Supplier Code of Conduct

Code of Conduct

PAINI-US believes in in adhering to the spirit of and the laws that govern international business.

 

This code is expected of our suppliers as well as our internal operation

 

This includes but is not limited to areas in business relations such as: fair competition, anti-bribery, trade compliance, labor practices, and environmental responsibility, and in human resources we emphasize the importance of transparency, accuracy in record-keeping, and respect for human rights.

 

1. Compliance with international trade laws and regulations

  • Customs and duties: Adhere strictly to the customs laws, regulations, and duty rates of all countries involved in the import process.
  • Export controls and sanctions: Comply with all applicable export controls, sanctions, and trade restrictions imposed by the relevant governments and international bodies.
  • Import/export licenses and permits: Obtain all necessary import and export licenses and permits as required for specific products or destinations.
  • Tariff classification and valuation: Accurately classify imported goods using the Harmonized System (HS) codes and determine the correct valuation for duty assessment, avoiding errors that can lead to penalties or delays.
  • Rules of origin: Properly determine and document the country of origin for all imported goods, especially when claiming preferential treatment under Free Trade Agreements (FTAs).
  • Supply chain security: Implement measures to ensure the security of the supply chain, such as those described in the World Trade Organization's SAFE framework or C-TPAT guidelines. 

2. Documentation and recordkeeping

  • Accurate and complete documentation: Maintain meticulous records of all import transactions, including commercial invoices, packing lists, bills of lading, certificates of origin, and other necessary documents.
  • Record retention: Retain import-related records for the period required by applicable regulations to facilitate audits and inspections.
  • Data privacy: Protect the privacy and confidentiality of all data shared with partners and customers during international trade transactions. 

3. Ethical and responsible conduct

  • Fair competition: Conduct business ethically and avoid anti-competitive practices such as price-fixing, market allocation, and bid rigging.
  • Anti-bribery and corruption: Prohibit bribery, kickbacks, and any form of corruption, including compliance with relevant anti-bribery laws like the FCPA and UK Bribery Act.
  • Forced labor and human rights: Ensure that products are not sourced from suppliers using forced labor or involved in human rights abuses, as mandated by laws like the U.S. Trade Facilitation & Trade Enforcement Act (TFTEA) of 2015.
  • Environmental responsibility: Promote environmentally responsible practices throughout the supply chain, from sourcing to distribution, in line with guidelines from bodies like the USDA.
  • Conflicts of interest: Avoid situations where personal interests conflict with the interests of the business or its stakeholders.
  • Transparency and accuracy: Ensure honesty and accuracy in all dealings, avoiding any misleading or deceptive practices. 

4. Internal compliance program

  • Dedicated compliance officer: Assign responsibility for trade compliance to a qualified individual or team.
  • Training and education: Provide regular training to employees on international trade compliance regulations and best practices.
  • Internal audits: Conduct periodic internal audits to assess compliance with regulations and identify potential areas of concern.
  • Reporting mechanisms: Establish clear channels for employees to report potential violations of the code of conduct without fear of retaliation.
  • Contingency plans: Develop procedures to respond to potential compliance incidents, including communication strategies, remediation steps, and regulatory disclosure procedures. 

By implementing and adhering to such a comprehensive code of conduct, we can navigate the complexities of international trade, maintain a strong reputation, and contribute to a more ethical and responsible global trading environment. 

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1. Legal Compliance:

 

International Trade:

  • Adherence to all applicable laws and regulations related to import/export, including customs procedures, trade restrictions, and sanctions. 

Anti-Bribery and Corruption:

  • Prohibition of bribery, kickbacks, and any form of corruption to obtain business advantages, including compliance with relevant anti-bribery laws like the FCPA and UK Bribery Act. 

Competition Laws:

  • Compliance with antitrust laws and regulations, including those prohibiting price-fixing, market allocation, and other anti-competitive practices. 

Data Privacy:

  • Protection of personal information and adherence to data privacy laws and regulations. 

2. Ethical Conduct:

  • Transparency and Accuracy:

Maintaining accurate records of all business activities and disclosing information to relevant parties without falsification or misrepresentation. 

  • Fair Dealing:

Conducting business with integrity and honesty, avoiding any actions that could be perceived as misleading or deceptive. 

  • Conflicts of Interest:

Avoiding situations where personal interests conflict with the interests of the business or its stakeholders. 

  • Responsible Sourcing:

Avoiding the use of raw materials that directly or indirectly finance armed groups or human rights abuses. 

3. Labor Practices:

 

Fair Treatment of Workers:

  • Respecting the rights of all workers, including ensuring fair wages, working hours, and safe working conditions. 

Non-Discrimination:

  • Prohibiting discrimination in hiring and employment practices based on race, religion, gender, age, or other protected characteristics. 

Freedom of Association:

  • Respecting the right of workers to freedom of association and collective bargaining. 

Elimination of Forced Labor:

  • Complying with laws prohibiting forced labor, human trafficking, and child labor. 

Respectful Workplace:

  • Maintaining a workplace free from harassment, abuse, and violence. 

4. Environmental Responsibility:

  • Sustainable Practices: Promoting environmentally sustainable practices in operations and supply chains. 
  • Waste Reduction and Management: Minimizing waste generation and implementing proper waste management procedures. 
  • Resource Conservation: Using resources responsibly and minimizing environmental impact. 

5. Compliance Program:

  • Reporting Mechanisms:

Providing channels for reporting violations of the code of conduct, including anonymous reporting mechanisms. 

  • Whistleblower Protection:

Protecting individuals who report violations from retaliation. 

  • Training and Awareness:

Ensuring that all employees and stakeholders are aware of the code of conduct and its requirements. 

  • Regular Audits and Reviews:

Conducting regular audits and reviews to ensure compliance with the code of conduct. 

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