AddressUnit 8, Atley Way, North Nelson Industrial Estate, Cramlington
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Office01670 716811
Write usenquiries@cpfl-tvs.co.uk
Conduct for Third Parties
1. Introduction
At Cramlington Precision Forge Ltd. (CPFL), our purpose is to excel in precision forging, shaping the future with integrity and innovation. We believe in the critical role that precision engineering plays in global development, and we are committed to serving society by generating prosperity for all while caring for the environment. Our values guide our efforts to remain an ethical company that continually grows in a sustainable manner.
These Principles of Conduct for Third Parties complement CPFL's Code of Conduct by outlining how our values should be implemented by our suppliers, customers, and other partners. We seek to collaborate with third parties who understand and comply with all applicable laws and who are committed to operating their businesses in a responsible and ethical manner. We encourage our third parties to incorporate these principles into their own codes of conduct.
2. How CPFL’s Values Apply to Our Third Parties
2.1 Life Matters Most
At CPFL, we place people at the center of our decisions, and we believe that everyone has the right to a safe and healthy environment. We follow an integrated and efficient management model to perform our activities with excellence, focusing on health, safety, and risk management. We believe that operating with excellence and safety naturally leads to achieving our production and financial goals in a responsible and ethical manner.
2.1.1 Security in All Aspects
Third parties must comply with applicable workplace health and safety laws and regulations and adhere to CPFL-site-specific health and safety rules and requirements when working at a CPFL site, ensuring a safe and healthy working environment.
2.1.2 Responsibility for People’s Lives
Third parties should recognize that their decisions may affect people’s lives. They must establish standards to ensure operational discipline and execute activities in an ethical, responsible, and safe manner.
2.1.3 Health at Work
Third parties should strive to promote a healthy and safe work environment, continuously adopting and monitoring solutions and technologies to identify, manage, reduce, and eliminate exposure to occupational health and safety risks.
2.2 Respect Our Planet and Communities
CPFL is committed to economic, social, and environmental development in all its business decisions. We are accountable for the risks and impacts of our operations on communities while contributing to the promotion of a positive legacy in the areas where we operate.
2.2.1 Care for the Environment
Third parties must comply with applicable environmental laws and regulations and adhere to CPFL’s environmental guidelines and any site-specific environmental rules and requirements when working at a CPFL site. Third parties should promote the responsible use of natural resources and adopt cleaner production and pollution prevention measures.
2.2.2 Relationship with Society
Third parties should respect the communities where we operate, considering community safety, inclusion, diversity, and the socio-economic, cultural, and environmental aspects of these areas. They should value the knowledge and skills of local communities and seek to understand and respect their history and rights. Third parties are encouraged to engage in transparent dialogue with communities impacted by their activities.
2.3 Value the People Who Build Our Company
CPFL respects and promotes human rights, constantly seeking to prevent potential impacts and violations and, if necessary, mitigating and remedying them. We follow the United Nations Guiding Principles on Business and Human Rights and the laws of each country in which we operate, in addition to national and international standards.
2.3.1 Respect for Human Rights
CPFL expects third parties to be familiar with CPFL’s Human Rights Policy and to guide their conduct accordingly. Third parties should respect and promote human rights in their supply chain and workplace, taking appropriate measures to prevent, mitigate, and if necessary, remedy violations. They are encouraged to report any human rights violations within our value chain through CPFL’s Whistleblower Channel.
2.3.2 Inclusive Work Environment
Third parties should aim to build a diverse and inclusive work environment based on mutual respect, ethics, and integrity, rejecting any form of prejudice, discrimination, or harassment.
2.4 Act with Integrity
Ethics is a daily requirement at CPFL, guiding every decision we make. Our Code of Conduct helps us make the best decisions in a responsible manner. CPFL has zero tolerance for bribery and corruption and will not protect anyone involved in such activities, whether they are an employee or a third party.
2.4.1 Open and Transparent Dialogue
Third parties are expected to engage in open and transparent dialogue, especially when interacting with their CPFL contacts. CPFL will never retaliate against anyone, including third parties, for expressing different opinions. We are committed to active listening and resolving problems transparently.
2.4.2 Absence of Conflicts of Interest
When working for or on behalf of CPFL, third parties must avoid any actions or omissions that could expose CPFL to legal liability, public criticism, or harm its operations, activities, or reputation. Third parties should disclose any personal relationships with CPFL employees involved in their business relationship with CPFL before entering negotiations and during their ongoing business relationship.
2.4.3 Data and Asset Accountability
Third parties must handle CPFL’s information and assets responsibly, maintaining the confidentiality and integrity of CPFL’s data according to the provided classification guidelines. They must not misuse CPFL information or assets for their benefit and should respect CPFL’s information disclosure and securities trading policies.
2.4.4 Personal Data Privacy and Protection
Third parties must conduct their activities in compliance with applicable personal data protection laws and strive to apply best practices, procedures, and technologies to ensure the protection of personal data and prevent incidents or breaches of privacy.
2.4.5 Intolerance for Corruption or Any Improper Advantage
Third parties must never offer, promise, or give anything of value to any government official or person to obtain an improper advantage or that could damage CPFL’s ethical reputation. Third parties must also refrain from making facilitation payments, even if permitted by local laws.
2.4.6 Fair Competition
Third parties should act with integrity, fostering a business environment free of fraud and manipulation, and complying with antitrust and fair competition laws. Third parties must not collude or agree to fix prices, terms, or conditions or attempt to influence the outcome of a CPFL procurement process.
2.4.7 Sanctions and Money Laundering
Third parties should conduct their activities with diligence, ensuring compliance with domestic and international import and export controls, respecting economic and trade sanctions, and adhering to anti-money laundering laws.
2.4.8 Gifts, Meals, and Entertainment
Third parties must never exchange gifts, meals, or entertainment with government officials or any other person on behalf of CPFL. They must also refrain from offering gifts, meals, or entertainment to CPFL employees for any improper advantage. The exchange of cash or cash equivalents, such as gift cards, with CPFL employees is strictly prohibited.
2.5 Make It Happen
CPFL seeks results that align with our values. We enforce autonomy with responsibility, preventing and mitigating risk at all levels. We conduct periodic monitoring to visualize the main risks and the effectiveness of our controls.
2.5.1 Internal Controls and Transparency
Third parties should maintain accurate financial books and records and have documentation to demonstrate alignment with these Principles of Conduct. CPFL may assess commitment to these principles through routine evaluations and requests for supporting documentation. Failure to comply, or failure to correct non-compliance, may result in the termination of CPFL’s business relationship with a third party.
3. Reporting Suspected Misconduct and Interacting with CPFL
3.1 Whistleblower Channel
CPFL’s Whistleblower Channel is available to employees and external third parties to report any concerns about ethical misconduct or failure to apply these Principles of Conduct. The channel guarantees confidentiality, protects whistleblower anonymity, and safeguards information for a fair investigation. CPFL handles allegations impartially and objectively, with all necessary measures taken to ensure fairness and accountability.
3.2 Listening and Response Mechanisms
CPFL has developed Listening and Response Mechanisms, implementing channels that stakeholders can use to communicate with the company. These interactions require a response or action from CPFL. The channels include “Contact Us,” social media platforms, and Community Relations Personnel, with additional local coverage channels where necessary.
4. Glossary
Harassment: A series of inappropriate actions or comments that create a hostile environment, including bullying, intimidation, and discriminatory insults. Sexual harassment is a specific form of harassment that involves unwanted sexual advances or attention.
Sanctions: Laws and regulations that prohibit or restrict business dealings with certain countries, nationals, entities, or individuals.
This adaptation of the Principles of Conduct for Third Parties aligns specifically with CPFL’s values and operational context, ensuring that all third parties conducting business with CPFL understand and adhere to these essential guidelines. This policy is designed solely for CPFL, with no reference to subsidiaries or affiliated entities.
2.5.1 Internal Controls and Transparency
Third parties should maintain accurate financial books and records and have documentation to demonstrate alignment with these Principles of Conduct. CPFL may assess commitment to these principles through routine evaluations and requests for supporting documentation. Failure to comply, or failure to correct non-compliance, may result in the termination of CPFL’s business relationship with a third party.
3. Reporting Suspected Misconduct and Interacting with CPFL
3.1 Whistleblower Channel
CPFL’s Whistleblower Channel is available to employees and external third parties to report any concerns about ethical misconduct or failure to apply these Principles of Conduct. The channel guarantees confidentiality, protects whistleblower anonymity, and safeguards information for a fair investigation. CPFL handles allegations impartially and objectively, with all necessary measures taken to ensure fairness and accountability.
3.2 Listening and Response Mechanisms
CPFL has developed Listening and Response Mechanisms, implementing channels that stakeholders can use to communicate with the company. These interactions require a response or action from CPFL. The channels include “Contact Us,” social media platforms, and Community Relations Personnel, with additional local coverage channels where necessary.
4. Glossary
Harassment: A series of inappropriate actions or comments that create a hostile environment, including bullying, intimidation, and discriminatory insults. Sexual harassment is a specific form of harassment that involves unwanted sexual advances or attention.
Sanctions: Laws and regulations that prohibit or restrict business dealings with certain countries, nationals, entities, or individuals.
This adaptation of the Principles of Conduct for Third Parties aligns specifically with CPFL’s values and operational context, ensuring that all third parties conducting business with CPFL understand and adhere to these essential guidelines. This policy is designed solely for CPFL, with no reference to subsidiaries or affiliated entities.
