{"issuer":{"name":"Acme Supplies SRL","legal_form":"Société à responsabilité limitée (SRL)","registration_number":"BE0123456789","address":"Rue de la Loi 100, 1040 Brussels, Belgium"},"applicable_to":"All Tier-1 suppliers of goods and services with annual spend of €25 000 or more with Acme Supplies SRL, and any Tier-2 sub-supplier identified as salient-risk under Acme's due-diligence assessment. By signing this Code the Supplier confirms that it will cascade equivalent obligations to its own sub-suppliers in line with art. 8 CSDDD (Dir. (EU) 2024/1760).","effective_date":"2026-01-01","version":"v2.0","commitments":[{"theme":"labour_rights","commitments":["Respect for the ILO Declaration on Fundamental Principles and Rights at Work (1998, amended 2022), including freedom of association and the effective recognition of the right to collective bargaining (ILO C87 and C98).","Elimination of all forms of forced or compulsory labour (ILO C29 and C105) and of child labour (ILO C138 and C182); no worker under the minimum age set by local law, and no hazardous work for workers under 18.","Elimination of discrimination in respect of employment and occupation (ILO C100 and C111) and of any form of harassment (ILO C190).","Payment of at least the applicable legal minimum wage or collective-agreement wage, whichever is higher; wages paid on time and in legal tender; overtime voluntary and paid at the legally required premium.","Working time within the limits of local law and the EU Working Time Directive 2003/88/EC where applicable; at least one rest day per seven-day period.","Written employment contract in a language the worker understands; no retention of identity documents; no recruitment fees charged to workers (Employer-Pays Principle)."]},{"theme":"health_safety","commitments":["Provide a safe and healthy working environment in line with ILO C155 and applicable EU OSH directives (notably Framework Dir. 89/391/EEC).","Conduct documented risk assessments for all work activities and implement proportionate prevention measures.","Provide appropriate personal protective equipment (PPE) at no cost to the worker.","Train every worker in emergency procedures and in the specific hazards of their role, with refresher training at least annually.","Report serious occupational accidents and near-misses to Acme within 48 hours when they affect workers producing goods or providing services to Acme."]},{"theme":"environment","commitments":["Comply with all applicable environmental permits and with REACH Reg. (EC) 1907/2006 obligations on substances of very high concern (SVHC); disclose SVHC content above 0.1% w/w in any article supplied.","Comply with RoHS Dir. 2011/65/EU for electrical and electronic equipment where in scope.","Track and reduce energy consumption and GHG emissions; report Scope 1 and Scope 2 emissions on request to support Acme's Scope 3 cat. 1 reporting under the GHG Protocol.","Apply the waste hierarchy of Dir. 2008/98/EC (prevention > reuse > recycling > recovery > disposal).","Do not source timber, paper, palm oil, soy, cocoa, coffee, cattle or rubber products that fall within the EU Deforestation Regulation (EU) 2023/1115 without a compliant due-diligence statement."]},{"theme":"ethics_anti_corruption","commitments":["Zero tolerance for bribery, corruption, extortion and embezzlement in any form, in line with the OECD Anti-Bribery Convention (1997) and applicable national law (BE: Law of 10 February 1999 on the punishment of corruption).","No facilitation payments. Gifts, hospitality and entertainment must be modest, infrequent and compliant with the Supplier's and Acme's policies.","Comply with EU and UN sanctions regimes and screen counterparties accordingly.","Avoid actual or perceived conflicts of interest and disclose any to Acme promptly.","Fair competition practices; no price-fixing, bid-rigging or market-sharing prohibited by art. 101 TFEU."]},{"theme":"data_protection","commitments":["When processing personal data on Acme's behalf, comply with the GDPR (Reg. (EU) 2016/679), sign Acme's Data Processing Agreement pursuant to art. 28 GDPR, and implement appropriate technical and organisational measures (art. 32 GDPR).","Notify Acme of any personal-data breach without undue delay and within 24 hours of awareness (tighter than the 72-hour controller-to-DPA deadline of art. 33 GDPR).","Do not transfer personal data outside the EEA without an adequacy decision or appropriate safeguards under art. 46 GDPR.","Honour data-subject rights requests forwarded by Acme within the applicable GDPR deadlines."]}],"prohibited_practices":["Any form of modern slavery, human trafficking, forced or bonded labour.","Child labour below the applicable minimum age or in hazardous conditions.","Retaliation against workers who raise concerns through the Supplier's or Acme's grievance channels.","Undeclared subcontracting of work covered by the Acme purchase order.","Misrepresentation of origin, composition, quality, sustainability certifications or CE/UKCA conformity of supplied goods."],"reporting_expectations":"The Supplier shall complete Acme's annual self-assessment questionnaire and provide, on request, documentary evidence (policies, audit reports, certifications such as ISO 14001, ISO 45001, SA8000, Sedex SMETA). Material changes in ownership, site location, sub-supplier panel or ESG performance shall be reported to Acme within 30 days.","audit_rights":"Acme, or an independent auditor mandated by Acme, may audit the Supplier's compliance with this Code with reasonable prior notice (typically 10 business days), including on-site inspections and worker interviews. For credible allegations of severe human-rights or environmental harm, audits may be unannounced. The Supplier shall grant equivalent audit rights to Acme over its own sub-suppliers.","remediation_process":"Where non-compliance is identified, the Supplier and Acme shall jointly agree a Corrective Action Plan (CAP) with time-bound milestones. Severe breaches (forced labour, child labour, grave safety failures, proven corruption) trigger immediate escalation, remediation at the Supplier's cost, and may result in suspension or termination of the commercial relationship, consistent with the 'cease-or-prevent' obligation of art. 10 CSDDD (Dir. (EU) 2024/1760). Acme operates a confidential grievance channel (ethics@acme-supplies.be) open to the Supplier's workers and third parties.","acknowledgement":{"supplier_name":"Delta Metalwork NV","signatory_name":"Marnik De Smet","signatory_role":"Managing Director, Delta Metalwork NV","date":"2025-12-11","place":"Antwerp"}}