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THE SPIRIT & THE LETTER INTEGRITY GUIDE FOR SUPPLIERS, CONTRACTORS & CONSULTANTS This GE HealthCare Code of Conduct for Suppliers also applies to Consortium Partners
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DocumentDocumentTHE SPIRIT & THE LETTER
INTEGRITY GUIDE FOR SUPPLIERS, CONTRACTORS & CONSULTANTS
This GE HealthCare Code of Conduct for Suppliers also applies to Consortium Partners
A Message from GEHC
GE HealthCare ("GEHC") is committed to unyielding integrity and high standards of business conduct in everything we do, especially in our dealings with GEHC suppliers, contractors, consortium partners and consultants (collectively "Suppliers"). GEHC bases its Supplier relationships on lawful, efficient and fair practices, and Suppliers must adhere to applicable legal and regulatory requirements in their business relationships as set out in this Integrity Guide for Suppliers, Contractors and Consultants (the "Guide") in connection with their activities for GEHC.
In addition, GEHC prides itself on embracing diversity among our Suppliers because we recognize the wealth of perspectives, experiences, and innovation it brings to our company. We actively work to expand our network of potential Suppliers to enrich our supply chain with fresh ideas and approaches that can drive greater innovation and competitiveness in our products and services. As a partner of GEHC, we expect our Suppliers to share in this mission.
Suppliers are responsible for ensuring that they and their employees, workers, representatives, suppliers and subcontractors comply with the standards of conduct set out in this Guide and in other contractual obligations to GEHC. Please contact the GEHC manager you work with or any GEHC Compliance Resource if you have any questions about this Guide or the standards of business conduct that all GEHC Suppliers must meet.
Responsibilities of GEHC Suppliers
You, as a Supplier to GEHC, agree:
Respectful Workplace: To (i) observe applicable laws and regulations governing wages, hours, overtime, recruitment and employment contracts; (ii) allow workers to choose freely whether to organize or join associations of their own choosing for the purpose of collective bargaining as provided by local law or regulation; (iii) prohibit discrimination1, harassment and retaliation; and (iv) treat all workers fairly and with respect.
Environment, Health and Safety: To (i) comply with applicable environmental, health and safety (EHS) laws and regulations and GEHC's contractor EHS requirements; (ii) provide workers a safe and healthy workplace; and (iii) ensure that you are not adversely affecting the local community. If housing is provided or arranged, it must meet host country safety standards.
Environmental Sustainability: In addition to the above statements, to (i) comply with applicable laws, regulations and standards, including but not limited to those applicable to subcomponents, raw material and packaging; (ii) undertake all reasonable measures to minimize its impact to the environment, including, but not limited to, reducing waste & pollution, including through circularity, conserving natural resources, promoting biodiversity, such as wood and water (but not only), improving energy efficiency, and promoting sustainable practices within its operations and organization. As a partner in the decarbonization of our supply chain, we ask our suppliers to undertake efforts to set a carbon reduction target in line with the latest science, be transparent about their environmental performance and
1 GEHC prohibits discrimination based on any protected characteristics, which include: race, color, religion, national or ethnic origin, ancestry, sex (including pregnancy and related conditions), gender (including gender identity and expression), sexual orientation, marital status, genetic information, age, disability, military and veteran status or any other characteristic protected by law.
Update April 2024
THE SPIRIT & THE LETTER
INTEGRITY GUIDE FOR SUPPLIERS, CONTRACTORS & CONSULTANTS
This GE HealthCare Code of Conduct for Suppliers also applies to Consortium Partners
disclose their carbon emissions (we encourage our suppliers to disclose their progress against their target through the Carbon Disclosure Project (CDP) and to GEHC through its supplier Ecovadis).
Forced Labor: To respect human rights of your employees and others in your business operations and activities for GEHC, which includes the following: (i) prohibiting the use of forced labor, including prison or indentured labor, and ensuring workers are not subject to any form of physical, sexual or psychological compulsion, exploitation, violence, coercion or inhumane treatment, or other forms of human trafficking; (ii) ensuring that a worker's identity or immigration documents are not withheld or destroyed; (iii) allowing workers to terminate their employment, for any reason, with reasonable notice; (iv) ensuring that recruitment fees of any type are not deducted from workers' pay or otherwise charged to workers; (v) prohibiting the use of fraudulent or misleading recruitment practices; (vi) ensuring that, upon end of employment, workers are reimbursed for their return transportation costs (for workers recruited from outside the country); and (vii) providing workers with terms and conditions of employment in a language the worker understands.
Child Labor and Young Workers: To (i) prohibit the employment of workers under sixteen (16) years of age (or local legal age if higher); and (ii) prohibit the employment of workers under eighteen (18) years of age (or local legal age if higher) for hazardous work.
Responsible Mineral Sourcing: To (i) adopt policies and establish systems to procure tantalum, tin, tungsten, gold and other rare earth minerals from sources that do not directly or indirectly finance armed groups in the Democratic Republic of the Congo or Conflict Affected High Risk Areas; and (ii) provide supporting data on your supply chain for tantalum, tin, tungsten, gold, or other requested rare earth minerals to GEHC when requested, on a platform to be designated by GEHC.
Working with Governments, Improper Payments and Dealings with GEHC Employees and Representatives: To maintain and enforce (i) a policy requiring adherence to lawful business practices, including a prohibition against bribery; (ii) a prohibition against offering or providing, directly or indirectly, anything of value that would constitute a bribe or a kickback, including but not limited to cash, gifts, entertainment, offers of employment, or other types of benefit, to any GEHC employee, GEHC representative, GEHC customer or to any government official in connection with any GEHC procurement, transaction or business dealing; and (iii) to agree to provide supporting data to GEHC when requested.
Competition Law: Not to share or exchange any price, cost or other competitive information or engage in any collusive conduct with any third party with respect to any proposed, pending or current GEHC procurement.
Intellectual Property: To respect the intellectual property rights of GEHC and of third parties, including all patents, trademarks, copyrights and trade secrets.
Security and Privacy: To (i) respect individual privacy rights by collecting, handling and protecting GEHC Personal Information responsibly and compliantly; (ii) implement and maintain appropriate physical, administrative and technical controls that meet GEHC standards and are designed to ensure the security and confidentiality of GEHC Confidential Information2 in order to prevent the unauthorized or unlawful destruction, alteration, modification or accidental loss of GEHC Confidential Information; and (iii) protect Supplier operations and facilities against exploitation by criminal or terrorist individuals and organizations.
2 GEHC Confidential Information is information created or collected by GEHC that would pose a risk of causing harm to GEHC if disclosed to or used improperly and includes but is not limited to GEHC Highly Confidential Information and Personal Information.
Update April 2024
THE SPIRIT & THE LETTER
INTEGRITY GUIDE FOR SUPPLIERS, CONTRACTORS & CONSULTANTS
This GE HealthCare Code of Conduct for Suppliers also applies to Consortium Partners
Trade Controls and Customs Matters: Not to transfer GEHC technical information to any third party without the express, written permission of GEHC, and to comply with all applicable trade control laws and regulations in the import, export, re- export or transfer of goods, services, software, technology or technical data including any restrictions on access or use by unauthorized persons or entities. Controllership and Tax Law: To ensure that all invoices and any customs or similar documentation submitted to GEHC or governmental authorities or audited by third parties in connection with transactions involving GEHC accurately describe the goods and services provided or delivered and the price thereof, to ensure that all documents, communications and accounting are accurate and honest and not to take or participate in any actions that may be viewed as tax evasion or the facilitation of tax evasion. Conflicts of Interest: Avoid all conflicts of interest or situations giving the appearance of a potential conflict of interest. A relevant conflict of interest typically occurs when personal interests interfere with or appear to interfere with Supplier's ability to perform the work/services without bias. Suppliers are expected to notify GEHC if an actual or potential conflict of interest arises. This includes any situations of potential or apparent conflicts between Suppliers' or their employees' personal interests and the interests of GEHC. Flow down: To ensure that your employees, workers, representatives, suppliers and subcontractors comply with the standards of conduct set out in this Guide and in other contractual obligations to GEHC.
Get Help How to Raise a Question or Concern
Subject to local laws and any legal restrictions applicable to such reporting, each GEHC Supplier is expected to inform GEHC promptly of any concern related to this Guide affecting GEHC, whether or not the concern involves the Supplier, as soon as the Supplier has knowledge of such an occurrence. GEHC Suppliers also must take such steps as GEHC may reasonably request to assist GEHC in the investigation of any such occurrence involving GEHC and the Supplier. If Supplier's work is related to a U.S. government contract, Supplier must notify GEHC of any alleged non-conformance with this Supplier Integrity Guide. Prompt reporting is crucial -- a question or concern may be raised by a GEHC Supplier as follows:
· By discussing with a GEHC Manager; OR
· By calling the GEHC Integrity Helpline: +1 833-248-6821 OR
· By emailing GEHealthCare.Ombuds@gehealthcare.com OR
· By contacting any Compliance Resource (e.g., GEHC legal counsel or auditor).
Note: Suppliers do not need to be certain that a violation has occurred, but rather should raise a concern when there is a good faith belief that something improper, a violation of law or policy, has occurred. GEHC fully examines every integrity concern raised and takes necessary remedial actions where appropriate. GEHC forbids retaliation against any person reporting such a concern.
Update April 2024