Sharp’s suppliers are an integral part of the overall success of Sharp. Each day, Sharp and its suppliers make decisions that impact Sharp’s ability to provide quality health care products and services to its customers.
This document outlines the principles, guidelines, and expectations for establishing and maintaining a business relationship with Sharp. Sharp is committed to having business relationships with suppliers who share the company’s dedication to providing quality products and services and conducting business in a legal and ethical manner. Because our suppliers are an extension of our business, we have the same expectations for them.
Sharp expects our suppliers to have their own supplier code of conduct/ policy in place and that it be provided to Sharp on request. Sharp expects suppliers to conduct their business to minimize environmental impact and avoid having adverse health impacts on communities.
All Sharp suppliers are expected to understand and comply with the “Sharp Supplier Code of Conduct.”. All suppliers shall cooperate fully with Sharp’s supplier ESG engagement platform ‘Integrity Next,’, audits and assessments designed to address the topics Environmental, Social & Governance (ESG) management. Suppliers are strongly encouraged to contact a Sharp Strategic Sourcing representative to discuss any questions.
Suppliers are also strongly encouraged to contact Sharp Strategic Sourcing whenever there are questions relating to the appropriateness of any activity. Strategic Sourcing employees can provide an overview and further guidance on applicable Sharp policies.
Sharp reserves the right to verify a supplier’s compliance with the “Sharp Supplier Code of Conduct”. If Sharp becomes aware of any actions or conditions not in compliance with the “Sharp Supplier Code of Conduct,” Sharp reserves the right to seek corrective action.
Kevin Orfan
President & CEO, Sharp
Ethics
Suppliers shall conduct their business in an ethical manner and act with integrity. Sharp
expects suppliers to comply with all legal and regulatory requirements regarding ethics including:
Conflict of Interest
A conflict of interest exists whenever there is a competing interest that may interfere with our ability to make an objective decision and act in the best interest of Sharp. Sharp, along with suppliers, are expected to use good judgment and to avoid situations that can lead even to the appearance of a conflict that may undermine the trust others place in us.
Suppliers that do business with Sharp shall not have any competing interest that may interfere with their ability to make objective decisions to act in the best interest of Sharp. Good judgment is expected as well as avoiding the appearance of a conflict of interest.
All suppliers shall notify Sharp immediately in the event of a potential or actual conflict of interest.
Business Integrity and Fair Competition
Suppliers shall conduct business competitively and in full compliance with all applicable laws, codes, and regulations. Suppliers shall not pay or accept bribes or participate in other illegal inducements in business or government relationships. Suppliers shall employ fair business practices including accurate and truthful advertising.
Suppliers agree to comply with the applicable provisions of the Sharp Conflicts of Interest Policy, including the following concepts related to interactions with Sharp employees:
- Employees shall deal with all suppliers, customers, and all other persons doing business with Sharp in a completely fair and objective manner without favor or preference based on personal financial considerations or personal relationships.
- Employees shall not accept or provide (directly or indirectly) gifts, prejudicial discounts, payments, fees, loans, entertainment, favors or services from any person or firm, which may influence or give the appearance of influencing purchasing decisions.
- No employee shall do business on behalf of Sharp with a close relative or own any financial interest in a supplier’s business where the Sharp employee has the appearance or ability to impact the supplier’s relationship with Sharp. Such relationships must be disclosed per Sharp policies.
- No employee shall grant permission for use of Sharp’s name and/ or logo without permission from Sharp
Sharp contract workers and agents (for example, consultants, contract sales forces, speakers, distributors, clinical investigators, etc.) must also comply with the applicable provisions of the Sharp Code of Business Conduct.
Sharp employees and suppliers are expected to report violations or possible violations of the Sharp Supplier Code of Conduct to Legal@SharpServices.com and to Sharp Strategic Sourcing or to the Sharp Senior Leadership Team.
Identification of Concerns
Suppliers shall be encouraged to report concerns or illegal activities in their relationship with Sharp without threat of reprisal, intimidation, or harassment. Sharp will review the concerns and respond to them in a timely manner.
Suppliers shall not use or disclose Sharp confidential information other than with the express prior written consent of, and for the benefit of, Sharp. Suppliers shall not exchange or otherwise disclose Sharp confidential information with any competitor or other supplier. Any information or data regarding Sharp operations shall always be treated as strictly confidential unless that information is in the public domain. Confidential information includes, but is not limited to:
- Purchase material specifications and conditions
- Requests for quotation
- Cost sheets
- Profit information
- Asset information
- Names of suppliers
- Pricing
- Purchase strategies
- Contact details
- Financial/sales/marketing information
- Operating processes/formulas and other know-how which are Sharp property and have not yet been disclosed to the public
- Sharp Intellectual Property (IP)
- Computer software programs
- Personal information about employees, offices, and directors
- Wage and salary scales
- The Sharp name or logo
Sharp shall require that suppliers confirm these obligations by entering into confidentiality agreements about any of the previously listed confidential information and to ensure that company, worker, and patient privacy rights are protected.
Sales Techniques
Suppliers are expected to interact with Sharp in an open and honest manner. The following sales techniques are strictly prohibited:
- Backdoor selling – circumventing the proper Sharp channels to convince an individual to purchase a specific product or service.
- Making commitments to provide a product or service without having the capacity to meet the commitment.
- Request for competitor information: asking for information regarding a competitor’s product, pricing, terms, distribution, or other segment of their business.
- Offering gifts more than nominal value.
- Providing pricing structures that are less favorable to Sharp if the supplier is the single or sole source for the goods or services provided.
- Requesting Sharp to accept a proposal after the closing date.
- Suppliers and business partners are not permitted to directly or indirectly promise, offer, or provide any improper advantage to any person or entity
Supplier Visitation Process
Suppliers have limited access to Sharp facilities. The following procedures are to be followed by all Sharp suppliers:
All suppliers should notify in advance of their intention to visit and are required to register with the receptionist or site security for access to the facility.
- Suppliers are to be always accompanied by a Sharp employee.
- Suppliers are never to occupy a Sharp employee’s office or cubicle without displaying proper Sharp-issued identification.
- Suppliers, upon departure of Sharp property, are to leave their visitor badges with the receptionist.
- Sharp host/sponsor is responsible for suppliers while on site.
Labor
Suppliers shall be committed to fair treatment of their employees and to treat them with dignity and respect. Sharp expects suppliers to comply with all legal and regulatory requirements pertaining to the fair and equitable treatment of employees including:
Freely Chosen Employment
Suppliers shall not use forced, bonded, or indentured labor, involuntary prison labor or human trafficking.
Child Labor and Young Workers
Suppliers shall not use child labor. The employment of young workers below the age of 18 shall only occur in non-hazardous work and when young workers are above a country’s legal age for employment, or the age established for completing compulsory education. Employee files should be maintained with adequate data to verify the ages of employees.
Non-Discrimination
Suppliers shall provide a workplace free of harassment and discrimination. Harassment or discrimination for reasons such as race, color, age, gender, sexual orientation, ethnicity, disability, religion, political affiliation, union membership or marital status is not condoned or tolerated. Sharp expects suppliers to share its commitment to equal opportunity in employment and its commitment to employee diversity.
Fair Treatment
Suppliers shall provide a workplace free of harsh and inhumane treatment. This includes, but is not limited to, any sexual harassment, sexual abuse, corporal punishment, mental or physical coercion or intimidation of workers.
Wages, Benefits and Working Hours
Suppliers shall pay workers according to applicable wage laws, including minimum wages, overtime hours and mandated benefits as per custom of the country of employment. Suppliers shall communicate with the worker on the basis on which they are being compensated in a timely manner. Suppliers are also expected to communicate with the worker whether overtime is required and the wages to be paid for such overtime. Suppliers shall keep accurate records regarding employee working hours and vacation hours. Open communication and direct engagement with workers to resolve workplace and compensation issues is encouraged.
Freedom of Association
Suppliers shall respect the rights of workers, as set forth in local laws, to associate freely with one another. Workers shall be able to communicate openly with management regarding working conditions without threat of reprisal, intimidation, or harassment.
Health and Safety
Suppliers shall protect workers in the workplace, and in any company-provided living quarters, by providing a safe and healthy environment. Sharp expects suppliers to comply with all standard, legal, and regulatory requirements regarding employee health and safety.
Environment
Suppliers shall operate in an environmentally responsible and efficient manner and shall strive to minimize adverse impacts on the environment. Suppliers are encouraged to conserve natural resources, to avoid the use of hazardous materials where possible, and to promote activities that reuse and recycle. Sharp expects suppliers to comply with all laws, regulations, standards, ordinances, rules, permits, license approvals and orders regarding the environment and the use of restricted substances. Please also refer to the Sharp Environment, Health and Safety policy.
Environmental Authorizations
Suppliers shall obtain all required environmental permits, licenses and approvals and comply with all applicable operational and reporting requirements.
Waste and Emissions
Suppliers shall have systems in place to ensure the safe handling, movement, storage, recycling, reuse or management of waste, air emissions and wastewater discharges. Any waste, wastewater, or emissions with the potential to adversely impact human or environmental health shall be appropriately managed, controlled and treated prior to release into the environment.
Spills and Releases
Suppliers shall have systems in place to prevent and quickly respond to all accidental spills and releases into the environment.
Restricted Substances
Suppliers are to adhere to all applicable restricted substance laws, regulations and customer requirements including responding to requests for substance composition in materials/parts, prohibition, or restriction of specific substances, including labeling for recycling and disposal.
Conflict Minerals
Supplier shall ensure that all parts and products supplied to Sharp do not contain “Conflict Minerals”, i.e., columbite-tantalite, cassiterite, wolframite (or their derivatives tantalum, tin, and tungsten) or gold sourced from the Democratic Republic of the Congo (DRC) or an adjoining country that have directly or indirectly financed or benefitted armed groups in the DRC or an adjoining country. Suppliers shall have systems in place that are designed to meet these objectives.
Procurement
Suppliers should have a sustainable procurement policy in place to ensure their own suppliers conduct business to minimize environmental impact and avoid having adverse health impacts on communities.
Management Systems
Suppliers shall have a quality management system in place to facilitate continual improvement and ensure compliance with the principles outlined in the Sharp Supplier Code of Conduct. Suppliers are encouraged to maintain conformance to international standard ISO 9001 and local regulations.
Commitment and Accountability
Suppliers shall allocate adequate financial, human, and technical resources.
Legal and Customer Requirements
Suppliers shall identify all applicable laws, regulations, rules, ordinances, permits, licenses, approvals, orders, standards, and relevant customer requirements and ensure compliance with them.
Risk Management
Suppliers shall have mechanisms in place to determine and control risks in all areas addressed by this document. Suppliers shall have adequate financial resources to assure business continuity and maintain financial solvency. Suppliers shall have appropriate Business Continuity Plans in place to address possible disruptions in their operations of their supply chains. Suppliers shall cooperate fully with Sharp’s questionnaires, audits and assessments designed to minimize our Supply Chain Risk.
Documentation
Suppliers shall maintain documentation necessary to demonstrate conformance with these principles and compliance with applicable laws, regulations, rules, ordinances, permits, licenses, approvals, orders, standards, and relevant customer requirements.
Training and Competency
Suppliers shall have an effective training program that achieves an appropriate level of knowledge, skills, abilities, and encourages a culture of learning in management and workers to perform the service that Sharp has requested and is covered by a contract. Documented training must be available for all employees as evidence that training was performed.
Continual Improvement
Suppliers are expected to continually improve by setting performance objectives, executing Implementation plans and taking necessary actions to correct deficiencies identified by internal or external assessments, inspections, and management reviews.
Communication
Suppliers shall maintain open and direct communication with appropriate Sharp business functions, including Strategic Sourcing and External Supply. Suppliers shall notify Sharp prior to making any change that may affect conformance to defined requirements, product quality, or a regulatory filing outlined within a supply agreement and/or quality agreement.
Data Requirements
Suppliers shall meet all data requirements prior to conducting business with Sharp.
Supplier Set-Up
Suppliers shall provide all key data (i.e., tax documents, banking information, etc.) to ensure proper set up in Sharp’s systems.
Collaboration and Innovation
At Sharp we embrace collaboration and innovation across our activities and our supply chain. To develop an environment that encourages innovation and collaboration, Sharp expects suppliers to:
- Embrace Innovation
- Strive to think creatively and positively seek new ways to improve processes, products, and services.
- Encourage a culture where new ideas are welcomed and given proper consideration.
- Embrace change and be open to new approaches to problem-solving.
- Foster Collaboration
- Respect and value the input of colleagues, recognizing that diverse perspectives and views can lead to stronger outcomes.
- Communicate openly and transparently, sharing information and insights to promote teamwork.
- Collaborate across departments and functions to leverage expertise and drive innovative thinking.
Transactions
Suppliers shall not perform any services without a fully executed contract and/or Purchase Order in place. Suppliers shall provide all accurate information on submitted invoices, as instructed by Sharp.
Sharp Supplier Code of Conduct
I certify that our company has received, read, understood and will abide by the Sharp Supplier
Code of Conduct.
Company Name
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Representative
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Job Title
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Signature
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Date
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