Diamond Vogel, Inc. Business Partner Code of Conduct

Updated: October 24, 2023

Acceptance of Purchase Order Terms & Conditions is also an acceptance of the Diamond Vogel Business Partner Code of Conduct.

For Diamond Vogel’s suppliers, joint venture partners, toll manufacturers, distributors, agents, consultants, and other business partners, the following seven tenets form Diamond Vogel's core values establish our expectations for our business partners:

Continuous improvement is an on-going effort to improve products, services, processes, and relationships.
Entrepreneurism is a mindset of innovation, risk-taking, responsibility, and accountability.
Relationships are mutually beneficial long-term interactions with others that are built on trust and loyalty.
Stewardship is the careful and responsible management of the talents and resources entrusted to us.
Integrity means being honest, ethical, and following through on the commitments we make. It is doing the right thing even when no one else is looking.
Quality means delivering products, solutions, and services that meet or exceed the customer’s needs and expectations. This relates to both internal and external customers.
Common sense is the ability to think and behave in a reasonable way, resulting in good decisions.The Diamond Vogel Business Partner Code of Conduct is aligned with the UN Global Compact’s ten Fundamental principles within the areas of human rights, labor rights, environment, and anticorruption. Our business partners, if they have not already done so, are expected to work towards implementing these standards within their own business and require the same from their business partners.

The Diamond Vogel Business Partner Code of Conduct is aligned with the UN Global Compact’s ten Fundamental principles within the areas of human rights, labor rights, environment, and anticorruption. Our business partners, if they have not already done so, are expected to work towards implementing these standards within their own business and require the same from their business partners.

Compliance with Laws, Rules, and Regulations

Diamond Vogel’s commitment to our core values begins with our efforts to ensure compliance with all applicable laws, rules, and regulations where we do business from wage and hour laws to health and safety codes to environmental regulations. If local laws, regulations, or standards are stricter than the principles and requirements set out in the Diamond Vogel Business Partner Code of Conduct, our business partners operating in such jurisdictions are expected to adhere to such stricter requirements.

In addition to adherence to the principles set out in this document, we expect our business partners to respect and comply with all applicable laws and regulations and prevailing industry standards. In the event of a conflict between such applicable laws, regulations, and standards and the Diamond Vogel Business Partner Code of Conduct, we expect the business partner to inform Diamond Vogel so we can work together to decide an appropriate joint approach to the issue.

Anti-Corruption

Diamond Vogel expects the conduct of its business partners to represent our core values. Parties should not engage (directly or indirectly) in unethical activities with public or private parties such as offering bribes, kickbacks, or other improper payments for the purpose of gaining favorable treatment. This includes compliance with the U.S. Foreign Corrupt Practices Act.

Gifts, Gratuities, and Business Courtesies

Diamond Vogel is committed to honest and transparent business dealings. Any business courtesies to Diamond Vogel employees and their close relatives must be reasonable in their scope, value, and frequency. Business courtesies include cash or equivalent, gifts, gratuities, gift cards, or other benefits from persons or companies with whom Diamond Vogel does or may do business. We seek to avoid giving or accepting business courtesies that constitute or could reasonably be perceived as constituting unfair business inducements or bribes that would violate law, regulation, or polices of Diamond Vogel, or would cause embarrassment or reflect negatively on Diamond Vogel’s reputation. If there are any questions regarding business courtesies, please contact the Diamond Vogel Compliance Officer.

Conflict of Interest

Diamond Vogel discourages employees, suppliers, and business partners from engaging in business transactions that create a conflict of interest or that give the appearance of a conflict of interest. Employees, suppliers, and business partners should disclose any potential conflict of interest to the Diamond Vogel Compliance Officer.

Charitable Contribution and Sponsorship

At Diamond Vogel, we actively avoid supporting political organizations and we never use charitable or commercial sponsorship to improperly influence decision makers. In a similar manner, we expect our business partners to avoid giving political support, making charitable donations, or offering sponsorship to gain an unfair advantage or influence decision making in connection with any Diamond Vogel transaction.

Non-Discrimination and Harassment

Diamond Vogel is an equal opportunity employer. It is Diamond Vogel’s policy to attract and retain the best qualified people available and to comply with applicable federal, state, and local law. Our nondiscrimination policy applies to applicants as well as employees and covers all terms and conditions of employment including recruiting, hiring, transfers, promotions, terminations, compensation, and benefits. Discrimination or harassment is prohibited, as is retaliation against a person who has made a complaint or given information regarding possible violations of this policy.

Slavery, Human Trafficking, Forced Labor, and Slave Labor

Diamond Vogel values the human rights of all people, including our employees, our business partners, and their employees, and therefore will not tolerate slavery, human trafficking, forced labor, or child labor in our supply chain. We are committed to complying with applicable laws prohibiting such exploitation and expect our business partners to do the same. We believe that the employment relationship should be voluntary, and the terms of employment must comply with applicable laws and regulations.

Health and Safety

Diamond Vogel is committed to providing employees with a safe and healthy workplace and we expect nothing less from our business partners. Our business partners must follow applicable safety rules and regulations, provide a safe and healthy work environment, and strive to promote an accident-free workplace.

When business partners are using dangerous goods, the business partner shall ensure that all risks are safely controlled and managed. Specifically:

Safe work procedures specific to the handling of dangerous goods and hazardous substances are available in the workplace and implemented.
Safety information, including Safety Data Sheets, is readily available.
Appropriate training and Personal Protective Equipment are provided for employees who may be exposed to dangerous goods and hazardous substances.

Books and Record Keeping

It is essential for Diamond Vogel to maintain accurate and complete books and accounting records. Our business partners must comply with all relevant laws, regulations, and reporting & accounting guidelines with respect to their business at all times.

International Sanctions and Export Control

Diamond Vogel complies with applicable International Sanctions and Export Control restrictions, including those imposed or introduced from time to time by the United States of America or the European Union and adopts appropriate measures to implement such compliance in practice. Our business partners must also observe and adhere to the relevant applicable International Sanctions and Export Control restrictions.

Anti-Money Laundering

Diamond Vogel does not engage in or accept any involvement with money laundering. Our business partners must have proper internal control systems in place to monitor their business for any indications of money laundering activities and thereby minimize the risk of being involved in such practices.

Environment

Diamond Vogel develops, manufactures, distributes, and sells our products in a way that promotes sustainability, preserves resources, prevents pollution, and reduces the environmental impact from our activities. The company uses natural resources including energy and raw materials in an economical way. The company works to ensure the safe handling, movement, storage, recycling, reuse, and management of waste, air emissions, and wastewater discharges. Diamond Vogel is committed to protecting the environment wherever we conduct business and strives for excellence in environmental stewardship.

Conflict Minerals

Diamond Vogel generally avoids the use of raw materials sourced from conflict minerals.

Confidential and Proprietary Information

Integral to Diamond Vogel’s business success is our protection of confidential company information, as well as nonpublic information entrusted to us by employees, customers, and other business partners. Confidential and proprietary information includes such things as pricing and financial data, customer names and addresses, or nonpublic information about other companies, including current or potential suppliers and vendors. Diamond Vogel employees, suppliers, and business partners are expected to honor all agreements protecting confidential information between the employee and Diamond Vogel and between Diamond Vogel and any other party for the duration of the agreements, both during the period of employment with Diamond Vogel and after such employment has terminated. We will not disclose confidential and nonpublic information without a valid business purpose and proper authorization.

Reporting of Concerns

Business partners are encouraged to provide means for their employees to report concerns or potentially unlawful activities in the workplace to their management, to treat such reports in a confidential manner, and to take corrective action if needed. To report concerns related to Diamond Vogel employees, please contact our Compliance Department at compliance@diamondvogel.com.

Adherence to the Business Partner Code of Conduct

The Diamond Vogel Business Partner Code of Conduct is applicable and mandatory for all our business partners. Our business decisions are not only based on our business partners’ quality, price, service, and professionalism, but also their respect for Diamond Vogel’s commitment to conduct business in an ethical, environmentally, and socially responsible manner in accordance with the Diamond Vogel Business Partner Code of Conduct.