Code of Conduct
Version 1.0, Published December 26, 2024
Last updated
Version 1.0, Published December 26, 2024
Last updated
At Dispel, we only work with suppliers that share our commitment to integrity, sustainability and human rights and have agreed to meet the requirements set out in this Supplier Code of Conduct.
Dispel's purpose is to enable a more secure, efficient future for operations, manufacturing, and industrial systems. In keeping with our purpose, Dispel is committed to maintaining the highest standards of integrity and transparency, and complying with all applicable laws and regulations across its global business operations. Given that the conduct of Dispel's suppliers and sub-processors can have a substantial impact on both Dispel and its stakeholders, we require all suppliers to adhere to similar legal standards and values as Dispel.
“Suppliers” refers to third parties—including individual contractors, vendors and sub-processors—that Dispel engages to purchase goods and/or services and/or works. The Supplier Code of Conduct does not apply to end-use customers.
As a Dispel supplier, you comply with all applicable laws and regulations wherever you operate, observe the principles reflected in Dispel’s Code of Conduct, and meet the requirements set out in this Dispel Supplier Code of Conduct, as well as your contractual obligations to Dispel.
We cannot cover every situation that may arise in this Code of Conduct, so we ask that you, as our supplier, be thoughtful and ethical. The Supplier Code should be viewed as the minimum standards that we expect from our supplier community. Dispel will assess a Supplier’s commitment to compliance with these requirements when making procurement and sourcing decisions.
We require our suppliers to respect the same international human rights principles and standards as Dispel. You shall respect the personal dignity, privacy and rights of each individual and refrain from making anyone work against his or her will. You will also prohibit behaviors, practices and threats that are intended to cause or are likely to result in physical, psychological, sexual or economic harm, including gender-based violence and harassment. In particular, you will:
Refrain from discrimination, harassment and retaliation based on gender, age, ethnicity, nationality, religion, disability, union membership, political affiliation, sexual orientation or other characteristics protected under local law and ensure equal and fair treatment of all workers;
Not hire individuals under 15 years of age, or 14 years of age where local law allows, consistent with ILO Convention number 138, or under the legal minimum age for employment in the country, whichever is greatest;
Ensure that any young workers (under the age of 18) in your employ are protected from performing any work that may harm their physical or mental development, interfere with their education, or compromise their potential or dignity;
Conduct human rights due diligence to identify, assess, eliminate or mitigate the risks of potential adverse effects related to forced and/or child labor in your supply chain. Adopt a traceability system that records information on product origins, suppliers and processing steps regarding forced labor and child labor. Develop a risk management plan to monitor and identify risks in the supply chain relating to forced labor and child labor;
Not use any form of and allow all workers the freedom to leave their employment upon reasonable notice;
Unless stipulated by applicable law, not require workers to surrender their original personal certificates and identifications, such as government-issued identification, passports or work permits, as a condition of employment;
Compensate workers fairly and in a timely manner. Follow local wage and overtime payment regulations and / or collective agreements. Where these do not exist, compensate employees so at the minimum they can meet their basic needs;
We do not tolerate any form of bribery or corruption and only enter into business relationships with third parties that share our ethical standards.
You shall conduct your business in an ethical manner. In particular, you will:
Not commit or become involved in, and seek to prevent, any form of bribery, corruption, fraud, theft, money laundering, unlawful tax evasion or any other violation of applicable laws;
Ensure that no payments (including facilitation payments), gifts or any other commitments are made to Dispel customers or employees, public officials or any other party in order to obtain or retain business, secure an improper advantage or influence someone to improperly perform their duties;
Adhere to antitrust and other competition laws and have in place effective processes and procedures to prevent anti-competitive behavior, and conduct your business in line with fair competition;
Disclose to Dispel information regarding any actual, potential or perceived conflicts of interest relating to your activities as an Dispel supplier, including disclosure of any financial interest that an Dispel employee, customer or their relatives or other proxy may hold in your business;
Respect the intellectual property rights of Dispel and others. Secure and protect all confidential information provided by Dispel and our respective business partners;
Comply with all applicable international trade and export control regulations and, in particular, properly classify and obtain all applicable approvals, licenses and certificates prior to export or transfer of products, technology or software.
Do not give gifts to influence Dispel Do not offer, provide, or solicit gifts or entertainment that might compromise a Dispel employee’s judgment or independence. This includes, but is not limited to:
Cash, cash equivalents, such as gift cards, gifts or charitable contributions individually or cumulatively valued at more than $150 in any one year; and
Entertainment that is lavish or that takes place in a location inconsistent with Dispel’s values
We use our assets responsibly and only for legitimate business purposes that are consistent with Dispel’s interests and rights and in accordance with our rules and governance.
You shall conduct your business in a secure manner, taking care of the safety and security of people as well as physical assets and information or data assets. In particular, you will:
Implement reasonable measures for minimizing exposure of Dispel to security threats such as cyberattacks, theft, and crime;
When visiting or working at Dispel locations, follow Dispel’s security procedures and report any security concerns through the appropriate Dispel channels;
Implement and maintain appropriate physical, technical and organizational measures to protect Dispel information and assets from destruction or unauthorized disclosure;
Adhere to applicable information security and cybersecurity regulations and standards, and immediately report to us any suspected or actual incidents that may impact Dispel information or systems;
Observe all applicable data-privacy regulations and laws on the collection, processing and transfer of personal data and cooperate in good faith with Dispel to ensure compliance with the aforementioned requirements.
We are committed to a transparent and competitive sourcing process and to dealing fairly and responsibly with our suppliers.
You shall procure goods and services in a responsible manner. In particular, you will:
Require your suppliers (including but not limited to labor agents or agencies, material suppliers and subcontractors) to respect standards consistent with the Dispel Supplier Code of Conduct and include your requirements in agreements with your suppliers;
Effectively communicate these principles along your supply chain and implement a process to verify supplier performance;
Inform Dispel immediately if you suspect a violation of these principles has taken place in your supply chain and work with your suppliers to mitigate and prevent further violations and remediate negative events that have occurred in the past;
When working at Dispel locations, only subcontract work with prior consent from Dispel.
We expect you to create a comprehensive overview of your supply chain, also known as supply chain mapping, so you can quickly identify and mitigate risks in terms of all topics covered in this Supplier Code of Conduct.
We comply with all regulations and laws on reporting or disclosure of human rights and environmental due diligence and take appropriate actions in a timely manner to address non-compliances or implement improvements.
To ensure and demonstrate compliance with the Dispel Supplier Code of Conduct, you will:
Comply with all regulations and laws regarding public reporting or disclosure on human rights and environmental due diligence, including laws requiring public disclosures on due diligence on modern slavery and child labor across the supplier’s value chain;
Create and maintain relevant documentation and provide supporting documentation to Dispel upon request;
Report to Dispel without undue delay in writing any identified risks to and violations of the principles outlined in this Supplier Code of Conduct and take appropriate corrective actions to prevent, end or mitigate the risk or violation.
To verify your compliance, we reserve the right to audit and inspect your operations, upon reasonable notice, with your consent. Such consent shall not be unreasonably withheld. If the results of such an audit or inspection show that you do not comply with this Dispel Supplier Code of Conduct, you shall take necessary corrective actions in a timely manner as directed by us.
If you fail to comply with this Dispel Supplier Code of Conduct, or fail to take necessary corrective actions to remedy violations of the Dispel Supplier Code of Conduct within a reasonable timeframe, Dispel reserves the right to take action against you, including suspending or terminating your activities as one of our suppliers.
This glossary explains important terms used in the Dispel Supplier Code of Conduct and implementation guide. It is based on universally accepted definitions, which have been edited for clarity and ease of understanding.
Child labor is often defined as work that deprives children of their childhood, their potential or their dignity. It refers to work that is mentally, physically, socially or morally dangerous and harmful to children and/or interferes with their schooling. Child labor also refers to employment of children who are underage or who do excessively long and heavy or hazardous work as determined by the laws of a state.
Employees include any staff or personnel engaged or employed by a supplier, including temporary labor engaged via labor agents or agencies.
Facilitation payments are payments made to a public official to facilitate or expedite the performance of routine governmental action (e.g., processing papers, issuing permits) that the person or company making the payment is legally entitled to receive.
Grievance mechanisms are formal, legal or non-legal (or “judicial/non-judicial”) complaint processes that can be used by individuals, workers, communities and/or civil society organizations that are negatively affected by certain business activities and operations.
Human rights refer to the basic rights and freedoms that belong to every person in the world, simply because they are human beings. They define the minimum standards necessary for people to live with dignity, freedom, equality, justice and peace. They are inherent to everyone, irrespective of race, gender, language, religion, political or other opinion, national or social origin, property, birth or status. The Universal Declaration of Human Rights, adopted by the United Nations General Assembly in 1948, establishes the fundamental rights and freedoms of all human beings.
Modern slavery is an umbrella term covering practices such as forced labor, debt bondage, child labor, forced marriage, involuntary prison labor, victims of slavery and human trafficking.
Suppliers refers to a third parties, including individual contractors, that Dispel engages to purchase goods and/or services and/or works.