CWM has customers all over the world. We strive to satisfy the needs and requirements of our customers and future customers and their changing needs.
Our Responsibility Standards for Suppliers reflect our internal values and the expectations of our management and customers. At CWM, we find that business relationships are more productive and effective when they are built on trust, mutual respect, and shared values, and we seek relationships with suppliers who share our vision.
At CWM, we have developed the necessary Standards to assist us with selecting suppliers who operate in a manner consistent with our cultural pillars and to support our suppliers in understanding and upholding our expectations.
Corrective Actions
CWM suppliers/partners are encouraged to issue corrective action requests (CAR’s) to CWM “whenever” we do not follow policies/procedures that we’ve established or agreed to with our partners. CWM understands that our suppliers cannot effectively provide the services we require without our direction and adherence to a set of principles/values (E.g., CWM Pillars). Our relationships cannot grow and prosper solely by unilateral actions. We realize that we (CWM) error at times and expect to be notified on those occasions utilizing a formal corrective action request (CAR) when necessary.
Code of Business Ethics
We set up our principles and standards based on ISO 9001 & ISO 14001. All of the principles and requirements included must be followed daily, not only by CWM but also by each of our suppliers. Therefore, our suppliers are required to acknowledge and comply with CWM’s Code of Business Ethics, legal obligations, and Industry standards and establish a sustainable procurement policy (addressing regulations such as the Dodd-Frank Act, RoHS, REACH, Anti-Human Trafficking Policy, Modern Slavery Act, Guiding Principles on Business and Human Rights, etc.) regarding their suppliers’ operational practice and supply chain. As part of building a business relationship, we require our suppliers to embrace and implement the below standards. Reading, understanding, and observing the expectations and requirements of the Supplier Standards will help you achieve your own goals more efficiently. If we are striving for these goals together, we will be on a course for success. The Supplier Standards form part of our contractual framework and applies in the early stages starting with our request for quote (RFQ).
Dodd-Frank Act S1502 (Conflict Minerals). The Supplier recognizes the significant legal and non-legal risks associated with sourcing tin, tantalum, tungsten, and gold. By accepting a PO, the Supplier must certify that it complies with the Dodd-Frank Act Section 1502 (“the Act”) reporting requirements, regardless of the country or countries in which it is doing business. If any tin, tungsten, tantalum, or gold are used in products provided to CWM, this must be disclosed to the CWM buyer. For the minerals identified, we expect the Supplier to perform a reasonable country of origin inquiry and proper due diligence to determine the conflict status of the smelter and/or mine. This information will be provided to CWM. The Supplier certifies and warrants that it will not knowingly deliver any products that contain conflict minerals to CWM as defined in the Act. Suppose the Supplier discovers any conflict minerals in the products delivered to CWM. In that case, the Supplier agrees to use its best efforts to eliminate the use of such conflict minerals for use in the products without adversely affecting its ability to continue to meet the product specifications.
The Supplier agrees that it shall require its own subcontractors and sub-tier suppliers in the Supply Chain for products delivered to CWM to comply with the requirements of this document. Additionally, Suppliers at any tier may be requested to provide evidence that a proactive policy – adhering to Dodd-Frank Act S1502 – is in place.
RoHS. The Restriction of Hazardous Substances Directive 2002/95/EC (RoHS) was adopted in February 2003 by the European Union. All Suppliers shall know and understand the contents of its products, including the products of its sub-tier suppliers. Upon CWM’s request, Suppliers shall provide a complete listing of the products’ physical contents. If necessary, CWM will require documentation from the Supplier certifying its product to be RoHS compliant.
REACH The European Regulation (EC) No. 1907/2006 concerning the Registration, Evaluation, Authorization, and Restriction of Chemicals (REACH) entered into force in June 2007. Suppliers shall comply with all applicable REACH requirements that affect the products they supply to CWM. CWM expects Suppliers to have a dialogue with their own Supply Chain and CWM regarding all applicable REACH aspects.
Upon CWM’s request, Suppliers shall provide a complete listing of the product’s physical contents.
Anti-Human Trafficking Policy
CWM requires suppliers doing business with us to disclose their efforts to eradicate slavery and human trafficking from their direct Supply Chains. All CWM Suppliers must certify that materials incorporated into the product comply with the laws regarding slavery and human trafficking in the country or countries in which they are doing business. In addition, the Suppliers are expected to comply with FAR 52.222-50 as applicable.
Human Rights, Labor, and Employment
CWM explicitly prohibits using forced and child labor and discriminatory treatment based on gender, age, beliefs, nationality, physical features, etc.
CWM is also working to prevent abuse of power and sexual harassment in the workplace.
In addition to compliance with applicable laws and regulations, we expect our suppliers to comply with our Human Trafficking Policy, our Policy on the Employment of Young Persons, and the requirements outlined in our Position on Conflict Minerals.
