Kinetic & Decorative Systems Automotive Supplier—Summit ...



HRC 07.14 – Supplier Relationship Guidelines – Gifts, Favors and Social Amenities 1.0Purpose1.1 To establish a clear standard of acceptable and unacceptable practices for gifts, favors and social amenities exchanged between Summit employees and suppliers. 1.2 To ensure that business and sourcing decisions are made based on appropriate business criteria such as:quality deliveryserviceprice2.0Scope2.1This policy applies to all employees of Summit Polymers, Inc. and its affiliates.3.0Responsibility3.1All employees of Summit Polymers, Inc. and its affiliates are responsible for reading and understanding these guidelines. Any questions related to this policy should be directed to your local Human Resources Manager. 3.2Summit Polymers employees are responsible for returning any gifts, favors or social amenities offer in excess of $50 with a note explaining Summit’s policy.3.2Human Resources Manager is responsible for providing guidance to employees on these guidelines. 3.3Vice Presidents and Regional Directors of Manufacturing are responsible for approving any entertainment requests including an overnight stay. 3.4All employees are responsible for reporting any suspected violations of this policy. If you suspect violations of this or any other Summit Policy, you should report it to SpeakUp@4.0Definitions4.1Unethical conduct: Conduct which suggests the intent or appearance of disregard of ethical standards of fair competition, integrity, or diligent promotion of the Company’s interest in dealing with vendors and/or customers.4.2Favoritism: Basing purchasing decisions on non-business related criteria, such as personal gain, conflict of interest, or availability of gifts, entertainment, money, loans, or other services.4.3Confidential Information: Information, which is not presented to all bidders in a bidding situation. Each competitor should have equal access to quote assumptions, terms, and targets of the Customer.5.0 Procedure 5.1If there is any conflict between this procedure and local regulations, local law will prevail. 5.2Summit Polymers does business with a wide variety of suppliers. We want to encourage appropriate relations with suppliers. Our practices ensure that business and sourcing decisions are made based on appropriate business criteria such as quality, delivery, value, price, etc.5.3Each employee of Summit Polymers is expected to avoid favoritism or unethical practices with suppliers, and to avoid conduct, which could be misinterpreted to suggest questionable behavior.5.4An employee of Summit should not be drawn into a compromising relationship. When dealing with a questionable situation, the first “small” step taken that undermines integrity is likely to be followed by another - and then another. 5.5The solicitation of any gift or favor, or any form of preferential treatment, either directly or indirectly by or on behalf of a Company employee or any relative or friend from any supplier doing or seeking to do business with the Company is absolutely prohibited.5.6 The acceptance of a gift or favor (other than one of nominal value, and involving normal sales promotion, advertising or publicity) by a Company employee from any supplier doing or seeking to do business with the Company is also prohibited. This is not intended to eliminate the acceptance of such items as a calendar, note pad, pencil or tie clip bearing the identification of the sender. Generally, items with the following values would be considered acceptable. 5.6.2 $50 USD in the United States5.6.3800 MXN in Mexico5.6.4300 CNY in China5.6.5In all other countries, limits should be set based on $50 USD at current exchange rates. 5.7 Gifts above the limits defined above should be returned to the supplier with a note explaining Summit’s policy.5.8Money, gift certificates, and liquor are not acceptable.5.6.3Business related entertainment or recreational activity should be limited to athletic, theatrical, or cultural events (generally in the local area) and the employee must be accompanied by a supplier employee. 5.5.3.1 Frequency should not be more than twice per year with the same supplier.5.5.3.2 Events requiring significant travel or overnight stays are not acceptable unless approved by a VP or RDM5.5.3.3 Attendance at adult entertainment clubs or other non-appropriate locations, either on Summit business with a supplier or paid by the supplier is not permitted.5.6.4Meal invitations with supplier employees may be accepted as long as they are before or after a business meeting or otherwise business related.5.5.4.1 Frequency should not be more than once per quarter with the same supplier.5.8 Business connected social contacts can be in the best interest of Summit when properly conducted on a limited basis. Employees should make every effort to ensure that there is not the slightest reason for a third party to view this relationship as improper.6.0ReferencesNone. AmendmentsRev A: Added 5.5.5Rev B: ................
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