Wilson Electronics Supplier Code of Conduct

This Supplier Code of Conduct sets forth our expectations for our suppliers and their employees, personnel, agents, and subcontractors. We expect all suppliers in our operations and supply chain and their suppliers to be aware of, attest to, train to, and adhere to the following social, environmental, and ethical responsibilities.

Personal Identification Information

  • No individuals are hired under 15 years of age, or 14 years of age where local law allows, and such exception is consistent with ILO Convention No. 138 & 182, or under the legal minimum age for employment in the country, whichever is greatest.
  • Any employment of workers under the age of 18 does not interfere with schooling or vocational education or expose children to risks that can harm physical, mental or emotional development including night shifts and overtime.

Forced Labor and Human Trafficking

  • All forms of forced labor are prohibited, including any form of prison, trafficked, indentured or bonded labor.
  • Original personal identification and travel documents are not retained, and freedom of movement is not restricted.
  • Workers are not charged or required to pay fees or deposits to obtain or maintain employment. Pay is not withheld, and no conditions are present that constrain a worker’s ability to freely choose employment.
  • Accurate and understandable information regarding the nature of work, compensation, work hours, and benefits is provided in writing in advance of employment.

Freedom of Association and Collective Bargaining

  • Workers will be permitted to associate freely, bargain collectively, and seek representation in accordance with local laws.
  • Suppliers are expected to permit workers to openly communicate and share grievances with management about working conditions without fear of reprisal or harassment.
  • In cases where freedom of association is restricted by local law, alternative means of freedom of association will not be obstructed.

Non-Discrimination and Harassment

  • The Company is committed to a work environment in which all individuals are treated with respect and dignity.
  • Discrimination or harassment in hiring, pay, promotion, or in the workplace on the basis of race, color, sex, national or social origin, religion, age, disability, sexual orientation, marital status, pregnancy status, gender identity or any other status protected by applicable law is prohibited.
  • All forms of abuse or harassment in the workplace is prohibited.

Health & Safety

  • A safe and hygienic workplace is provided in compliance with the law, and systems are in place to detect and manage potential risks to workers.
  • Workers undertake health and safety training, hazardous materials and chemicals are properly stored, and workers are provided with the appropriate personal protective equipment.
  • Health and hygiene of workers is provided for as relevant at the site, including toilet facilities, access to drinking water and food safety.
  • Unreasonable restrictions are not placed on workers’ toilet, rest or lactation breaks.
  • Employer-provided housing, transportation and food must be sanitary and safe.

Hours of Work

  • Regular and overtime working hours are in compliance with the law and take into account worker safety, and overtime is voluntary.
  • 24 consecutive hours of rest are provided in every 7-day work period. If allowed by law, 48 consecutive hours of rest in every 14-day work period are permitted.


  • All legally mandated wages and benefits are provided.
  • Payment is made on time and on at least a monthly basis.
  • Deductions are not taken from pay as punishment.
  • Itemized records are maintained, consistent with this standard, and transparent pay information is provided in a timely manner.


  • The supplier complies with all applicable laws, including those pertaining to bribery, corruption, or any type of fraudulent business practice.


  • Compliance with applicable environmental laws, particularly with regard to waste, air and water.
  • All required environmental permits for use and disposal of water and waste are obtained.
  • Legal title to or a legal lease for its land is obtained, and there are no indications that the supplier’s right to own or lease that land is contested.

Responsible Sourcing of Minerals

  • Suppliers shall have a policy to reasonably assure that the tantalum, tin, tungsten and gold in the products they manufacture does not directly or indirectly finance or benefit armed groups that are perpetrators of serious human rights abuses in the Democratic Republic of the Congo or an adjoining country. Suppliers shall exercise due diligence on the source and chain of custody of these minerals and make their due diligence measures available to customers upon customer request.


  • Workers will be aware of, and have access to, a supplier-provided complaints mechanism that is transparent, responsive, anonymous, unbiased, and confidential through which they can raise questions about or report violations of supplier policies, expectations contained in this Supplier Code of Conduct, other workplace grievances, or legal or ethical violations.
  • Retaliation against workers reporting violations or cooperating in investigations is prohibited.


  • Suppliers are strongly encouraged to provide resources to support and contribute to the communities and countries in which they operate.

Wilson Electronics Supplier Code of Conduct

All suppliers to Wilson Electronics are expected, at a minimum, to comply with applicable laws and regulations.

If the Supplier Code of Conduct establishes a higher standard than is required by applicable law, Wilson Electronics expects its suppliers to apply the Supplier Code of Conduct. Where alignment with the Supplier Code of Conduct could lead to a conflict with or a violation of applicable laws or regulations, the supplier will notify Wilson Electronics of the situation and explain how it intends to operate in a responsible manner.

Suppliers are expected to adopt or establish appropriate policies, management systems, procedures, training, and staffing to meet the expectations in the Supplier Code of Conduct. Suppliers will communicate to workers the standards to which the supplier is committed, as well as relevant laws, regulations, and protections. Suppliers will notify Wilson Electronics of any actual or suspected legal infractions, including any legal actions against the supplier by the authorities for violations of human rights, environmental laws, or anti-corruption or bribery laws. Wilson Electronics reserves the right to request and receive additional information from the supplier regarding its management of relevant issues.

To identify whether a supplier is in compliance with the Supplier Code of Conduct, Wilson Electronics reserves the right to request suppliers to complete self-assessments, disclose relevant policies or procedures, or to be subject to announced and unannounced on-site direct and/or third-party audits or evaluations of the supplier’s facilities, including housing provided by the supplier or labor providers, and workplaces to which the supplier has sub-contracted production of Wilson Electronics procured products. Wilson Electronics reserves the right to audit the operations, records, policies, and procedures of the aforementioned entities and to conduct confidential worker interviews in connection with such audits or evaluations as appropriate and as agreed. Upon request, distributors, brokers and agents supplying to Wilson Electronics will also provide Wilson Electronics with access to the workplaces, records, policies, procedures, and workers of their first-tier suppliers. If Wilson Electronics identifies areas of non-compliance, Wilson Electronics reserves the right to request suppliers to make the necessary investments in systems and condition improvements to ensure compliance.

Wilson Electronics, in its sole discretion, reserves the right to not initiate, to suspend or to terminate its relationship with a supplier if the supplier refuses to consent to the Supplier Code of Conduct or to take the appropriate steps to come into compliance with the Supplier Code of Conduct.

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