We always do what is right. We strive to operate in a manner that reflects high ethical standards and are committed to complying with all applicable laws, regulations, and other legal requirements in every country we operate.
We are dedicated to providing quality products and services that meet or exceed the requirements of our patients and customers. Our business relationships are built on trust, mutual respect, and transparency.
Introduction
Nuance Medical requires all third-party suppliers to comply with this Supplier Code of Conduct (“Code”). Third-party suppliers include any supplier, along with their subsidiaries, affiliates, agents, and subcontractors (“Suppliers”), who provide goods and services to Nuance Medical or its subsidiaries and affiliates, whether directly or indirectly.
Nuance Medical recognizes that its Suppliers operate independently and are not under its control or direction. However, adherence to this Code is required to be selected as a Supplier for Nuance Medical.
Nuance Medical reserves the right to audit its Suppliers at any time to ensure compliance with this Code. Any potential violations may jeopardize the business relationship, up to and including termination.
Suppliers acknowledge that this Code and applicable laws and regulations are subject to change over time. They agree to stay informed and comply with any updates to this Code and their legal obligations.
Labor and Human Rights
We are committed to fostering an ethical culture and a safe workplace. We expect our suppliers to act ethically and with integrity in all business dealings and to adhere to the following standards:
Nuance Medical strives to engage with suppliers committed to conducting business ethically and responsibly, including respecting internationally recognized human rights. We expect suppliers to treat their workers with dignity and respect and to uphold the highest human rights standards.
Specifically, we require the following of each of our suppliers:
Underage Labor. Nuance Medical does not tolerate the use of underage labor and will not knowingly work with suppliers that employ underage workers. An underage worker is defined as any individual younger than the local minimum working age or the age of 15, whichever is older, or anyone not adhering to the age-related working restrictions established by local law or international standards as defined by the International Labor Organization (ILO).
If underage workers are found working, the Supplier must:
Forced Labor or Human Trafficking. We condemn the use of any form of forced, bonded, indentured, compulsory, exploitative prison, trafficked, or slave labor as defined by the International Labor Organization (“ILO”) Forced Labour Convention (No. 29) and Abolition of Forced Labour Convention (No. 105).
Suppliers are strictly prohibited from recruiting, harboring, transporting, provisioning, or obtaining individuals for labor or services through force, fraud, or coercion. All labor must be voluntary. Workers must have the right to freedom of movement without undue restrictions on entering and exiting facilities and must be free to leave or terminate their employment at any time.
Working Hours. Suppliers must ensure working hours do not exceed the applicable legal limit or 60 hours per week, except in emergencies or other exceptional circumstances. Suppliers must also provide workers with at least one day off in every seven-day working period. Overtime work must always be voluntary and compensated at a premium rate.
Wages. Workers must not be required to perform unpaid work. Workers’ monthly wages or piece-rate pay must, at a minimum, meet local legal minimum wage requirements or industry benchmark rates. Wages must be paid regularly, in full, and in accordance with local laws.
Compensation. Suppliers must ensure that workers are paid at least the minimum wage and provided benefits as required by applicable laws and regulations. Overtime must be compensated at the rates mandated by those laws and regulations. Workers must be free to leave their employment with reasonable notice and must be paid on time and in full for all work completed prior to their departure.
Health and Safety. Suppliers must provide workers with a workplace that meets applicable health and safety standards and, if applicable, safe and healthy living quarters. Suppliers must also have health and safety programs in place to:
Worker Safety and Protection: Protect workers from exposure to chemical, biological, and physical hazards in the workplace.
Hazardous Chemical Information: Provide workers with safety information and training about hazardous materials and their safe use to prevent exposure. Workers should be informed about hazardous materials, including cleaning agents, solvents, raw materials, and various types of waste.
Emergency Preparedness and Response: Develop and display emergency evacuation routes and response procedures in the workplace facilities and company-provided living quarters to minimize the impact of emergencies requiring immediate evacuation.
Fair Treatment. Suppliers must maintain a working environment free from harsh or inhumane treatment, including mental or physical coercion or corporal punishment. Physical, psychological, verbal, or sexual abuse or harassment will not be tolerated under any circumstances.
Fair Treatment Oversight. Suppliers should designate a qualified individual to ensure fair treatment policies and practices are implemented. All workers must understand disciplinary and grievance procedures, and fines imposed as part of disciplinary action must be legal and fair. Supervisors or individuals in positions of authority found abusing workers must be appropriately disciplined.
Security Personnel Standards. Workers must not be subjected to body searches. When physical security searches are necessary, they must be conducted only by authorized parties, in accordance with local laws and legal standards, and performed by same-sex security guards.
Working Conditions. Suppliers must provide all workers with access to clean toilets and potable water. Workers must also have access to sanitary food preparation, storage, and dining areas. If residential facilities are provided, they must be safe and sanitary.
Freedom of Associations. Suppliers must respect workers’ rights to freely choose to join associations, organizations, and trade unions, and to bargain collectively, as permitted by local laws or regulations.
Antidiscrimination. Suppliers must promote a workplace free from discrimination. They must not discriminate against any worker based on age, ethnic origin, disability, national origin, gender, marital status, physical appearance, pregnancy, religion, race, sexual orientation, or union association in hiring or other employment practices.
Reporting Concerns. Workers should be encouraged to report concerns or illegal activities in the workplace without fear of retaliation, bullying, or harassment. Suppliers must investigate reports and take appropriate, ethical corrective action if necessary.
Cash Deposits. Suppliers must not require workers to pay cash deposits to secure their jobs, employer-provided accommodations, or pay deposit fees for tools, training, or personal protective equipment needed to perform their jobs safely.
Ethical and Compliant Business Practices
Conflicts of Interest. Suppliers must have processes to identify, prevent, and manage conflicts of interest involving their employees, owners, or investors.
Anti-Bribery and Corruption. Suppliers must comply with all applicable anti-bribery and corruption laws and industry codes. They must not offer or accept bribes, kickbacks, illegal political contributions, or other improper payments to any customer, government official, or private individual.
Facilitation Payments. Facilitation payments are strictly prohibited, regardless of whether they are permitted under local laws.
Gifts, Hospitality, and Entertainment. Gifts, hospitality (refreshments, meals, and/or accommodations), or entertainment must never be provided to influence or encourage a recipient to make a favorable business decision for the Supplier or Nuance Medical. In restricted, regulated circumstances, gifts, hospitality, or entertainment may be permitted but must be modest, reasonable, and infrequent for any individual recipient. Suppliers must adhere to Nuance Medical’s policies regarding gifts, hospitality, and entertainment to healthcare professionals, as well as restrictions on providing anything of value to government officials.
Competing Fairly. Suppliers must conduct business in a manner consistent with fair and vigorous competition and in compliance with all applicable antitrust laws. Suppliers are expected to employ fair business practices, including accurate and truthful advertising.
Subcontracting. Suppliers who use subcontractors under the terms of any agreement with Nuance Medical must ensure that all subcontractors comply with this Code. Suppliers must not retain any subcontractor who fails to adhere to this Code.
Global Trade and Compliance. Suppliers must comply with all applicable import/export laws and international trade control and customs regulations, including requirements for licensing, shipping, import documentation, reporting, and record retention. Suppliers are also expected to adhere to international supply-chain security requirements, such as those under the U.S. Customs-Trade Partnership Against Terrorism (CTPAT), Canada Partners in Protection (PIP), or Mutual Recognition Arrangements for comparable international Authorized Economic Operators (AEO).
Confidential Information and Data Privacy. Suppliers must implement and maintain adequate personal data and information security protections for all information they process, including that processed by subcontractors acting on their behalf. Suppliers must comply with all applicable data protection and privacy laws and align with industry standards for safeguarding and securing information.
Protection of Data and Personal Information: Suppliers must establish an organizational structure to effectively manage policies and procedures for protecting the confidentiality, integrity, and availability of information. This includes safeguarding Personal Information and confidential business information from cyber threats, unauthorized access, destruction, alteration, disclosure, or misuse.
Monitoring, Enforcement & Management Systems
Monitoring and Enforcement. Suppliers are expected to cooperate with and support Nuance Medical, either directly or through a third party, in conducting inspections and audits upon reasonable notice to ensure compliance with this Code. Suppliers must maintain all documentation demonstrating compliance and provide it to Nuance Medical or an authorized third-party agent upon request.
Subcontractor Relationships: Suppliers must implement a vendor risk management program, conduct due diligence activities, and notify Nuance Medical in advance. Written consent from Nuance Medical is required before subcontracting or assigning any obligations under a contract with Nuance Medical.
Documentation: Suppliers must maintain and ensure easy access to documentation demonstrating compliance with applicable laws, industry codes, and Nuance Medical contract obligations.
Books and Records: Suppliers must maintain complete and accurate books and records for all Nuance Medical-related business activities, along with supporting documentation, in accordance with applicable accounting laws and industry codes.
Compliance Training and Education: Suppliers must implement training programs to educate their employees on making ethical decisions in compliance with applicable laws, industry codes, and Nuance Medical contractual requirements. When necessary, Nuance Medical may, at its discretion, require a Supplier to facilitate training that meets Nuance Medical’s standards in any subject area covered by this Code, at the Supplier’s expense.
Reporting Concerns to Nuance Medical: Suppliers who know of or suspect a violation of this Supplier Code of Conduct, applicable laws, regulations, or industry codes, whether by someone within or outside the Supplier’s organization, must take action to report the violation. Reports can be made through one of the following reporting channels: