Supplier Code of Conduct

INTRODUCTION

Qfix/CIVCO Radiotherapy and its subsidiaries commit to conducting global business in a legal, ethical, and socially responsible manner. This commitment extends to the suppliers with whom we chose to do business. Qfix/CIVCO Radiotherapy expects the same level of honesty and integrity of its suppliers that it expects of its own employees. To clarify the exact nature of these expectations, Qfix/CIVCO Radiotherapy has prepared this Supplier Code of Conduct (“Code”) which applies globally to all suppliers and the associated sub-suppliers who are part of the supply chain. Suppliers who do not conform to these standards may have their business relationship with the Qfix/CIVCO Radiotherapy terminated.

All suppliers are expected to take necessary steps to ensure compliance with this Code. In addition to any contractual restrictions regarding the use of subcontractors, suppliers will not use any subcontractor unless the subcontractor has agreed to the terms of this Code. Suppliers are also required to be familiar with the business practices of their suppliers and any sub-contractors to ensure that they operate within the guidelines of this Code.



 

COMPLIANCE WITH LAWS AND REGULATIONS

Suppliers will comply with all laws and regulations applicable to its business, as well as the standards of its industry, including those applicable to the manufacture, pricing, sale, distribution, labeling, transport, import and export of goods and services. Qfix/CIVCO Radiotherapy expects Suppliers to comply with the standards set forth in this Code even if more restrictive than any applicable laws, so long as adherence to the Code does not violate any applicable laws. Supplier must actively assess and monitor the day-to-day management processes to ensure compliance with applicable laws and this Code. Suppliers commit to advising applicable employees of the requirements of this Code.

EMPLOYMENT PRACTICES

Qfix/CIVCO Radiotherapy expects compliance with all applicable labor and employment laws and regulations.

Compensation & Benefits: Suppliers must comply with all applicable wage and hour laws and regulations, including those relating to overtime, minimum wage, and other elements of compensation, including any legally mandated benefits.

Working Hours: Suppliers must maintain regular working hours in accordance with all applicable laws and regulations. Suppliers will not require employees to work more in regular or overtime hours than allowed pursuant to applicable law.

Child Labor: Suppliers are prohibited from using child labor. “Child” is defined as any person who is younger than 16 or younger than the minimum working age under applicable law.

Forced Labor: Qfix/CIVCO Radiotherapy will not tolerate the use of forced or involuntary labor. Qfix/CIVCO Radiotherapy will not work with suppliers who directly or indirectly use in any manner forced labor, indentured labor, bonded labor, or involuntary prison labor.

Human Trafficking: Suppliers shall maintain a work environment that is free from human trafficking. Qfix/CIVCO Radiotherapy will not tolerate employment practices that include the recruitment, transportation, transfer, harboring or receipt of persons through the use of force or the threat of force or through other forms of coercion, abduction, fraud, deception, abuse of power or by giving or receiving payments or benefits to achieve the consent of a person having control over another person for the purpose of exploitation.

Non-Discrimination, Harassment & Disciplinary Practice: Suppliers will not unlawfully discriminate against any worker in its hiring or employment practices on the basis of race, sexual orientation, gender identity, age, gender, disability, natural origin, religion or any other legally protected class or category. Employees of suppliers must not be exposed to physical punishment, threats of violence or physical, sexual, psychological, or verbal harassment or maltreatment.

Freedom of Association: Suppliers should respect the rights of employees to choose whom to associate with or not associate with and to establish any lawful organization including labor organizations pursuant to applicable law.

Health & Safety: Suppliers must provide employees with a safe and healthy working environment, and where provided, a safe and healthy living environment. Suppliers shall comply with all applicable worker safety laws and regulations which include:

• Building Integrity

• Occupational Safety

• Occupational Injury & Illness

• Emergency Preparedness

• Machine Safeguarding

• Chemical Safety

• Sanitation, Food & Dormitory

• Air quality

ETHICAL CONDUCT AND ANTI-CORRUPTION

Qfix/CIVCO Radiotherapy requires its suppliers to commit to the highest standards of integrity and ethics in conducting its business, including:

Corruption and Bribery: Suppliers will not engage in corruption, extortion, or embezzlement in any form, offer or accept bribes or employ any other means to obtain an undue or improper advantage. Suppliers must comply with all applicable anti-corruption laws and regulations of the countries where it conducts business, the U.S. Foreign Corrupt Practices Act, the UK Anti- Bribery Act, the Organization for Economic Co-operation, and Development (“OECD”) Anti- Bribery Convention and all international anti-corruption treaties or conventions.  Suppliers must not bribe or provide kickbacks or any improper payments or gifts to any officer, director, employee, representative or agent of Qfix/CIVCO Radiotherapy. Suppliers must immediately report to Qfix/CIVCO Radiotherapy any instance where an employee or representative of Qfix/CIVCO Radiotherapy has made any such unethical or illegal request or demand of the supplier.

Books and Records: Suppliers’ accounting records must:

• be kept in accordance with the laws of each applicable jurisdiction

• be maintained in reasonable detail, and accurately and fairly reflect transactions, assets, liabilities, revenues, expenses; and

• not contain any false, misleading, or deceptive entries.

Conflicts of Interest: Suppliers must immediately report to Qfix/CIVCO Radiotherapy any conflict of interest of which it becomes aware. A conflict of interest is defined as any circumstance, transaction or relationships directly or indirectly involving the supplier in which the business interest of the supplier or the private interest of any employee improperly interferes or appears to improperly interfere with the interests of Qfix/CIVCO Radiotherapy.

Reporting Requirements: Suppliers must have a policy prohibiting unlawful or unethical conduct that provides employees and representatives of the supplier a way to raise concerns and a process for investigating and resolving incidents. Suppliers must not tolerate retaliation against any employee who makes a report of abuse, intimidation, discrimination, harassment, or any violation of law or of the Code, or who assists in the investigation of the report.

ENVIRONMENTAL

Suppliers shall comply with all applicable environmental laws and regulations. This shall include having processes in place to ensure compliance with those regulations relating to the handling, recycling, and disposal of dangerous or hazardous materials.

SECURITY

Suppliers will maintain adequate security at all production and warehousing facilities and implement supply chain security procedures designed to prevent the introduction of non-manifested cargo into outbound shipments. Each supplier facility must have written security procedures to document proof of adequate security controls.

GIFT & GRATUITY POLICY

Qfix/CIVCO Radiotherapy employees are prohibited from soliciting or accepting any gifts, gratuities or other monetary incentives designed to improperly influence business decisions or as a condition of doing business. Suppliers have an affirmative duty to report any such request or demand immediately to Qfix/CIVCO Radiotherapy.

CONFLICT MINERALS

Suppliers shall implement procedures to reasonably assure that the use of tin, tantalum, tungsten, and gold (“Conflict Minerals”) in the products they manufacture does not directly or indirectly finance or benefit armed groups in the Democratic Republic of Congo or an adjoining country. Suppliers will exercise due diligence, in accordance with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, on the source and chain of custody of Conflict Minerals and make their due diligence practices available. Upon Qfix/CIVCO Radiotherapy’s request, Suppliers will fully cooperate in responding to any due diligence and country of origin inquiries regarding Conflict Minerals (including requesting information from its own suppliers) and provide the requested documentation.

MONITORING AND REPORTING

Qfix/CIVCO Radiotherapy will review this Code on a regular basis and will revise it to incorporate additional parameters when necessary.
 

Supplier must maintain all documentation necessary to demonstrate its compliance with the Code and will provide Qfix/CIVCO Radiotherapy access to such documentation upon its request.

Qfix/CIVCO Radiotherapy shall have the right to periodically inspect suppliers and their facilities to verify compliance with this Code either directly or through a third-party. Such inspections may be conducted without notice to suppliers. Suppliers are also required to disclose all material facts relating to production of products for Qfix/CIVCO Radiotherapy upon request.

Suppliers must immediately notify Qfix/CIVCO Radiotherapy using its ethics and compliance hotline (detailed in Qfix/CIVCO Radiotherapy’s Code of Ethics: (https://civcort.com/ro/About-Us/Code-of-Ethics) upon learning of any known or suspected improper behavior by supplier or by employees of Qfix/CIVCO Radiotherapy.

This Code is a general statement of Qfix/CIVCO Radiotherapy’s expectations with respect to its suppliers. The Code should be read in conjunction with suppliers’ obligations set forth in any agreements between Qfix/CIVCO Radiotherapy and suppliers. In the event of a conflict between this Code and any such agreement, the agreement shall control.