This Supplier Code of Conduct (“Code”) outlines the minimum standards Mativ Holdings, Inc., and its affiliated companies (Mativ) require their Suppliers (as defined below) to comply with when doing business with Mativ, in addition to complying with all laws and regulations that are applicable to the Supplier. The Supplier will respond without delay to any request from Mativ aiming at the implementation of existing or new laws or regulations on Mativ premises. Should a conflict arise between the standards listed below and local laws or regulations, Suppliers will be expected to comply with the laws and regulations of the jurisdictions in which they operate. For purposes of this Code, a “Supplier” is any person or legal entity which provides Mativ with products or services. In addition to Suppliers who have a direct contractual relationship with Mativ, this definition also includes the Suppliers’ sub- suppliers.
We expect Suppliers to produce, preserve, and deliver the product and/or service in conformity with agreed upon specifications and to provide any relevant information, results, or performance ratings related to the product and/or service. Mativ will purchase goods and services which are produced and delivered under conditions which do not abuse or exploit any person or the environment. It is each employee’s and Supplier’s responsibility to ensure that our products and services are obtained from sources which respect safety, health, environment, product stewardship, product quality, social, legal, and ethical standards, and sustainability requirements as defined below. The Supplier shall have appropriate management systems in place to enable adherence to this Code or its own equivalent code as well as all other relevant and applicable laws and regulations. The functioning and quality of the management system shall be in proportion to the size, complexity, and risk environment of the Supplier’s business. The Supplier shall adopt a systematic approach to the assessment, mitigation, and management of risks related to human and labor rights, occupational health and safety, responsible business practices, and environmental impact. All applicable laws, regulations, and contractual terms governing the Supplier’s assignments shall be duly applied and communicated, with sufficient training provided to relevant employees and business partners. The Supplier shall have systems in place to enable the reporting of Code-related grievances (e.g., a whistle-blowing system) to the Supplier’s management team. The Supplier shall communicate this Code or its own equivalent code to its own suppliers and sub-suppliers.
Human Rights and Labor Standards
Mativ will trade with Suppliers who observe the UN’s Universal Declaration of Human Rights (UDHR). Where a supplier is found to be in gross violation of the principles of the declaration, we will advocate a change of practice, working with the Supplier to highlight concerns and develop mutually acceptable solutions. The use of slavery, forced or compulsory labor (including prison labor), and human trafficking and exploitation are prohibited. Suppliers are expected to comply with the requirements of International Labour Organization (ILO) Convention No. 138 on the minimum age for admission to employment and work and to not employ any workers below 15 years (14 years in certain developing countries) or the minimum age according to applicable legislation, whichever is higher. Suppliers shall provide a harassment-free work environment and shall ensure that their employees and contractors do not suffer harassment, retaliation, physical or mental punishment, or other forms of abuse.
Mativ values diversity and inclusion. Discrimination in any form will not be practiced, including discrimination based on distinction, exclusion, or preference based on race, color, sex, sexual orientation, gender identity, age, ethnic or national origin, religion, disability, or any other status protected by law. To learn more about our approach to human rights, please see our Human Rights Policy.
Environmental Health and Safety (EHS) and Sustainability
The Supplier is required:
- to fulfill all applicable legal EHS requirements, including the EU Registration, Evaluation, Authorization, and Restriction of Chemicals (REACH) directive, where applicable,
- to have a written EHS policy of its own, to demonstrate management’s commitment to EHS, and to assign responsibility for EHS within its organization,
- to ensure that operational controls such as rules and procedures are in place and communicated to all relevant employees,
- to increase its employees’ awareness of health and safety issues, to enhance safety culture through open
communication, and to ensure that its staff have received appropriate EHS training,
- to measure and monitor its EHS performance and hazards with the help of properly conducted workplace inspections and audits,
- to assign responsibility for environmental and safety issues within its organization,
- to report and investigate all health and safety incidents,
- to have emergency preparedness and response procedures in place,
- to ensure that relevant employees have appropriate know-how and experience in relation to environmental and safety issues, as well as resources to enable them to effectively meet their responsibilities,
- to ensure that written instructions covering all processes with potential environmental impacts, such as the storage and handling of hazardous materials, are available and that the relevant information is communicated to all employees involved,
- to proactively work to prevent emergencies and ensure the capacity to react appropriately to such events by analyzing, identifying, and adopting suitable preventive and corrective measures,
- to handle environmental and safety violations and complaints systematically and communicate them to employees and external stakeholders, including Mativ if affected,
- to provide Mativ with up-to-date material safety data sheets (MSDS or SDS), as applicable, and any other relevant documents and information requested by Mativ,
- to optimize the use of resources and minimize the generation of emissions and waste,
- to provide Mativ with available information regarding their sustainability performance as requested (e.g., product life cycle assessment data, carbon reduction plans relating to Mativ’s Scope 3 emissions, etc.) and reasonable assistance in understanding and utilizing this information as we work to reduce our own environmental impacts.
Wages and Working Hours
At a minimum, wages and working hours will comply with all applicable wage and hour laws, rules, and regulations, including minimum wage, overtime, and maximum hours in the country or locality concerned.
The Supplier is required:
- to pay employees at least the minimum wage and applicable overtime wages defined by applicable laws or any applicable collective agreements,
- to apply normal working hours that comply with applicable laws and collective agreements,
- to avoid scenarios where employees work excessive hours on a routine basis.
Compliance with the EU Timber Regulation and the US Lacey Act
Mativ expects all applicable Suppliers to fully comply with the EU Timber Regulation and the US Lacey Act. Suppliers should not engage in practices that contribute to deforestation and should seek third-party certification (FSC, PEFC, or an alternative credible standard) for supplied timber and timber-derived materials. Mativ supports practices that end deforestation and the illegal harvest of timber.
In August 2012, the U.S. Securities and Exchange Commission (SEC) adopted final rules implementing Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, also known as the “Conflict Minerals Rule.” Under these rules, publicly traded companies must annually report to the SEC whether products they manufacture or contract to manufacture contain specific “conflict minerals” originating from the Democratic Republic of the Congo or adjoining countries (DRC). The conflict minerals are columbite-tantalite (tantalum), cassiterite (tin), gold, and wolframite (tungsten). If public companies determine they are subject to the Rule, they must conduct a “country of origin” inquiry reasonably designed to determine whether any conflict material used originated from the DRC or adjoining countries (collectively, the DRC region).
- is committed to compliance with the requirements of the Conflict Minerals Rule and to any further action that ensures the protection of human rights.
- expects its suppliers to:
- source materials from socially and ethically responsible suppliers,
- identify any conflict minerals in products supplied to Mativ and the origin of such minerals, and
- provide information to Mativ to aid Mativ’s ability to comply with the Conflict Minerals Rule.
The Supplier is required to conduct its business in full compliance with this Code or the Supplier’s own equivalent ethical rules. This means, among other things, that the Supplier is required:
- to conduct business in full compliance with all applicable antitrust and fair competition laws,
- to prevent situations where there is a conflict of interest between the Supplier and Mativ,
- to act in compliance with all applicable anti-corruption laws, including the Foreign Corrupt Practices Act and the UK Modern Bribery Act, by, among other things, refusing to receive or offer bribes, facilitation payments, or anything of value for the purpose of obtaining or retaining business or any improper benefit or advantage,
- to act in compliance with all rules and regulations related to the safety and quality requirements of products and services, including rules defined by Mativ for work conducted at Mativ locations,
- to transparently and accurately record and disclose details of its business activities, corporate structure, financial situation, and performance in accordance with applicable laws and regulations,
- to maintain the integrity of confidential data.
Mativ Representatives shall always pay for their own travel and accommodation costs when visiting the Supplier, attending conferences, or conducting other business. The Supplier shall not offer any Mativ Representatives any gifts, hospitality, or expenses that could be considered unreasonable or inappropriate with regard to possible business transactions, although reasonable meals incidental to business discussions are permitted. For purposes of this Code, “Mativ Representatives” include the company’s employees and legal representatives.
Suppliers shall promptly disclose to Mativ at [email protected] any situation that is or may be perceived to be a conflict of interest which involves Mativ employees or any suspected violation of this Code.
If Mativ finds that the Supplier is not meeting the requirements and expectations set out in this Code, Mativ will offer guidance specifying which issues need to be corrected or improved. The Supplier must then take corrective actions promptly as advised by Mativ. Mativ nevertheless reserves the right to cancel outstanding orders, suspend future orders, or terminate the contract with the Supplier in case of a material breach of this Code. When a conflict exists between this Code and an executed supply agreement, the conditions and terms of the supply agreement will supersede this Code.
Mativ reserves the right to update this Code as we deem necessary. For questions, please contact [email protected].