Code of Conduct

CODE OF CONDUCT INTRODUCTION

WSIDE Teknoloji ve Yazılım A.Ş (WSIDE) is committed to carrying out its activity respecting people and the environment.

At WSIDE, we are convinced of the importance of people’s welfare as well as   with our suppliers; and this has inspired us to set these requirements that compose the WSIDE Code of Conduct (hereinafter the Code of Conduct or CoC).

The Code of Conduct generally explains what WSIDE expects from its suppliers with regards to compliance with the law, labour practices, environment-friendliness and anticorruption practices.

These requirements apply to all suppliers who manufacture for and/or supply to WSIDE. It should be noted that the provisions of the Code of Conduct are minimum standards, not maximums. WSIDE expects suppliers to dedicate their efforts to the continuous improvement of working conditions and compliance with the environment.

Expectations regarding quality standards, product standards and delivery instructions are covered in the WSIDE website and/or other agreements.

 

 

REQUIREMENTS

WSIDE expects its suppliers to conduct their operations in a responsible manner, placing all their efforts into protecting people and the environment. In brief the requirements of the Code of Conduct are:

1.     Compliance with the law

1.1.  Compliance, at all times, with all national and any other applicable legislation.

1.2.  Respect for intellectual property rights, data protection and any other 3rd party rights.

1.3.  Information Confidentiality

1.4.  Responsibility and duty to maintain information confidential at all times, even once the commercial relationship has come to an end.

2.     Labour

2.1.  Child labour is strictly prohibited.

2.2.  No form of discrimination in the workplace.

2.3.  Forced labour is prohibited.

2.4.  Support the freedom of association and collective bargaining.

2.5.  Prohibition of degrading or inhumane treatment.

2.6.  Special consideration to vulnerable groups.

2.7.  Safe and hygienic work environment.

2.8.  Legality of employment conditions.

2.9.  Decent living wage, paid on time.

2.10.               No excessive work hours.

3.     Environment

Commitment to the protection of the environment and compliance with applicable legislation.

4.     Health and Safety

Everyone in workplace must comply with applicable health and safety standards.

5.     Anti-corruption

Any bribery and corrupt practices are forbidden and not tolerated.

6.     Money Laundering

7.     Market and competitive behavior

7.1.  Relationships and interactions with competitors

7.2.  Customer relationships

7.3.  Abuse of a dominant market position

8.     Trade and professional association meetings

1.     Compliance with the law

1.1.  Suppliers must, at all times, comply with its national law and any other applicable legislation.

1.2.  In those cases where both legislation and the rules laid out in the Code of Conduct refer to the same matter, suppliers should apply the provision that gives greater protection to workers and/or the environment.

1.3.  Suppliers must guarantee the respect of intellectual property rights, and under no circumstance should they offer or produce counterfeits (piracy).

1.4.  Suppliers are obliged and required to preserve the integrity and confidentiality of information received as a result of the business relationship with WSIDE.

1.5.  This mandatory confidentiality must continue even once the relationship with WSIDE has reached an end. This includes the obligation to destroy and/or delete any digital material as well as the return of any physical material relating to the company that the supplier has in their possession.

2.     Labour

WSIDE respects human rights and does not want to be complicit in any situation where human rights are infringed or abused. WSIDE expects its suppliers to respect the human rights of workers and meet the requirements set forth.

2.1.  Child labour

2.1.1.     Workers should be at least 18 years of age, or older if so dictated by local legislation, including regulations regarding compulsory education.

2.1.2.     Workers who carry out hazardous tasks or work at night must be aged 18 or older, if so dictated by local legislation.

2.2.  Discrimination

2.2.1.     Suppliers should not apply, encourage or tolerate discrimination in the workplace. This includes the recruitment, hiring, training, working conditions, allocation of work, remuneration, promotions, discipline, dismissals and retirement.

2.2.2.     The only permissible basis for differentiation of workers will be their ability and willingness to perform the job. Workers should never be differentiated based on personal characteristics such as; gender, age, religion, marital status, race, caste, social background, illness, disability, pregnancy, ethnicity or national origin, membership in workers’ organizations including unions, political affiliation or sexual preference.

2.3.  Forced labour

2.3.1.Workers should act on a voluntary basis, meaning that all forms of forced labour, including servitude, slavery, forced labour or imprisonment are strictly prohibited.

2.3.2.Suppliers may not violate/infringe the free choice of employment by demanding deposits or withholding wages or identity documents.

2.3.3. Suppliers should allow workers to rescind/terminate their contracts of employment, with reasonable notice.

2.4.  Freedom of association

2.4.1.  The supplier adopts an open attitude and facilitates workforce representation; likewise, they must allow workers to form and/or join unions of their choice, and to use collective bargaining processes.

2.4.2.  Worker representatives shall have access to the workplace to carry out their representation functions.

2.4.3.  In those cases where freedom of association and collective bargaining rights are limited by law, suppliers should facilitate (rather than hinder) alternative forms of worker representation and negotiation.

2.4.4.  Suppliers must implement conflict resolution mechanisms that allow for the resolve of internal industrial disputes and worker complaints.

2.5.  Prohibition of degrading or inhumane treatment

Suppliers must treat workers with dignity and respect, and not practice or tolerate any form of harassment (including sexual harassment), intimidation, violence, corporal punishment or abuse of any kind; including physical, psychological and/or verbal abuse.

2.6.  Special consideration to vulnerable groups

Suppliers should show special consideration for the rights of those who are most vulnerable to abusive labour practices, such as women, homeworkers, casual and temporary staff, and immigrants.

2.7.  Health and safety

2.7.1.     Suppliers must provide a safe and healthy workplace, ensuring minimum conditions of light, ventilation, hygiene, fire prevention and security measures.

2.7.2.     Suppliers ensure that the necessary precautions are taken to prevent accidents and injury from occuring during work and in the workplace.

2.7.3.     Suppliers must provide workers with regular health and safety training at work.

2.7.4.     Suppliers should provide access to clean sanitary facilities, potable water and, if applicable, hygienic food storage and preparation facilities.

2.7.5.     In cases where accommodation is provided, these must be clean, safe, and must cover the workers’ basic needs.

2.8.Legality of employment conditions

2.8.1.Suppliers should initiate recognized work relations, in conformity with national legislation and practices.

2.8.2.Suppliers must not attempt to evade their legal obligations under the employment relationship.

2.9.Salaries

2.9.1.Suppliers must remunerate workers with wages, paid overtime, benefits and paid holidays, equivalent to or above the legal minimum and/or industry benchmarks, whichever is greater.

2.9.2.Salaries and other remuneration should be paid regularly and on time.

2.9.3.Suppliers may not make deductions from wages that are not covered by national legislation, nor may they do so as a disciplinary measure.

2.9.4. Before starting work, suppliers must provide workers with written and easily understandable information regarding their conditions of employment and salary; likewise, upon each payment of salary the supplier should also provide worker with written document detailing the sum being paid.

2.10.Work hours

2.10.1.Suppliers must define by contract the number of normal working hours. This number must be in accordance with national legislation or collective agreements.

2.10.2.Suppliers must not resort to overtime on a regular basis, applying extra hours responsibly and in exceptional circumstances; it should be noted and accepted that overtime is voluntary, therefore workers are not obliged to work extra hours.

2.10.3.A maximum of 45 hours may be worked over a seven-day period, except in exceptional and unforeseen circumstances; and only if permitted by national legislation, in the collective agreement and ensuring that measures are taken to protect the workers’ health and safety.

2.10.4.Suppliers must give workers appropriate rest breaks during the working day. Workers must also be granted at least one day off per seven-day period  and legal holidays.

3.Environmental responsibility

WSIDE believes that good environmental practices are essential for its industrial success. For this reason, WSIDE expects its suppliers to adopt an approach of continual improvement which, in the long term will allow them to not only meet but exceed the legislation in place and proactively manage their environmental performance.

3.1.Suppliers must place a constant emphasis and commitment to environmental friendliness and must meet the applicable local and national standards and legal requirements; likewise, they will also employ their efforts to meeting international standards in this area.

3.2.Suppliers must obtain all required environmental licenses, and keep them updated.

3.3.Suppliers must make reasonable efforts to ensure that their purchasing decisions do not encourage deforestation, animal cruelty nor have a negative impact on vulnerable eco-systems or endangered species (as defined by the CITES convention).

4.Product health and safety

For WSIDE, it is important to offer customers products that meet the highest health and safety standards; and therefore we expect maximum commitment from our suppliers in regulating the use of those substances of legally limited use.

4.1.Suppliers are responsible for all products supplied to WSIDE meeting the health and safety standards established by WSIDE, so as to ensure that items placed on the market do not pose any risk to the customer.

5.Anti-corruption

WSIDE expects its suppliers to carry out highly ethical business practices.

5.1.Suppliers must comply with all applicable laws against bribery and corruption.

5.2.Suppliers must not offer, pay, solicit or accept bribes, nor facilitate payments of such. Moreover any gift with value over 150 USD Dollars shall not be offered to WSIDE employees.

6.Money laundering

Not only Suppliers but also supplier employees, affiliated companies, consultants, advisers, shall, either alone or in concert with others, perform any activities that contravene domestic or foreign regulations governing money laundering. In the event of doubts as to the propriety of transactions that involve the transfer of cash, the relevant financial department should be consulted at an early stage.

7.Market and competitive behavior

WSIDE, its employees and affiliated parties are unconditionally committed to the principles of fair competition and comply with the antitrust and fair competition laws of the countries in which WSIDE conducts business.

As accurate legal assessment depends on the complexities of the laws concerned and the individual circumstances of each situation, an attorney from WSIDE should be consulted wherever doubt arises.

7.1.Relationships and interactions with competitors

Agreements with competitors and coordinated behavior aimed at or causing a restraint or limitation on competition are forbidden. These include agreements to fix or set prices, quotations, terms and conditions of sale, production or sales quotas, and also the apportionment or allocation of customers, territories, markets or product portfolios. Not only formal agreements are forbidden, but also coordinated behavior arising from, for example, informal talks or gentlemen’s agreements aimed at or giving rise to such a restraint on competition.

In discussions with competitors, we must apply strict controls in order to ensure that we do not pass on or receive any information that would allow conclusions to be drawn about the current or future market behavior of the information donor. Current or future information regarding price, margins, costs, market share, internal proprietary practices, sales terms and specific customer or vendor information should not be obtained from or exchanged with a competitor.

7.2.Customer relationships

WSIDE employees will not interfere with supply relationships with their business partners (geographical, personal or material restraints). WSIDE employees will not encourage illegal tying and resale arrangements.

8.Trade and professional association meetings

WSIDE employees shall attend only meetings of legitimate trade and professional associations, conducted for proper business purposes. It is preferable that meeting minutes be recorded. Any benchmarking or comparative information supplied must be in full compliance with applicable laws and regulations (including regulation fort he antitrust/fair competition).

 

 

CODE OF CONDUCT COMPLIANCE

WSIDE is aware of the challenges in meeting all the requirements set in this Code of Conduct. However, it considers that compliance is key to its future commercial success and that of its suppliers.

Complying with the Code of Conduct is as important as meeting our quality standards or delivery terms. WSIDE seriously endeavours to work with open and honest suppliers who demonstrate their commitment to making continuous improvements.

1.     Performance Management

1.1.  Suppliers must implement an effective management system that allows them to proactively manage the compliance with the Code of Conduct.

1.2.  Suppliers must disclose this Code of Conduct to their employees. They should also raise awareness of its content. A copy, translated into the local language, should be displayed in a place that is accessible to all employees.

1.3.  Suppliers are expected to conduct regular internal evaluations.

1.4.  Suppliers are responsible for ensuring compliance with the Code of Conduct throughout the entire production chain.

2.     Monitoring and transparency

2.1.  Suppliers should allow WSIDE and/or their representatives to carry out announced or unannounced checks.

2.2.  In the course of these possible controls, suppliers are to offer complete cooperation and allow unrestricted access to workers, records, work areas and accommodation, if any.

2.3.  Suppliers must keep complete and accurate records to effectively assess compliance. Under no circumstance should this information be manipulated nor should it distort any aspect of its activities.

2.4.  Suppliers authorise WSIDEto reveal their name and the addresses of production locations to third parties, as well as information relating to their performance in accordance to the Code of Conduct.

3.     Penalties

3.1.  If violations of the Code of Conduct were to be detected, WSIDEwill demand that the supplier develop an improvement plan and execute it within a given time, which may vary dependent on the nature of the offense.

3.2.  In the case of very serious offenses, for example, child labour, forced labour, bribery, use of forgeries, and/or if the supplier continuously fails to carry out improvement plans, WSIDE reserves the right to terminate the business relationship with the supplier, including the cancellation of orders that are in process.

3.3.  WSIDE will find the supplier liable for any damages and costs incurred, including loss of profits that come as a result of the supplier breaching the Code of Conduct.

WSIDE wishes to establish long term relationships with suppliers who are genuinely committed to working towards improving working conditions and protecting the environment.

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