Toradex Business Partner Code of Conduct

Toradex is committed to conducting its business ethically, legally, and in a socially and environmentally responsible manner. Toradex does request its business partners to join Toradex in its commitments, based on a shared set of values and principles.

Toradex seeks to grow business with Toradex Business Partners that are committed to acting fairly and with integrity towards their stakeholders, observing the applicable rules of law, and supporting and respecting internationally proclaimed human rights. In addition, Toradex is committed to ensuring that working conditions along the supply chain are safe, that workers are treated with respect and dignity, and that manufacturing processes are environmentally responsible.

Toradex Business partners shall commit, in all their activities, to operate in full compliance with applicable laws, rules, and regulations of the countries in which they are active.

Introduction

Scope

The Toradex Business Partner Code of Conduct applies to all our business partners, including consultants, supply chain partners, service providers, sales channel partners, and technology partners. It applies to any business relationship with Toradex and defines the minimum standard of business conduct and practices we expect our business partners to follow.

Alternatively, Toradex Business partners may commit themselves to following the Responsible Business Alliance Code of Conduct (latest version) or another Code of Conduct exceeding our minimum standards as defined below.

The Toradex Business Partner Code of Conduct does not intend to create any new and / or additional third-party rights, including for employees.

Toradex Business Partners Cooperation

Toradex may request from its business partners information about compliance with this Code of Conduct or as required by law. A timely and complete response to any information request is expected. In addition, Toradex expects that Toradex Business Partners perform appropriate due diligence to assess whether their sourcing activities do directly or indirectly support armed conflicts or human rights violations.

Corporate Law and Statutes

Toradex Business partners are required to follow all applicable local laws.

Fair Competition and Antitrust

Standards of fair business, advertising, and competition are to be upheld. Toradex Business partners and their employees are expected to compete fairly and act ethically for all business opportunities. Toradex Business partners shall uphold the highest standards of ethics and integrity in all business interactions. All forms of bribery, corruption, extortion, embezzlement, or similar practices are prohibited.

Confidential Information and Data Privacy

Toradex Business Partners shall commit to protecting the reasonable privacy expectations for the personal information of everyone they do business with, including Toradex Business Partners, customers, consumers, and employees. Toradex Business Partner shall comply with privacy and information security laws and regulatory requirements when personal information is collected, stored, processed, transmitted, and shared.

Programs that ensure confidentiality, anonymity, and protection of Toradex Business Partner and employee whistleblowers are to be maintained unless prohibited by law.

Intellectual Property

Intellectual property rights are to be respected, and the transfer of technology and know-how is to be done in a manner that protects intellectual property rights. Customer and Toradex Business Partner information is to be safeguarded. All applicable privacy and information security laws and regulatory requirements must be followed.

Conflict Minerals

Toradex Business Partner shall adopt a policy and exercise due diligence on the source and chain of custody for the tantalum, tin, tungsten, and gold products they manufacture to reasonably assure that they are sourcing in a way that is consistent with the OECD Conflict Minerals Guidance (including all annexes and supplements) or other internationally recognized equivalent regulations (e.g., EU Regulations on Conflict Minerals, Swiss Ordinance on Due Diligence and Transparency in relations to Minerals and Metals from Conflict-Affected Areas and Child Labour “DDTrO” etc.) Upon request, Toradex Business Partners shall provide Toradex with all information needed to comply with the above-mentioned regulations and exercise due diligence on the source and chain of custody of the above-mentioned minerals. In addition, Toradex Business Partners shall make their due diligence measures available to Toradex.

Labor Law and Statutes

Toradex Business partners are expected to create and maintain a work environment where all employees are treated with dignity and respect. The work environment shall be free of any violence, abuse, mental or physical coercion, unlawful discrimination, or harassment. Toradex Business partners shall not engage in discrimination or harassment based on race, color, age, gender, sexual orientation, gender identity and expression, ethnicity or national origin, disability, religion, political affiliation, union membership, or other distinctive features.

Freely Chosen Employment

All employment must be freely chosen. Any forced labor, prison, or slave labor is prohibited in any stage of providing any services. All workers must be provided with a written employment agreement that contains a description of the terms and conditions of employment. Work must be voluntary, and workers shall be free to leave work at any time or terminate their employment without penalty if reasonable notice is given as per the worker’s contract. Employers, agents, and sub-agents may not require employees to give up possession of personal documents, including identification papers, immigration documents, or work permits unless such holdings are required by law. In this case, at no time should workers be denied access to their documents.

Working hours and remuneration

Compensations paid to workers shall comply with all applicable wage laws, including those relating to minimum wages, overtime hours, and legally mandated benefits. Deductions from wages as a disciplinary measure shall not be permitted. For each pay period, workers shall be provided with a timely and understandable wage statement that includes sufficient information to verify accurate compensation for work performed. All use of temporary, dispatch and outsourced labor shall be within the limits of the applicable local law.

Forced Labor and Human Trafficking

Toradex Business partners must commit to upholding the human rights of workers, treat them with dignity and respect, and employ them according to local working laws and regulations.

Child Labor

Toradex Business partners shall neither use nor support child labor in any stage of providing any service, as defined in the ILO Minimum Age Convention No. 138, the ILO Worst Form of Child Labor Convention No. 182 and respective Recommendations, or any other internationally recognized equivalent regulations (e.g., Swiss Ordinance on Due Diligence and Transparency in relation to Minerals and Metals from Conflict-Affected Areas and Child Labour “DDTRO”.) Business Partners are expected to implement an appropriate mechanism to verify the age of workers. Workers under the age of 18 (young workers) shall not perform work that is likely to jeopardize their health or safety, including night shifts and overtime.

Freedom of Association

In conformance with local laws, Toradex Business partners shall respect the right of all workers to freely join or not join labor unions, to bargain collectively, to engage in peaceful assembly, or to join workers’ councils. Workers and / or their representatives shall be able to openly communicate and share ideas and concerns with management regarding working conditions and management practices without fear of discrimination, reprisal, intimidation, or harassment.

Health and Safety

Toradex Business partners must be committed to creating safe working conditions and a healthy work environment for all its workers. Appropriate controls, safe work procedures, preventative maintenance, and protective measures must be provided to mitigate health and safety risks in the workplace. Reasonable steps must be taken to remove pregnant women and nursing mothers from working conditions with high hazards.

Workers must be protected from over-exposure to chemical, biological, and physical hazards. Workers' potential for exposure to health and safety hazards is to be identified, assessed, and mitigated by appropriate measures. Where hazards cannot be adequately controlled, workers are to be provided with appropriate, well-maintained, personal protective equipment and educational materials about risks associated with these hazards.

Production and other machinery shall be evaluated for safety hazards, and appropriate measures are to be provided to minimize injury hazards to workers.

Workers are to be provided with ready access to hygienic toilet facilities and clean drinking water. If Toradex Business partners or labor agents provide dormitories to workers, these accommodations must be freely accessible, clean, and safe, with access to hot water, adequate lighting, heat, and ventilation, with the possibility for personal retreat and privacy.

Chemicals, waste, and other materials posing a hazard to humans or the environment are to be identified, labeled and managed to ensure their safe handling, movement, storage, use, recycling or reuse, and disposal.

Air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone-depleting substances, and combustion by-products generated from operations as well as wastewater are to be characterized, routinely monitored, controlled, and treated as required by applicable laws and regulations prior to discharge. Ozone-depleting substances are to be effectively managed in accordance with the Montreal Protocol and applicable regulations.

Toradex Business Partners shall comply with all applicable laws and regulations prohibiting or restricting the use and handling of specific substances in manufacturing and product materials, including labeling for recycling and disposal. This legislative compliance includes:

Restrictions of Hazardous Substances (RoHS)
Regulation of Registration, Evaluation, Authorization, and Restriction of Chemicals (REACH)
Waste Electrical and Electronic Equipment Directive (WEEE or RoHS2) or its implementation into national laws
other regulations applicable in countries and regions where Toradex is active

Upon request, Toradex does expect its Business Partners to disclose the material content and origin of materials provided to Toradex.

Environmental Protection

Toradex Business partners are expected to do business in an environmentally responsible manner that minimizes adverse effects on the community, the environment, and natural resources. This includes optimizing the use of natural resources, such as energy, water, chemicals, and raw materials, avoiding the use of hazardous materials where possible, and engaging in activities that reduce, reuse, or recycle.

All applicable laws and regulations regarding the prohibition or restriction of specific substances (such as hazardous materials) including labeling laws and regulations for recycling and disposal must be followed.

All required environmental permits, licenses, approvals, and information registrations are to be obtained, maintained and kept current, and their operational and reporting requirements are to be followed.

Emissions and discharges of pollutants and generation of waste are to be minimized or eliminated at source or by practices such as adding pollution control equipment, modifying production, maintenance, and facility processes, or by other means.

The use of natural resources, including water, fossil fuels, minerals, and virgin forest products, is to be conserved by practices such as modifying production, maintenance, facility processes, materials substitution, reuse, conservation, recycling, or other means.

Toradex Business partners are invited to adopt environmental management policies and procedures, to track environmental performance and define reduction goals for non-hazardous solid waste, water use and discharge, energy consumption, and greenhouse gas emissions.

Requirement for a Management System

Toradex Business Partner shall adopt or establish a management system that is in compliance with this Code of Conduct and allows identification and mitigation of operational risk defined in this Code. In addition, the management system shall ensure compliance with all applicable laws and regulations within their territorial scopes.

The management system should include the following elements:

Commitment to legal compliance.
Corporate social and environmental responsibility policy statement.
Commitment to the Toradex Code of Conduct, alternatively the RBA Code of Conduct or equivalent.
Implementation of risk assessment and risk management processes associated with Toradex and related to environmental, social, and governance issues (ESG).
Regular audits and assessments ensure conformity with legal and regulatory requirements, the content of this Code of Conduct, and additional Toradex contractual requirements.

Toradex Business Partners shall create and maintain records to ensure regulatory compliance and conformity to the Toradex requirements along with appropriate confidentiality to protect the privacy of parties involved.

Toradex Open Door

Toradex commits to upholding the highest standards in ethics and business integrity in its operations and supply chain. We encourage employees or external stakeholders to bring forth questions, remarks, or concerns that help Toradex maintain a positive work environment and comply with all values and principles defined in our Code of Conduct.

Toradex provides its Business Partners with a confidential communication channel to raise questions and concerns: Send us Feedback