information, price fixing, bid rigging, or collusive conduct in connection with any transaction involving Viega, and are expected to understand and comply with all applicable anti-trust and competition laws. Finally, gifts, money, entertainment, services, discounts, or other similar privileges may not be offered to any Viega employees or agents in order to obtain favorable treatment from Viega. Under no circumstances should any Viega employee or any party operating on Viega’s behalf use gifts or entertainment to secure business or gain an improper or competitive advantage.

7. Fair Dealing and Conflicts of Interest

Third Parties shall not take unfair advantage of Viega through abuse of privileged or proprietary information, misrepresentation of material facts, or any other unfair or dishonest practices, including implementing effective systems and controls to keep accurate books and records. Third Parties shall not enter into a financial or any other relationship with a Viega employee that creates any actual, potential, or even the appearance of a conflict of interest between the employee’s personal interests and those of Viega’s business. Viega employees may not serve as officers, directors, employees, agents, or consultants of Third Parties, except with the consent of appropriate Viega leadership. All conflicts discovered by Third Parties must be promptly disclosed and resolved to Viega’s satisfaction.

8. Privacy and Intellectual Property

Viega takes the privacy of businesses and individuals, including employees and customers very seriously. Third Parties should be familiar and comply with those laws that apply to them and safeguard all data provided by Viega, which may include private and sensitive personal information. Personal information should never be disclosed except as permitted by law. Third Parties shall not misappropriate or misuse the intellectual property and confidential information of Viega. Third Parties may use such property and information only upon obtaining authorization from Viega and only for the limited purpose authorized. Third Parties in possession of Viega’s intellectual property or confidential information must take appropriate actions to safeguard the same against the unauthorized disclosure or misuse of such property and information.

9. Customs and Trade

Third Parties will comply with all applicable trade control laws and regulations in the import, export, or transfer of Viega products. Viega is committed to strict compliance with applicable laws and regulations, including without limitation, U.S. export controls, anti-boycott, and trade sanctions laws and regulations. Third Parties shall have policies and procedures in place to ensure compliance with these legal requirements as they relate to Viega products and services. Upon request from Viega, a Third Party will provide applicable country of origin, harmonized tariff code and any dual use or export control classification numbers for products the Third Party provides to Viega. In addition, Viega is a member of the US Customer Trade Partnership Against Terrorism (CTPAT) program and will request confirmation of compliance with the program’s Minimum Security Criteria (MSC) from Third Parties on an annual basis. Viega may request countermeasures or implementation of certain processes in order to comply with its membership obligations. If a Third Party participates in CTPAT or another approved Authorized Economic Operator (AEO) program with a Mutual Recognition Arrangement (MRA), then that Third Party’s participation is deemed to be acceptable proof of meeting the program requirements. Viega may request evidence of such participation at any time.

10. Third Party Compliance Program

Third Parties must adopt or establish a compliance program designed to ensure compliance with this Code, applicable laws and regulations, as well as identify and mitigate related operational risks and facilitate continuous improvement in these matters. Third Parties are expected to have adequate monitoring and record keeping systems to verify such compliance. Third Parties are also responsible for ensuring that their subcontractors and agents comply with this Code. Viega reserves the right to monitor, review, and verify compliance with this Code and take appropriate actions in the event of noncompliance.

11. Reporting Violations or Concerns

Third Parties must comply with this Code in all aspects of their dealings with, for, or on behalf of Viega. Third Parties must establish a system allowing workers to report any concerns applicable to this Code or any other applicable laws without risk of retaliation. Subject to applicable laws and regulations, Third Parties are expected to promptly notify Viega on any noncompliance involving or affecting Viega. The duty to report applies regardless of whether the concern involves the Third Party. In addition to reporting concerns, Third Parties are expected to cooperate and assist Viega in the investigation of a reported matter, if necessary. A concern or suspected violation of law or this Code may be reported by any of the methods listed below. Anonymous reporting is available except where prohibited by local laws.

(i) General Counsel and Chief Compliance Officer at compliance@viega.us

(ii) Through the Ethics and Compliance Hotline at 800-290-2720.

12. Consent

By virtue of doing business with Viega and being a Viega Supplier or Third Party, you agree to comply with this Code and communicate its principles to your employees and agents. If a Third Party does not consent to this Code, it must issue an active rejection to Viega using the contact email address above.