1. To Our
The Globe Group is committed to conducting its
business activities ethically and in accordance with the law, utilizing good
governance and procurement practices. We procure from you, our suppliers, a
wide variety of goods and services that enable us to provide products to our
customers. Consequently, to assure that we fulfill our corporate
responsibility, we believe it is essential for you to understand our management
philosophy and to support our procurement activities accordingly. This
Procurement Guidelines was created to help you better understand our
procurement activities and to enlist your cooperation in helping us fulfill our
2. Basic Procurement Policies
The Globe Group will build fair
partnerships with suppliers, based on mutual trust.
Exercising high ethical standards, we
will conduct our procurement activities in strict compliance with both the
letter and spirit of laws and regulations, both national and international, in
every region where we operate.
Suppliers must strive to reduce the environmental
impacts of their activities and must operate with best in class health, safety
and environmental practices.
We will always seek stability, quality,
and competitive price, and uninterrupted delivery from suppliers.
Partnership: to forge good partnerships,
we believe that our suppliers must meet the requirements below.
A stable management foundation
Conducts its business activities in
strict compliance with laws and regulations.
Has strong technical competencies that
enable it contribute to Globe products
Ability to continuously supply materials
that meet or exceed quality requirements
Ability to supply the most
Ability to supply goods at the right
time and in the right quantity
We are committed to conducting all our
activities in accordance with the highest ethical standards. We expect you to
likewise maintain the highest code of ethics.
The Globe Group does not make reciprocal
deals, as all its dealings with suppliers are based on fair and impartial
We ask you to fully understand the
content and intent of the Globe Code of Conduct (found at www.glbsm.com) and to conduct your business
activities accordingly. We would like you to ask and assure that your own
business partners (sub-suppliers, from Globe's perspective) comply with a
similar supplier code of conduct.
We in the Globe Group will meet the
expectations of our customers while conducting operations that comply with local,
national, and international laws, and regulations. It is imperative that you,
our suppliers, also understand that you must carry out all aspects of your
business activities in compliance with the laws and regulations of the country
or region in which you operate. You need a system to identify and remain
compliant with all applicable laws, regulations and codes, including any
Health, Safety and the Environment
Health and safety are the most fundamental of
all concerns. We place the highest importance on promoting the creation of a
safe work environment and on maintaining and enhancing the health of our
employees. We do this by, for example, identifying and assessing potential
hazards and risks within our operations in order to prevent accidents and
occupational injuries. When, despite our efforts, an accident does occur, we
thoroughly analyze the root cause and take steps to prevent similar accidents
and occupational injuries. We would like you to take similar actions to
provide, maintain and improve the safety, sanitation and health of your work
environment so that your employees can feel safe.
We ask you to remember that adequate
environmental care is essential for any manufacturer of products for global
markets, and we expect you to minimize the adverse effects of your
manufacturing processes on society, the environment and natural resources.
Therefore, we require suppliers of
production materials in particular to: maintain and manage environmentally
considerate production processes; comply with applicable environmental, health
and safety legislation, control substances in products so as to prevent the
inclusion of controlled materials as stipulated separately, prepare supporting
data (to enable Globe to comply with customer requirements); maintain
compliance with legislation on industrial waste management and pollution
We reserve the right to verify and
evaluate our suppliers' state of compliance against the requirements imposed by
these guidelines. If an on-site audit is needed, we will contact you in advance
to discuss the schedule.
The cost of the raw materials or parts
that you provide significantly impacts the cost competitiveness of Globe
products. We therefore expect your prices to be highly competitive against the
rest of the market, and we expect you to actively drive ongoing cost-reduction
and streamlining activities.
The volume and delivery requirements of our customers varies, and we need to be able
to produce product in a timely manner and with a minimal amount of waste so
that we can immediately respond to their requirements. Therefore, we expect you
to strictly manage delivery schedules by maintaining close communication with
us. You are also expected to be able to flexibly accommodate changes in demand
for raw materials and parts. Promised delivery dates are to be met, and
continuous efforts are to be made to shorten lead-times.
The quality of the raw materials, parts
and other goods that we purchase from you affects the performance of our
products. A satisfactory level of quality for raw materials and parts is
contingent on your having an effective quality assurance system.
Demonstration of ample supply of quality
In the case of mined products, present reserve
studies, engineering and safety reports to demonstrate ample proven reserves in
accordance with internal and/or SEC guidelines of in-spec resources on a
continuous, uninterrupted basis with sufficient alternatives (at the same
quality and cost) in case the relevant resource/operation is unavailable for
any reason. In addition, provide MSHA
violation history to demonstrate that there are no operating issues.
Submit for review historical and projected financial statements and business plans upon request to demonstrate (i) financial viability and (ii) past and future fiscal responsibility.
We reserve the right to verify and evaluate our suppliers' financial state. If an on-site audit is needed, we will contact you in advance to discuss the schedule.
Failure to pass such reviews/audits may result in cancellation of the contract.
Suppliers shall not engage in
discrimination based on race, color, age, gender, sexual orientation,
ethnicity, disability, pregnancy, religion, political affiliation, union
membership or marital status in hiring and employment practices such as
promotions, rewards, and access to training. Employees shall be able to
communicate openly with management regarding the working environment without
fear of discrimination, reprisal, intimidation or harassment.
Suppliers must recognize that the
quality of products and services are enhanced by a safe and healthy work
environment. The health and safety standards are: 1) Occupational Safety
Employee exposure to potential safety hazards (e.g., electrical and other
energy sources, fire, vehicle, and fall hazards) are to be controlled through
proper design, engineering and administrative controls, preventative
maintenance and safe work procedures (including lockout/tag out). Where hazards
cannot be adequately controlled by these means, employees are to be provided
with appropriate personal protective equipment and educational materials
suitable for the hazards. Employees shall be encouraged to raise safety
concerns, including self-reporting environmental and/or safety and health
concerns to the appropriate authority.
Suppliers are to have a system in place
for identifying, assessing, and analyzing emergency and potential emergency
situations. Impacts are to be minimized by implementing emergency plans and
response procedures, including: emergency reporting, employee notification and
evacuation procedures, evacuation drills, appropriate fire detection and
suppression equipment, adequate exit facilities and recovery plans.
Occupational Injury and Illness
Procedures and systems are to be in place to manage, track and report
occupational injury and illness, including provisions to: a) encourage employee
reporting; b) classify and record injury and illness cases; c) provide
necessary medical treatment; d) investigate cases and implement corrective
actions to eliminate their causes; and e) facilitate return of employees to
Employee exposure to chemical,
biological and physical agents is to be identified, evaluated, and controlled.
When hazards cannot be adequately controlled by engineering and administrative
means, employees are to be provided with appropriate personal protective
Work where employees are engaged in
physically demanding tasks, including manual material handling and heavy
lifting, prolonged standing and highly repetitive or forceful assembly tasks is
to be identified, evaluated and controlled.
Physical guards, interlocks and barriers
are to be provided and properly maintained for machinery used by employees.
Employees are to be provided with clean
toilet facilities, access to potable water and sanitary food preparation and
storage facilities. Employee dormitories provided by the Supplier or a labor
agent are to be clean, safe, and provide emergency egress, adequate heat and
ventilation and reasonable personal space.
Suppliers shall provide employees with
appropriate workplace health and safety training in a language they can
understand. Health and safety related information shall be posted in the
Suppliers shall submit the legally
required applications, notices and reports needed to obtain environmental
permits and shall remain compliant with environmental laws and regulations by
keeping permits and operations current.
Emissions of all types, including
wastewater, wastes, and emissions from energy use, are to be reduced or eliminated
by practices such as modifying processes or by substituting, recycling and
Suppliers shall identify and manage
chemical and other materials posing a hazard if released to the environment to
ensure their safe handling, movement, storage, recycling or reuse and disposal.
Industrial wastewater is to be properly
treated and controlled to ensure that it meets discharge standards prior to
being discharged. Wastes emitted from factories shall be properly sorted,
stored and controlled prior to disposal by the supplier or the supplier's waste
management provider. Suppliers shall routinely monitor industrial wastewater
and wastes emitted from factories.
Industrial facility air emissions of
volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting
substances such as CFCs, and SOx, NOx, and ash dust
emitted by exhaust flues are to be characterized, controlled and routinely
Suppliers are to adhere to all
applicable laws and regulations regarding prohibition or restriction of
specific substances including labeling laws and regulations for recycling and
disposal. Suppliers are also to establish and adhere to processes to comply
with each agreed-upon customer-specific restricted and hazardous materials
Suppliers should prevent contamination
of storm water runoff.
Suppliers shall properly control and
record energy consumption and greenhouse gas emissions. In addition, they shall
reduce energy consumption and greenhouse gas emissions using reasonable methods.
Suppliers shall adopt or establish a
management system whose scope ensures compliance with these Guidelines.
Clearly identified company
representative[s] responsible for ensuring implementation and periodic review
of the status of the management systems.
Identification, monitoring and proper
understanding of applicable laws, regulations and customer requirements.
Process to identify the legal
compliance, environmental, health and safety and labor practice risks
associated with Supplier's operations.
Evaluation of the relative significance
for each risk and implementation of appropriate procedural and physical
controls to ensure regulatory compliance to control the identified risks.
Written standards, performance
objectives, targets and implementation plans including a periodic assessment of
Supplier's performance against those objectives.
Training programs for training managers
and employees to implement Supplier's policies, procedures and improvement
Communication process for communicating
clear and accurate information about Supplier's performance, practices and
expectations to employees suppliers and customers.
Ongoing processes to assess employees'
understanding of and obtain feedback on practices and conditions covered by
these Guidelines and to foster continuous improvement.
Periodic self-evaluations to ensure
conformity to legal and regulatory requirements, and the content of these
Process for prompt correction of
nonconformance identified by internal or external assessments, inspections,
investigations and reviews.
Creation and retention of documents and
records to ensure regulatory compliance and conformity to company requirements
along with appropriate management of confidential information to protect
Process for communicating Guideline
requirements to suppliers and for monitoring supplier compliance to the
The highest standards of integrity are
to be expected in all business interactions.
All forms of bribery, corruption,
extortion, and embezzlement shall strictly be forbidden (including the promise,
solicitation, furnishing, and acceptance of any and all forms of bribery).
Suppliers are to conduct all transactions with transparency and refuse any
involvement with organized crime or other anti-social groups. Moreover,
supervision is to be provided and actions taken to ensure compliance with
Local and international anti-corruption
regulations are to be observed, and under no circumstances are bribes, gifts,
entertainment, hospitality, or other means intended to confer or receive
excessive or unfair advantage to be offered or accepted either directly or
Information regarding labor, health and
safety, environment, business activities, structure, financial situation and
performance is to be disclosed in accordance with applicable regulations and
prevailing industry practices.
Intellectual property rights are to be
respected. Suppliers must protect customer information.
Standards of fair business, advertising and
competition are to be upheld.
A communication process shall be
prepared so employees are able to raise any concerns without fear of
A policy is to be established for
reasonably ensuring that the tantalum, tin, tungsten and gold in products does
not directly or indirectly finance or benefit armed groups that are
perpetrators of serious human rights abuses in the Democratic Republic of the
Congo or an adjoining country. Perform due diligence on the source and chain of
custody of these minerals and make these due diligence measures available to
customers upon customer request.
Commit to protecting personal
information of everyone involved in the business, including suppliers,
customers, consumers and employees. Comply with privacy and information
security laws and regulatory requirements when personal information is
collected, stored, processed, transmitted and shared.
A well-defined management system is to
be provided for the export of legally regulated technology and goods, and the
proper export procedures are to be followed. "Legally regulated technology
and goods" includes things such as parts, finished products, technology,
equipment, and software whose export is regulated by law or regulations on the
basis of international agreements. In some cases an export license or other
form of approval from a regulatory authority must be acquired prior to export.
Security in the supply chain is to be
When the Globe Group requests that
information provided under a non-disclosure agreement be kept secret, the
supplier shall comply with the agreement concerning the agreed upon information
(including goods) and any information that was created using the agreed upon
information. IT systems are to be equipped with technological defenses against
computer network threats (e.g. unauthorized access and viruses) and
monitored/administered so that damage does not spread within your company or to
other companies such as ours.
A written application is to be submitted
to the procurement organization of the Globe Group if permission to use any
trademark or company name belonging to the Globe Group is desired.
Any assets owned by the Globe Group that
are consigned for use in production shall be managed in compliance with
applicable agreements and laws. Consigned assets are to be properly managed so
that they are kept in good working order. Suppliers are to promptly accommodate
consigned-asset related requests from the Globe Group, including but not
limited to requests for receipts, stocktaking requests, and requests for
permission to conduct on-site inspections of usage conditions. (Note: Suppliers
ordinarily are to procure any equipment needed for production of delivered
goods, but the Globe Group may consign such equipment when deemed necessary.
However, any such consignments shall require the execution of a basic trade
agreement or an individual consignment/lease agreement that specifies the
consignee's obligation of care.)
An action plan is to be established that
describes comprehensive measures for continuing business in the event of an
accident, disaster or other serious disruption or for resuming business within
a stated target timeframe, and a business continuity management system is to be
built to execute and maintain such plan.