CODE OF BUSINESS CONDUCT & ETHICS
Optoma Corporation and its affiliated entities worldwide (hereinafter referred to as “Optoma”) are committed to the highest standards of product quality and business integrity in their dealings with customers and suppliers. As a result, all suppliers and the Optoma employees who work with them are expected to conduct themselves with the highest standards of honesty, fairness and personal integrity. It is critical to Optoma that suppliers and employees alike maintain high ethical standards, adhere to all applicable laws, and avoid even the perception of impropriety or conflict of interest.
Violations of the Code of Business Conduct and Ethics
All suppliers should immediately report any known or suspected violation of this Code of Business Conduct and Ethics, including any violation of applicable laws, rules, regulations or policies. All reports of known or suspected violations of the law or this Code of Business Conduct and Ethics will be handled sensitively and with discretion. The confidentiality of any reporting person will be protected to the extent possible, consistent with applicable law and Optoma's need to effectively investigate the reported concern.
Compliance with Laws and Regulations
All suppliers must conduct their business activities with Optoma in compliance with applicable laws and regulations:
- Antitrust: Conduct business in full compliance with antitrust and fair competition laws that govern the jurisdictions in which suppliers conduct business. Suppliers should promote free and fair competition in the marketplace and avoid business practices that have the purpose or effect of limiting competition, such as bid rigging, price fixing, cover pricing or market sharing.
- Licensing/Permits: Obtain all required licenses or permits to conduct business activities.
- Privacy: Comply with all laws and regulations regarding the privacy of information, data protection and cross-border data flows.
- Trade: Comply with all applicable trade controls, as well as all applicable export, re-export and import laws and regulations.
Business Practices and Ethics
All suppliers must conduct their business consistent with the highest standards of business ethics and in compliance with their own applicable professional standards, and must, without limitation:
- Business Records: Accurately record and report all business and financial information and comply with all applicable standards, laws and regulations concerning the completion, accuracy and retention of such records and reports.
- Confidential Information: Safeguard all non-public information of Optoma or third parties with which Optoma conducts business, which might be of use to competitors or, if disclosed, harmful to Optoma or such third parties, unless disclosure is authorized or legally mandated, and then only in compliance with applicable confidentiality agreements and procedures.
- Conflicts of Interest: Avoid any private interest that might influence, or appear to influence, the ability to act in the interests of Optoma or that makes it difficult to conduct Optoma's business objectively and effectively. Suppliers should immediately report any such actual or potential conflict of interest to Optoma, and Optoma will determine whether a conflict of interest exists and, if so, how best to address it.
- Fair Dealing: Deal fairly in all relationships and avoid taking unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts or other unfair-dealing practice.
- Gifts and Entertainment: Avoid gifts and entertainment that might compromise, or appear to compromise, the ability of the recipient to make objective and fair business decisions or that could be viewed as an inducement to or reward for any particular business decision. Properly account for all gifts and entertainment expenses on expense reports. Any gift from a supplier to an Optoma employee or director must be permissible under our Code of Business Conduct and Ethics.
Labour Practices and Human Rights
Optoma pursues fair employment practices in every aspect of its business. All suppliers must conduct their employment practices in compliance with all applicable labour laws and regulations, and must, without limitation:
- Anti-Discrimination and Diversity: Cooperate with Optoma's commitment to provide equal opportunity and fair treatment to all individuals on the basis of merit, without discrimination because of race, colour, religion, national origin, sex (including pregnancy), sexual orientation, age, disability, veteran status or other characteristic protected by law. We encourage our suppliers to foster diversity within their work force and provide an inclusive and non-discriminatory working environment in which all employees are valued and empowered to succeed. We believe that diversity in our work force is a valuable asset that supports different ideas, perspectives, and beliefs.
- Anti-Harassment: Avoid harassment in any form, whether physical or verbal and whether committed by supervisors, non-supervisory personnel or non-employees. Harassment may include, but is not limited to, offensive sexual flirtations, unwanted sexual advances or propositions, verbal abuse, sexually or racially degrading words or the display in the workplace of sexually suggestive objects or pictures.
- Freedom of Association: Respect workers' rights to freedom of association and collective bargaining in accordance with applicable legal requirements. Suppliers may not discriminate with respect to employment based on union membership.
- Prevention of Underage Labour: Comply with all applicable minimum age laws or regulations and not use child labour. Suppliers may not employ anyone under the age of 15, the minimum age for employment in the applicable location or the age for completing compulsory education in that
location, whichever is higher. Children under the age of 18 are prohibited from doing work likely to jeopardize their health, safety or morals.
- Non-Retaliation: Prohibit retaliation against any supplier or Optoma employee who, in good faith, seeks help or reports known or suspected violations of this Code of Business Conduct and Ethics.
- Supplier Diversity: Proactively identify local and diverse suppliers who can support business operations effectively and promote strategic objectives with high quality goods and services, innovation, competitive pricing, reliability and customer focus. We desire to promote an environment that provides sourcing opportunities to a wide range of local and diverse business types because we believe these partnerships contribute to the development of the communities that host our properties.
- Voluntary Labour: Use only voluntary labour. The use of forced labour whether in the form of indentured labour, bonded labour or prison labour by suppliers is prohibited. Also prohibited is support for any form of human trafficking of involuntary labour through threat, force, fraudulent claims or other coercion. Workers must not be required to surrender any government-issued identification, passports or work permits, or to post any other deposits, as a condition of employment, and must be permitted to terminate their employment in accordance with applicable laws and regulations without unlawful penalty.
- Wages and Benefits: Pay all workers at least the minimum wage required by applicable laws and regulations and provide all legally mandated benefits. Wages and benefits paid for a standard work week must meet, at a minimum, all applicable standards, laws and regulations. Deductions from wages as a disciplinary measure (without the express, written permission of the worker) or as otherwise prohibited by applicable laws or regulations are not permitted.
- Working Hours: Restrict workdays to the maximum hours of daily labour set by local laws and regulations and ensure that overtime is voluntary and paid in accordance with applicable laws and regulations.
Health and Safety
Optoma is committed to maintaining a healthy and safe work environment. All suppliers are expected to integrate sound health and safety management practices into all aspects of their business, and must, without limitation:
- Alcohol and Drugs: Prohibit the use of alcoholic beverages, except at sanctioned events, and prohibit the possession, use, distribution or sale of illegal drugs and other controlled substances under all circumstances while on duty or on the premises of Optoma or any supplier.
- Violence and Weapons: Optoma will not tolerate violence or threats of violence in, or related to, the work environment. Optoma does not permit any individual to have firearms or weapons of any kind in Optoma’s property or vehicles, while on the job nor off-site while on Optoma’s business, except as otherwise permitted by law.
- Working Conditions: Provide a safe and healthy work environment and fully comply with all safety and health laws, regulations and practices including those applicable to the areas of occupational safety, emergency preparedness, occupational injury and illness, industrial hygiene, physically demanding work, machine safeguarding, sanitation, food and housing.
Optoma is committed to sustainability and the protection of the environment. Suppliers are encouraged to share our commitment by meeting or exceeding the requirements of applicable environmental laws and regulations and promoting sustainable business practices. At a minimum, our suppliers are expected to, without limitation:
- Environmental Permits Obtain, maintain and keep current all required environmental permits and registrations and follow the operational and reporting requirements of such permits.
- Hazardous Materials: Identify and manage substances that pose a threat to the environment if released.
- Resource Reduction: Endeavour to reduce or eliminate waste of all types, including water and energy, by implementing appropriate conservation measures in their facilities, through their maintenance and production processes and by recycling, re-using or substituting materials.
Protection and Use of the Assets
To ensure the protection and proper use of Optoma's assets, suppliers must, without limitation:
- Business Use: Use Optoma's telephone system, other electronic communication services, written materials and other property only for business-related purposes.
- Care: Exercise reasonable care to prevent, and report to Optoma the actual or suspected, theft, damage or misuse of Optoma’s property.
- Security: Safeguard all electronic programs, data, communications and written materials from unauthorized access by others.