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Supplier Code of Conduct

Introduction

HERE expects all its Suppliers to meet or exceed all applicable laws and regulations that are in force in the countries where HERE and Suppliers operates. We encourage suppliers to go beyond legal compliance by committing to meet relevant international standards (such as those from the International Labor Organization or applicable United Nations conventions) and to commit to continuous improvement.

The standards set forth in this Supplier Code of Conduct are intended to guide you as you fulfill your role as a HERE supplier. They are not intended to change or replace any specific contractual requirements. Rather, this Supplier Code of Conduct establishes the basic principles for business conduct which HERE expects from HERE suppliers. If Suppliers have agreed to stricter or more detailed requirements than this Supplier Code of Conduct, then we expect them to meet those contractual requirements.

This Supplier Code of Conduct has been created based on the principles set forth in internationally recognized standards such as the United Nations Declaration of Human Rights and the International Labor Organization (ILO) Conventions.

This Supplier Code of Conduct includes requirement in the following areas:

  • Ethics
  • Labor and Human Rights
  • Health and Safety
  • Environment
  • Management Systems
Topics

Ethics

HERE Suppliers shall conduct their business in accordance with the highest ethical standards.

Act ethically

HERE Suppliers shall conduct their business in accordance with the highest ethical standards and require the same compliance throughout their entire supply chain.

HERE Suppliers shall demonstrate a zero-tolerance policy prohibiting any and all forms of corruption and bribery. All business dealings shall be transparently performed and accurately reflected within their records. HERE Suppliers shall choose their business partners carefully and only after conducting a thorough background check and due diligence.

HERE Suppliers’ monitoring and enforcement procedures must be sufficient to ensure compliance with all applicable anti-bribery and anti-corruption legislation including the provisions of the German Criminal Code, the U.S. Foreign Corrupt Practices Act (FCPA) and the Bribery Act 2010 in the United Kingdom of Great Britain.

In addition, HERE Suppliers shall have a defined and enforceable policy for conducting business in an ethical manner. Formal policy on business conduct and compliance helps drive business ethically, honestly, and in full compliance with all laws and regulations.

Do not give or receive bribes

HERE Suppliers shall not offer, give, receive, or solicit any bribes or other means to obtain any improper benefit or advantage. HERE Suppliers shall not allow others to make improper payments for their benefit.

Disclose information truthfully

HERE expects that HERE Suppliers shall disclose information truthfully and accurately as they pertain to their business activities, structure, financial situation, and performance in accordance with applicable laws, regulations, and prevailing industry practices.

Respect Intellectual Property Rights

HERE Suppliers shall always respect Intellectual Property Rights. Any transfer of technology and know-how shall be carried out in a manner that protects Intellectual Property Rights.

Comply with fair business, advertising and competition laws

HERE Suppliers shall understand and comply with all applicable fair business, advertising and competition laws including fair trading and antitrust laws.

Ensure that there are safe ways to report abuses

HERE Suppliers shall create an environment where employees are comfortable raising concerns. HERE Suppliers shall have adequate “whistle-blower” or reporting channels available and feedback processes in place designed to ensure confidentiality and protection for employees and suppliers.

Avoid conflicts of interest

HERE Suppliers shall avoid conflicts between them and HERE by ensuring that they disclose any personal or outside business arrangements between their employees and themselves and any HERE employees or their families.

Source your materials responsibly

If HERE Suppliers manufacture components, parts, or products containing tin, tantalum, tungsten, or gold, HERE Suppliers must source those materials from environmentally and socially responsible sources only. Materials, which either directly or indirectly contribute to a conflict, are unacceptable. Suppliers in this category must exercise due diligence regarding the source and chain of custody of these minerals and make any due diligence measures available to HERE upon request.

Respect privacy

HERE expects that HERE Suppliers comply with privacy and information security laws and regulatory requirements, where applicable, when processing, collecting, storing, transmitting, or sharing personal data related to customers, suppliers, consumers, and employees. HERE Suppliers shall commit to protecting the reasonable privacy expectations of personal information of everyone you do business with.

Labor and Human Rights

HERE Suppliers shall ensure that human resources are managed in accordance with internationally recognized principles of corporate responsibility.

Ensure that employment is freely chosen

HERE Suppliers must not use forced, bonded, compulsory, or imprisoned labor.

HERE Suppliers shall not force anyone into performing work and shall not be involved in any manner with human trafficking.

Do not use child labor

A “child” is any person who is younger than (i) 15 years old (or 14 where the law of the country permits); (ii) the minimum age for completing compulsory education in the country of employment; or (iii) the minimum age for employment in that country, whichever is the highest. Additionally, we expect HERE Suppliers to refrain from hiring anyone under the age of 18 to carry out work which is likely to jeopardize their health, safety, or morals.

Provide adequate compensation and benefits

HERE Suppliers shall ensure that their employees receive at least the minimum compensation, benefits and overtime payments required by law.

Provide employees adequate time off

HERE Suppliers shall take all appropriate steps to ensure workweeks do not exceed the maximum working hours as defined by local laws or applicable collective agreements except in emergency or extraordinary situations with the consent of the employees.

Treat employees with respect and dignity

HERE Suppliers shall treat all employees with respect and dignity, and ensure that they are protected from physical, sexual, verbal, or other forms of abuse, coercion, or harassment.

Do not discriminate in employment or hiring practices

HERE Suppliers shall not discriminate in their employment or hiring practices. This includes discrimination based on race, color, age, gender, gender identity or expression, sexual orientation, ethnicity, disability, pregnancy, religion, political affiliation, union membership, marital status, or any status or characteristic which does not relate to any individual’s qualifications or the inherent requirements for a position.

Allow freedom of association

HERE Suppliers shall recognize their employees’ rights to join or refuse to join labor unions or associations and to bargain collectively as permitted by law.

Health and Safety

HERE Suppliers shall provide their employees with a safe and healthy working environment in compliance with all applicable laws and regulations.

We expect HERE Suppliers to have effective safety programs covering such areas as: human safety, emergency preparedness, chemical, physical, and biological agent exposure, ergonomics, which includes incident reporting and investigation.

Follow a Health & Safety policy & management system

HERE suppliers shall define a Health & Safety policy and implement a Health & Safety management system (EHS) with the aim of getting it certified against the appropriate health & safety management system standard such as ISO 45001 by an accredited third-party agency.

Environment

HERE Suppliers shall minimize the negative impacts their business operations have on the community, environment, and natural resources throughout their supply chain.

Comply with applicable laws and HERE requirements

HERE Suppliers shall adhere to all applicable laws, regulations and any additional environmental requirements agreed upon with HERE.

Obtain necessary permits and observe reporting requirements

HERE Suppliers must obtain, maintain, and keep current all applicable environmental permits, approvals, and registrations. Suppliers shall abide by and follow relevant operational and reporting requirements.

Do not pollute the environment or waste resources

HERE Suppliers shall ensure that they identify the environmental impacts of their operations, products and/or services. In addition, and where possible, HERE Suppliers shall investigate ways to improve energy efficiency and reduce greenhouse gas emissions and water consumption, as well as ways to minimize waste generation and promote reuse and recycling.

HERE Suppliers shall endeavor to minimize air pollution. HERE Suppliers shall characterize, monitor, control and treat as required prior to discharge air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting chemicals and combustion by-products generated from operations.

Control any hazardous substances

HERE Suppliers shall ensure that chemical and other materials - that pose a hazard if released to the environment - are identified and managed to ensure their safe handling, movement, storage, use, recycling or reuse and disposal.

Implement proper waste management processes

HERE Suppliers shall treat wastewater and solid waste generated from operations and sanitation facilities according to legal requirements and good environmental practices.

Follow an environmental management system

HERE Suppliers shall define an Environmental policy and implement an Environmental management system (EMS) with the aim of getting it certified against the appropriate Environmental management system standard such as ISO 14001 by an accredited third-party agency.

Integrate environmental and social factors within HERE Suppliers’ procurement

When HERE Suppliers purchase any component or material or avail the services of a third-party, they shall ensure that their suppliers are taking care of social and environmental factors and integrating these factors within their procurement operations.

Management Systems

HERE Suppliers have adequate management systems in place, which are designed to ensure compliance with this Code of Conduct.

Recognize and Protect HERE Confidential Information

From time to time HERE Suppliers may have access to HERE Confidential Information and/or personal data that belongs to HERE employees, customers, consumers, developers, and others. HERE Suppliers shall recognize that information and take appropriate actions to protect it from misuse and unauthorized disclosure.

HERE Suppliers should report any event of potential unauthorized disclosure promptly to HERE. If you have questions, contact your HERE representative for help.

Commit to corporate, social and environmental responsibility

We encourage HERE Suppliers to make corporate, social, and environmental responsibility statements, endorsed by executive management. These shall affirm your commitment to the values and topics addressed in this Code of Conduct and to their continuous improvement.

Know who is responsible

HERE Suppliers shall identify who is responsible for ensuring implementation of their management systems and associated programs in their company.

Understand your obligations

HERE Suppliers shall ensure that they have adequate process in place for identifying, monitoring, and understanding applicable laws, regulations, and HERE’s requirements, including the requirements of this Code of Conduct.

Assess and manage your risks

HERE Suppliers shall have adequate processes in place for identifying risks (such as the environmental, health and safety, labor and human rights, ethics and legal compliance) associated with their operations and have appropriate procedural and controls to manage such risks and ensure regulatory compliance.

Communicate your expectations clearly and provide adequate training

HERE Suppliers shall have sufficient processes in place to ensure that clear and accurate information about their policies, expectations, and performance, including the requirements in this Code of Conduct, is communicated to their employees, suppliers, and customers. In addition, HERE Suppliers shall have sufficient training programs in place to ensure proper implementation.

Always strive for improvement

HERE Suppliers shall periodically evaluate their conformity to the standards set forth in this Code of Conduct and maintain open discussions with HERE in order to maintain continuous improvement and correct any deficiencies in a timely fashion.

Maintain proper documentation and records

HERE Suppliers shall ensure that they and their suppliers have adequate process for the creation and maintenance of documents and records designed to ensure regulatory compliance and conformity to document along with appropriate confidentiality to protect privacy.

Violations of this Code of Conduct

Any violation of this Code of Conduct may result in corrective action. The appropriate action in a particular case depends on the nature and severity of the Code violation and the circumstances surrounding the situation.

Failure to comply with this Code and/or any additional requirements set forth by HERE, or any applicable laws and regulations may result in the termination of any agreement as a HERE supplier and referral of the matter to local authorities.