Compliance

Suppliers must comply with all applicable laws and regulations, industry standards and the requirements of this Supplier Code.  NDC reserves the right to audit against compliance to this Supplier Code. Suppliers are expected to ensure that documentation is kept that demonstrates compliance with this Code; NDC may request access to that documentation at any time upon reasonable notice. NDC may also request access to supplier sites for audit purposes.

Business Ethics and Anti-Corruption

Suppliers shall strictly comply with all applicable laws relating to anti-corruption and bribery, e.g., the UK Bribery Act and the U.S. Foreign Corrupt Practices Act.  This means that Supplier shall not engage in or permit any kind of corrupt practices, including giving and/or receiving bribes.  We also expect our suppliers to comply with all applicable law regarding fair competition, which means, among other things, not engaging in any sort of bid rigging, price fixing, illegal collusion, or other anti-competitive behavior.  We encourage our Suppliers to implement and abide by an internal ethics program which includes employee ethics training.

Human Rights and Labor Standards

Suppliers shall support and respect the protection of internationally proclaimed human rights and must not be complicit in any form of human rights abuse. Specifically, Suppliers:

• Must not tolerate any form of unlawful discrimination during recruitment or employment.
• Must not use any form of forced or compulsory labor. All labor must be voluntary.
• Must not engage in or support trafficking of human beings or any form of slavery.
• Must not use child labor. No persons may be employed or engaged in any work if they are below the legal working age.

Environment

Suppliers must operate in a manner which is sensitive to the environment, emphasizing energy efficiency and minimization of pollution.  We expect Suppliers to collaborate with us to reduce the environmental impacts of our products and our services.

Quality and Process Improvement

Suppliers must demonstrate a commitment to quality and continuous improvement throughout their operations.  We encourage suppliers to work openly and collaboratively with us to ensure we are continually improving our operations.