{"issuer":{"name":"Acme Supplies SRL — Procurement & Compliance","date":"2026-01-15","version":"v3.0 (2026-01)"},"applicable_to":"This Code of Conduct applies to every supplier (including agents, sub-contractors, distributors and resellers) of Acme Supplies SRL ('Acme') worldwide, regardless of contract value or duration. It is incorporated by reference into every Acme purchase order and master supply agreement. Suppliers shall ensure equivalent commitments cascade to their own sub-tier suppliers.","themes":[{"theme":"labour_rights","commitments":["Comply with the ILO Declaration on Fundamental Principles and Rights at Work (1998, revised 2022): freedom of association and collective bargaining (ILO Conventions 87 and 98), elimination of forced labour (ILO Conventions 29 and 105 + 2014 Protocol), abolition of child labour (ILO Conventions 138 and 182), elimination of discrimination in employment (ILO Conventions 100 and 111) and a safe and healthy working environment (ILO Conventions 155 and 187).","Pay at least the legal minimum wage and a wage that meets local cost-of-living benchmarks; pay overtime at premium rates compliant with local law.","Limit working time in accordance with applicable national law and the ILO Hours of Work Convention 1, with one rest day in seven minimum.","No use of forced, bonded, prison or compulsory labour. No retention of identity documents or recruitment fees charged to workers (Employer Pays Principle, IOM 2014)."]},{"theme":"health_safety","commitments":["Provide a safe and hygienic workplace consistent with ILO Convention 155, ILO-OSH 2001 and locally applicable OHS law.","Identify, assess and control occupational hazards; provide free PPE; train workers on hazards and emergency procedures.","Investigate every serious incident, document root causes and share lessons learned within 30 days."]},{"theme":"environment","commitments":["Hold and comply with all required environmental permits and reporting obligations.","Measure and reduce greenhouse-gas emissions in line with the goals of the Paris Agreement; disclose Scope 1 and 2 to Acme on request and progressively Scope 3.","Comply with Reg. (EU) 2023/1115 on deforestation-free products for in-scope commodities (cattle, cocoa, coffee, oil palm, rubber, soya, wood and derived products).","Comply with Reg. (EC) No 1907/2006 (REACH), Directive 2011/65/EU (RoHS) and the EU Construction Products Regulation where applicable."]},{"theme":"ethics_anti_corruption","commitments":["Zero tolerance for bribery, kickbacks, facilitation payments or any form of corruption (UK Bribery Act 2010, US FCPA, OECD Anti-Bribery Convention 1997, French Sapin II law 2016).","No conflict of interest involving Acme staff without prior written disclosure.","Comply with applicable competition / antitrust law (Articles 101 and 102 TFEU).","Maintain accurate books and records; cooperate with Acme audits."]},{"theme":"data_protection","commitments":["Process personal data received from or on behalf of Acme strictly in line with Regulation (EU) 2016/679 (GDPR), in particular Article 5 (principles), Article 28 (processor obligations) and Articles 44–49 (international transfers).","Notify Acme of any personal-data breach without undue delay and within 24 hours of becoming aware (Acme contractual standard, stricter than GDPR Art. 33)."]},{"theme":"export_controls","commitments":["Comply with all applicable export-control regimes including Reg. (EU) 2021/821 on dual-use items, EU sanctions (Reg. (EU) 2580/2001, Reg. (EC) 881/2002, Reg. (EU) No 833/2014 and amendments), UN Security Council resolutions and US OFAC requirements.","Screen counterparties (customers, agents, sub-suppliers) against consolidated sanctions lists and maintain auditable evidence."]},{"theme":"conflict_minerals","commitments":["Source tin, tantalum, tungsten and gold (3TG) responsibly in line with Reg. (EU) 2017/821 and the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (3rd ed., 2016).","Provide Acme with the standard CMRT (Conflict Minerals Reporting Template) on request, with smelter-level traceability."]},{"theme":"animal_welfare","commitments":["Where animal-derived materials are used, comply with Council Regulation (EC) No 1099/2009 on the protection of animals at the time of killing and applicable national welfare legislation; preference for the Five Domains framework (Mellor 2017)."]}],"prohibited_practices":["Child labour below the age set by ILO Convention 138 (in any case below 15 years, or 14 in countries having availed themselves of the relevant exception).","Any form of forced or bonded labour, human trafficking or modern slavery.","Recruitment fees charged to workers and retention of identity documents.","Discrimination on the basis of sex, race, ethnicity, religion, age, disability, sexual orientation, gender identity, union membership or political opinion.","Physical punishment, harassment, intimidation or any other inhuman treatment.","Bribery, facilitation payments and kickbacks of any kind.","Any unlawful environmental discharge or unpermitted handling of hazardous substances.","Sourcing of 3TG minerals contributing to armed conflict in CAHRAs (Conflict-Affected and High-Risk Areas).","Sourcing of in-scope commodities under Reg. (EU) 2023/1115 from land deforested or degraded after 31 December 2020."],"reporting_mechanism":{"channel":"Acme Speak-Up — independent third-party operated whistleblowing channel run by EQS Integrity Line GmbH, available 24/7 in 23 languages including FR, NL, EN, DE, IT, ES, PL and PT, accessible at https://acmesupplies.integrityline.com.","email":"speakup@acmesupplies.be","phone":"+32 800 26 555 (toll-free in BE) — local numbers per https://acmesupplies.integrityline.com/contact","anonymous_option":true},"audit_rights":"Acme (or an independent third party mandated by Acme) is entitled to audit the supplier's compliance with this Code on reasonable prior notice (30 days for routine audits; without notice in case of credible suspicion of breach). Audits cover document review, site visits and confidential worker interviews. The supplier shall grant Acme equivalent rights at sub-tier suppliers in cascade.","sanctions_for_breach":"Any breach of this Code is a material breach of the underlying purchase order or master supply agreement. Depending on severity and the supplier's response, Acme may require a corrective-action plan, suspend orders, terminate the contractual relationship in whole or in part, claim damages and report serious matters to competent authorities. Retaliation against any person raising a good-faith concern is itself a material breach.","signatory_block":{"supplier_name":"Heinrich Fasteners GmbH","signatory_name":"Klaus Heinrich","title":"Geschäftsführer","date":"2026-04-10"}}