Our Supplier Code of Conduct

Supplier Code of Conduct


Audia Plastics Holdings, Inc. and its subsidiaries ( collectively, the "Company") are committed to the principles-of corporate integrity,responsible product sourcing, ethical business practices, protection of environment and regulatory compliance. To these ends, the Company expects its vendors and suppliers to comply, at a minimum, with all applicable labor, employment, health and safety, and environmental laws and regulations of the countries in which they operate. This Supplier Code of Conduct (the "Code of Conduct") establishes the minimum standards that must be met by any supplier that that sells goods to, provides services to, or otherwise does business with the Company. This Code of Conduct is in addition to, and not in lieu of, any other Company policies that apply to Suppliers and may be amended by the Company from time to time, and such amendments will be communicated to Suppliers.


This Code of Conduct applies to all vendors and suppliers and their officers, employees, agents and subcontractors ( collectively referred to herein as "Suppliers") while conducting business with or on behalf of the Company. This Policy applies to (and has been adopted by) the Company and each of its foreign and domestic subsidiary companies, including but not limited to Washington Penn Plastic Co., Inc., Uniform Color Company, Southern Polymer, Inc. and Audia USA LLC.

Suppliers shall contractually require all downstream suppliers and/or subcontractors to conform to standards of conduct equivalent to the provisions of this Code of Conduct. The Company reserves the right to audit a Supplier's downstream suppliers and/or subcontractors for compliance with this Code of Conduct and Suppliers shall accommodate the Company's audits as reasonably requested.




A.     Audia's Code of Ethics.

The Company's Code of Ethics (a copy of which is available for review upon request) establishes the standards of conduct with which all Company employees are expected to comply and is guided by the following fundamental tenets:

These standards of conduct apply to all Company employees, directors and officers. Similarly, the Company expects all Suppliers to embrace this commitment to integrity by complying with and training their employees on this Code of Conduct.  

B. Zero Tolerance for Corruption and Bribery.

Suppliers shall not participate in bribes or kickbacks of any kind, whether in dealings with public officials or individuals in the private sector. The Company is committed to observing the standards of conduct set forth in the U.S. Foreign Corrupt Practices Act ("FCPA") and the anti-corruption laws and best practices of the countries in which the Company operates. Suppliers must comply with all applicable anti­ corruption and anti-money laundering laws, including, without limitation, the FCPA, as well as laws governing lobbying, gifts, and payments to public officials, political campaign contribution laws, and other related regulations. Suppliers must not, directly or indirectly, offer or pay anything of value (including travel, gifts, hospitality expenses, and charitable donations) to any official or employee of any government, government agency, political party, public international organization, any candidate for political office or any person employed privately to (i) improperly influence any act or decision of the individual for the purpose of promoting the business interests of the Company in any respect, or (ii) otherwise improperly promote the business interests of the Company in any respect. A Supplier will maintain complete and accurate records of all payments received from the Company and made by or on behalf of the Company. Suppliers are expected to fully comply with the Company's Anti-Corruption Policy, a copy of which is available upon request.  

C. Regulatory Compliance.

Suppliers are expected to conduct their business activities in full compliance with all applicable laws, rules and regulations. Without limiting the generality of the foregoing, Suppliers must comply with the following while providing goods or services to the Company:

International Trade Laws. Suppliers must comply with all applicable trade controls, as well as·all applicable export, re-export, and import laws and regulations.    

Antitrust and Competition Laws. Suppliers are expected to conduct business in full compliance with antitrust and fair competition laws that govern the jurisdictions in which they operate.

D. Business Practices and Ethics.

Suppliers are expected to conduct their business in an ethical manner and to act with integrity.  

Conflicts of Interest. Suppliers must not engage in activities that create, or even appear to create, conflict between the Supplier's interests and the interests of the Company. Suppliers shall not provide gifts or anything of value to an officer, employee, agent or co-worker of the Company other than gifts of nominal value, customary in the country where the Company operates and proportionate to the occasion. The provision of any and all such gifts must be in line with each supplier's internal policies and the supplier must at all times evidence that by written records upon Company's request.  

Business Records. Suppliers are expected to: (a) honestly and accurately record and report all business information and comply with all applicable laws regarding their completion and accuracy; (b) create, retain, and dispose of business records in full compliance with all applicable legal and regulatory requirements; and (c) be honest, direct, and truthful in discussions with regulatory agency representatives and government officials.  

Conflict Minerals. Suppliers are expected to ensure that products supplied to the Company do not contain metals derived from minerals or their derivatives originated from conflict regions that directly or indirectly finance or benefit armed groups.  

E. Labor Practices and Human Rights.

Suppliers are expected to display a commitment to the human rights of their employees and to treat them with dignity and respect. 

Involuntary Labor. All labor must be voluntary. Suppliers shall not support or engage in slavery, forced or compulsory labor or human trafficking, and shall also forbid bonded, indentured or prison labor at any point along the supply chain. Suppliers are expected to implement and maintain a reliable system to verify the eligibility of all workers, including age eligibility and legal status of foreign workers.  

Child Labor. Suppliers must comply with all local and national minimum working age laws or regulations and not use child labor. Suppliers cannot employ anyone under the age of 15, under the age for completing compulsory education, or under the legal minimum working age for employment­ whichever is higher. The Company only supports the development of legitimate workplace apprenticeship programs for the educational benefit of young people and will not do business with those who abuse such systems. Workers under the age of 18 cannot perform hazardous work and may be restricted from night work, with consideration given to educational needs.  

Work Hours, Wages and Benefits. Suppliers shall comply with all applicable laws and regulations governing the hours of work and rest and compensation and benefits for all those in their employ in all countries of operation. Working hours for suppliers' employees will not exceed the maximum set by the applicable local and national law. Compensation paid to employees will comply with applicable national wage laws and ensure an adequate standard of living. Unless otherwise provided by local laws, deductions from basic wages as a disciplinary measure will not be permitted (this does not exclude the entitlement of damages on a contractual or legal basis). Suppliers are expected to provide their employees with fair compensation and benefits. Among other things, compensation and benefits should aim at providing an adequate standard of living for employees and their families. Suppliers' employees will be paid in a timely manner. It is recommended that suppliers offer their employees ample training and educational opportunities.

No Discrimination, Abuse or Harassment. Suppliers are expected to embrace the principles of diversity, inclusion and equal opportunity. Supplier shall not discriminate in hiring, compensation, training, advancement or promotion, termination, retirement, or any other employment practice (and shall not tolerate discriminatory treatment of any employee) based on race, color, national origin, gender, gender identity, sexual orientation, military status, religion, age, marital or pregnancy status, disability, or any other characteristic other than the worker's ability to perform the job. Supplier shall treat workers with respect and dignity. Supplier shall not subject workers to corporal punishment, or physical, verbal, sexual, or psychological abuse or harassment. Supplier must not condone or tolerate such behavior by its employees, agents or subcontractors.  

Freedom of Association. Suppliers shall respect, and shall not interfere with, the right of workers to decide whether to lawfully associate with groups of their choice, including the right to form or join trade unions and to engage in collective bargaining. Without limiting the foregoing obligations, Suppliers shall not: (a) take any action to prevent or suppress the workers' exercise of freedom of association or collective bargaining rights; (b) discriminate or retal_iate against, or discipline or punish, any worker who supports or exercises freedom of association or collective bargaining rights; (c) discriminate or retaliate against, or discipline or punish, any worker who raises collective bargaining compliance issues; or (d) discriminate or retaliate against, or discipline or punish, any worker based on union membership or the worker's decision to join or not join a union.

F. Health and Safety.

Suppliers are expected to provide a safe and healthy working environment for their employees. Suppliers shall implement procedures and safeguards to prevent workplace hazards, and work-related accidents and injuries, including procedures and safeguards to prevent industry-specific workplace hazards, and work-related accidents and injuries, that are not specifically addressed in this Policy. Suppliers must fully comply with all applicable 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. Adequate steps must be taken to minimize the causes of hazards inherent in the working environment.  

G. Product Safety.

A Supplier must meet or exceed standards for product safety applicable in its industry, including those established by applicable regulators and consumer standards associations. The safety of products provided by a Supplier must also be protected by adequate security measures at all stages of production, packaging, storage and distribution in order to prevent tampering or contamination. A Supplier is expected to have in place proper procedures to identify potentially harmful products arid complete an appropriate product recall, whether voluntary or mandated, in accordance with applicable laws and industry practices. Such procedures should ensure clear and prompt communication regarding such products to the Company and the immediate removal of potentially harmful products.  

H. Facilities.

Supplier shall ensure that all Facilities meet all applicable building codes and industry design and construction standards; obtain and maintain all construction approvals required by law; and obtain and maintain all zoning and use permits required by law. Suppliers shall also ensure that all Facilities have an adequate evacuation plan; adequate, well-lit (including emergency lighting), clearly marked, and unobstructed emergency exit routes, including exit doors, aisles, and fire-rated enclosed stairwells; a sufficient number of emergency exit doors, which are located on all sides of each building, are unlocked from the inside, and are readily opened from the occupied side and swing in the direction of emergency travel; visible and accurate evacuation maps posted in the local language, and including a "you are here" mark; adequate ventilation and air circulation; adequate lighting; adequate first aid kits and stations; adequate fire safety, prevention, alarm, and suppression systems; adequate access to potable water; and adequate access to private toilet facilities.  

I. Environmental Regulations and Protection.

Suppliers are expected to comply with all applicable environmental laws and regulations in all countries of operation. Specifically, Suppliers shall operate their facilities in compliance with all environmental laws, including laws and international treaties relating to waste disposal, emissions, discharges, and hazardous and toxic material handling. Suppliers must also ensure that the goods they manufacture comply with all environmental laws and treaties. The Company also expects Suppliers to adopt plans to monitor and improve their impacts on the environment on an ongoing basis.

J. Protection of Assets and Intellectual Property.

Suppliers must protect and responsibly use any of the Company's tangible and intangible assets in their possession. The Company considers its confidential information and intellectual property to be valuable assets and protects them accordingly. Any non-public information that the Company shares with Suppliers must be protected by the Suppliers through appropriate and reasonable safeguards and, where applicable, legally enforceable confidentiality agreements. Suppliers must not make any unauthorized disclosures of trade secrets or confidential information belonging to the Company, its customers or its other vendors/suppliers. When sharing Company information with others such as subcontractors or sub-suppliers, Suppliers must ensure that appropriate controls are in place to protect the Company's interests. Under no circumstance will a Supplier use such tangible and intangible assets for any illicit purpose or in any manner that would adversely affect the interests or reputation of the Company.  


Suppliers shall allow the Company and/or any of its representatives or agents access to their facilities and-all relevant records associated with the products and services provided to the Company. In each such case, the relevant Supplier and the Company shall establish a mutually agreeable date and time for access. However, risks to the Company's business may require immediate access to the products, services and associated records and Suppliers shall accommodate the Company's reasonable access as required. Suppliers also agree to cooperate with the Company to investigate any allegations of wrongdoing, misconduct or corruption.  


Suppliers shall self-report any violations of this Code of Conduct and implement a corrective action plan to cure all non-compliance within a specified time period (furnished to the Company in writing). The Company reserves the right to terminate the business relationship, including but not limited to suspending placement of future orders and potentially terminating current production. The Company reserves the right to hold Suppliers responsible for reasonable costs of investigating non-compliance.  

Suppliers can submit questions and comments regarding the Code of Conduct, or report any suspected violations thereof, to the Company's Legal Department by mail or e-mail as follows:  


Legal Department

Audia International, Inc.

480 Johnson Road

Washington, PA 15301



Suppliers shall not retaliate or take disciplinary action against any worker who has, in good faith, reported violations or questionable behavior, or who has sought advice regarding this Code of Conduct.