Code of ConductCode of Conduct

CPFL Code of Conduct

CPFL, based in the UK, has a built a customer base of some of the most prestigious customers in the world. Being associated with such esteemed corporations meaning we have a huge responsibility towards those customers, employees, investors, the public, and the environment. This corporate responsibility includes compliance with the laws in force everywhere and at all times as well as respecting ethical values and acting sustainably.

Scope of Application
In line with the corporate responsibility strategy pursued by us, the Company expects its Customers and suppliers (i.e. all contracting parties that supply us with goods, materials, or services) and business partners and their employees to act responsibly and undertake to observe the basic principles outlined in this our Code of Conduct. If the suppliers or business partners commission third parties (e.g. subcontractors or representatives) in their business dealings with us, we expect these third parties to also observe the principles laid down in this our Partner Code of Conduct.

Partner Code of Conduct
We reserve the right to send experts to inspect the business premises of its suppliers and
business partners for compliance with the requirements listed below on a case- by-case
basis. Advance warning will be given of such inspection which will take place during
normal business hours in the presence of a representative from the supplier or business
partner and in compliance with the applicable law, particularly with data protection laws.

Corporate Responsibility
Corporate responsibility involves a duty to comply with all rules and regulations in force.
We expect our suppliers and business partners to especially observe the basic principles
that follow.

Human rights
We respect and protect the regulations in force worldwide to protect human rights as a fundamental and general requirement. This also involves us refraining from employing forced or child labour we comply with the rules laid down in ILO Conventions 138 and 182 concerning the minimum age of employment for children.

Product safety
We respect and comply with all applicable legal product safety regulations and requirements, particularly legal requirements pertaining to the safety, labelling and packaging of products as well as the use of dangerous substances and materials.


Equal opportunity and non-discrimination
We do not discriminate on grounds of ethnic, national, or social origin, skin colour, sex, religion, views, age, disability, sexual orientation, political views insofar as they are based on democratic principles and tolerance toward those of a different opinion, or any other legally protected characteristics unless the law requires otherwise.

Safety in the workplace and working hours
We comply with the relevant legal regulations for health and safety in the workplace. We support the further development and improvement of working conditions. Working hours correspond at least to the respective national legal standards or the minimum standards of the respective national economic sectors.

Minimum wage
We ensure that our employees are commensurately remunerated corresponding at the very least to the legally valid and guaranteed minimum. Where legal or collective bargaining agreements do not exist, compensation and benefits are based on industry-specific collective agreements customary to the respective location that ensure an appropriate standard of living for the employees and their families.
Compliance with legal provisions
We take responsibility when it comes to environmental
protection concerns and comply with all applicable legislation relating to the environment
and sustainability.

Increase energy and resource efficiency
We use natural resources sparingly and minimize
environmental pollution in their production processes and products. They contribute to
reducing energy consumption and CO2 emissions.

Environmental and climate protection
We want to make a significant contribution to environmental and climate protection.
We are expected to especially observe the basic principles that follow.

Implementation and application of environmental management systems
We continuously improve our environmental performance. with production sites implement
Or are working towards a suitable environmental management system (e.g. in accordance
with ISO 14001 or the EMAS Directive of the European Union).

Transparent business relationships
Openness and transparency are key to credibility and trust in business practice.
We especially observe the basic principles that follow.



Avoiding conflicts of interest
We take decisions based solely on objective criteria and do not allow themselves to be
guided by personal interests or relationships.

Prohibition of corruption
We do not tolerate corruption we ensure that our employees, subcon- tractors or representatives do not grant, offer or accept any bribes, kickbacks, inadmissible donations, or other inadmissible payments or benefits to or by customers, officials or other third parties. This also applies to so-called “facilitation payments” (e.g. illegal payments to accelerate administration matters that are routinely encountered).

Gifts, hospitality, and invitations
We do not offer our employees or third parties any inappropriate benefits either directly or indirectly in the form of gifts, hospitality, or invitations to unduly influence them. Neither do they ask for, nor accept such benefits.

States as customers and dealing with authorities
We consistently comply with the strict legal provisions when dealing with governments, authorities, and public institutions. When taking part in a public solicitation for bids, they comply with legal regulations and abide by the rules of free and fair competition.

Consultants and agents
We only employ consultants or agents in line with the laws in force. We take particular care to ensure that consultants or agents are only remunerated for consulting and agency services actually rendered and that the payments are commensurate with the performance rendered.







Fair market conduct
We are fair and responsible market participant and adheres to its contractual obligations.
We also expect the same from its suppliers and business partners and especially expects
them to observe the basic principles that follow.

Free competition
We comply with the antitrust legislation in force. In
particular, we do not enter into any anti-competitive agreements with competitors,
suppliers, or customers. If we are in a dominant position on the market, we do not abuse
this position.

Export control
We make sure that they comply with all applicable legal provisions for importing and exporting goods, services, and information.

Money laundering
We only conduct business relationships with business partners of whose integrity they are convinced. We ensure that the applicable legal money laundering provisions are not breached.

Business information
We publish business information and report on our business activities truthfully and in line with the laws in force.

Protection of data, business secrets and company assets
Confidential data, business secrets, and company assets have to be protected. We expect suppliers and business partners to especially observe the basic principles that follow.

Data protection
We observe all laws in force to protect the personal data of employees, customers, suppliers, and other parties concerned.

Protection of know-how, patents, trade and business secrets
We respect the know-how, patents, trade and business secrets of us and third parties and do not pass such information on to third parties without the express prior written consent of us or in a way that is otherwise inadmissible.

Handling company assets
We respect our tangible and intangible assets and do not use them for unfair or non-business purposes. We ensure that our employees as well as any third parties they commission in the business relationship (such as subcontractors or representatives) neither damage nor misuse our assets, i.e. use these assets contrary to our interests.

Security of the international supply chain
We have to ensure that the business premises and the loading and shipping areas where products for our customers are produced, stored, prepared, loaded and transported, are protected against unauthorized access within a safe and secure supply chain, and that all employed staff is reliable.

Anti-Corruption
We force a culture of integrity and ensure strict compliance with anti-bribery and
anti-corruption laws across all jurisdictions where we operate.
All employees, directors, and members of our company must comply with this and its
associated procedures, even if local laws permit behaviours that this Policy prohibits.

Anything of Value: Includes, but is not limited to, money, gifts, meals, entertainment,
sponsorships, donations, job opportunities, goods, or properties.

Bribery: The offer, promise, payment, or granting of Anything of Value to improperly induce

Corruption: Dishonest, unethical, or illegal conduct by someone in a position of authority,

often involving an Improper Advantage to gain personal or business benefits.

Facilitation Payments: Payments made to expedite or secure routine governmental actions by a Government Official.

Improper Advantage: A benefit that a company or individual is not entitled to, often obtained through bribery or corrupt practices.
Third Parties: Any individual, company, or entity doing business with us. including suppliers, clients, business partners, and recipients of socioenvironmental investments.
Principles:

We are committed to conducting business with the highest standards of integrity and ethics. Corruption is illegal, unethical, and incompatible with our values.

We have zero tolerance for bribery and corruption in any form. All activities must comply with applicable anti-corruption laws.

Prohibitions:
Bribery: Employees and administrators are prohibited from giving, promising, offering, or authorizing payments or Anything of Value private person to obtain an Improper Advantage.

Facilitation Payments: These are strictly prohibited and must not be made by any employee or administrator.

Cash Gifts: It is forbidden to give cash gifts or cash equivalents, such as gift cards, Gifts, Meals, any Entertainment to Any private persons.

Political Contributions: Employees and administrators must not make political donations or contributions on behalf of our company, including donations to political parties, candidates, or campaigns.

Third Parties: Employees and administrators must not use third parties to carry out activities that we prohibited from performing directly.

Due Diligence: Perform appropriate Anti-Corruption Due Diligence on third parties and business acquisitions to identify potential risks.

Red Flags: Be vigilant for any Red Flags that may indicate potential corruption risks and report any concerns.

Recordkeeping: Maintain accurate and transparent records of all our business transactions.
Cooperation: Employees and administrators must fully cooperate with investigations and maintain confidentiality.

Training: Corporate Integrity will conduct periodic anti-corruption training, which is mandatory for all employees.

General Manager will maintain the Anti-Corruption Policy, overseeing Corporate Integrity, and reports directly to the Board as needed.

Consequences Management and Responsibilities:

Violations: Any violation of this Policy will result in disciplinary actions, which may include dismissal.

Legal Penalties: Violations of anti-corruption laws can lead to civil or criminal penalties.

Termination of Third-Party Relationships: we may terminate a relationship with any third party found to be in violation of this Policy.

Reporting: Employees, administrators, and third parties must report any suspicious activity or potential violations immediately through the Whistleblower Channel.
(See whistleblowing policy)
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