Supplier Code of Conduct

1. Who this applies to

This Code applies to every supplier, subcontractor and service provider of Innovation Group DBA Innovation Fasteners LLC (“Innovation Fasteners”), including mills, distributors, heat treaters, platers and coaters, testing laboratories, machine shops, carriers and their own suppliers and subcontractors who work on Innovation Fasteners orders (together, “Suppliers”).

Our customers build refineries, power plants, pipelines and critical equipment. They rely on us, and we rely on our Suppliers, to deliver material that is exactly what its paperwork says it is, made by people who are treated lawfully and fairly. This Code sets the minimum standard. Where a purchase order or contract sets a higher standard, the higher standard applies. This Code does not replace the terms of our purchase orders and does not create rights for anyone other than Innovation Fasteners.

2. Compliance with laws

Suppliers must comply with all laws and regulations that apply to their business and to the goods and services they provide to Innovation Fasteners, in every country where they operate.

3. Quality, traceability and genuine material

Quality and traceability are the foundation of what we sell. Suppliers must:

• Supply material and services that conform to the purchase order, the specification and revision it references, and the applicable ASTM, ASME, API or other standards.
• Provide accurate material test reports and certifications, traceable to the melt source and heat number, and never alter, falsify or reissue a certificate for material it does not cover.
• Never supply counterfeit, suspect or misrepresented material, and tell us immediately if they discover that anything they supplied may be nonconforming or counterfeit.
• Tell us in writing before changing the material source, mill, manufacturing process, subcontractor or facility used for our orders.
• Retain quality and traceability records for at least ten (10) years, or longer where the purchase order requires, and make them available to us on request.
• Allow us, and our customers where required, to inspect product and processes at reasonable times.

4. Anti-bribery, gifts and conflicts of interest

Suppliers must not offer, pay, promise, request or accept bribes, kickbacks or any improper payment or benefit to win or keep business, in dealings with Innovation Fasteners, our customers or any government official. This includes compliance with the U.S. Foreign Corrupt Practices Act and similar laws.

Gifts and hospitality must be modest, infrequent and never in cash or cash equivalents, and must never be given to influence a purchasing decision. Suppliers must disclose to us any financial or family relationship with an Innovation Fasteners employee that could create a conflict of interest.

5. Trade compliance, sanctions and country of origin

Suppliers must comply with U.S. sanctions administered by the Office of Foreign Assets Control, the Export Administration Regulations and, where applicable, the International Traffic in Arms Regulations. Suppliers must not source material from, or route shipments through, sanctioned countries or restricted parties.

Country of origin, domestic content and specialty metals statements must be accurate. Where our purchase order flows down Buy American, DFARS specialty metals or similar requirements, Suppliers must meet them and certify compliance.

6. Forced labor, child labor and human trafficking

Suppliers must not use forced, bonded, indentured, prison or trafficked labor, or child labor, anywhere in their operations or supply chains. In particular:

• No worker may be younger than 15, or younger than the minimum working age under local law if higher, and no worker under 18 may do hazardous work.
• Workers must be free to leave their employment on reasonable notice, and must not be required to surrender identity documents or pay recruitment fees.
• Suppliers must comply with the Uyghur Forced Labor Prevention Act and must not supply goods made wholly or partly in the Xinjiang region of China, or by entities on the UFLPA Entity List.

7. Fair treatment of workers

Suppliers must pay at least the legally required minimum wage and overtime, keep working hours within legal limits, and give workers clear records of their pay. They must not discriminate in hiring, pay, promotion or dismissal on the basis of race, color, religion, sex, pregnancy, sexual orientation, gender identity, national origin, age, disability, veteran status or any other characteristic protected by law, and must not tolerate harassment or abuse. Suppliers must respect workers’ lawful right to join, or not to join, labor organizations.

8. Health and safety

Suppliers must provide a safe and healthy workplace that meets the Occupational Safety and Health Act or the equivalent law where they operate, including suitable guarding, personal protective equipment, hazard communication, training and emergency preparedness. Anyone working at our facility must follow our site safety rules.

9. Environment and materials disclosure

Suppliers must hold the environmental permits their operations require and comply with laws on air emissions, wastewater, waste and hazardous materials. On request, Suppliers must provide accurate information about regulated substances in what they supply, including RoHS, REACH and PFAS content, and safety data sheets for coatings, platings and chemicals.

10. Conflict minerals

Suppliers must exercise reasonable due diligence on the source of any tin, tantalum, tungsten and gold (3TG) in the products they supply, and must not knowingly supply material that finances armed groups in the Democratic Republic of the Congo or adjoining countries. On request, Suppliers must complete a Conflict Minerals Reporting Template (CMRT).

11. Confidential information

Suppliers must protect the drawings, specifications, pricing and other non-public information we or our customers share with them, use it only to fulfil our orders, and return or destroy it when asked. Customer drawings must not be used to quote or sell to anyone else.

12. Subcontractors and sub-tier suppliers

Suppliers must not subcontract work on our orders without our approval where the purchase order requires it, and must flow down the requirements of this Code, and of our purchase order, to any subcontractor or sub-tier supplier that works on our material. Suppliers remain responsible for work their subcontractors perform.

13. Our responsible-sourcing commitment

Innovation Fasteners holds itself to the same standards it asks of its Suppliers. We do not use forced, bonded or child labor. We verify each employee’s identity and right to work in the United States, pay at least the legal minimum wage and overtime, and give employees a way to raise concerns without fear of retaliation.

We buy material from mills and distributors that provide traceable certification, review new Suppliers before approving them under our ISO 9001:2015 quality management system, and reserve the right to stop buying from any Supplier that does not meet this Code. We review this Code and our sourcing practices at least once a year.

14. Reporting concerns

Suppliers and their workers can report a suspected breach of this Code, by a Supplier or by anyone at Innovation Fasteners, to info@innovationfasteners.com or by phone at 832-446-3442. We will treat reports confidentially to the extent the law allows and will not retaliate against anyone who raises a concern in good faith.

15. Audits, corrective action and termination

We may ask Suppliers to confirm compliance with this Code in writing, complete questionnaires, or allow audits of relevant records and facilities on reasonable notice. Where we find a breach, we will normally ask the Supplier to agree and complete a corrective action plan within an agreed time. Serious breaches, or a failure to correct a breach, may lead us to suspend orders or end the relationship, in addition to any other remedy under our purchase orders.

16. Supplier acknowledgement

By accepting an Innovation Fasteners purchase order, a Supplier agrees to comply with this Code. Suppliers asked for a signed acknowledgement can print this page, complete the details below, and return it to info@innovationfasteners.com.