Commercial Vehicle Control Systems Division, a part of ZF Group has a powerful reputation for the excellence of its products and services, built on a strong foundation of integrity and fair dealing in every aspect of our business. In this increasingly complex, competitive, and dynamic world, protecting our reputation is a key pillar to maintain the confidence and trust of Division’s diverse stakeholders. To conduct business openly and honestly, Division will avoid conflicts of interest, and comply with all applicable anti-corruption laws, including the US Foreign Corrupt Practices Act. We will obey the law of the countries in which we operate, and respect the dignity of every individual.The Division builds mutually beneficial relationships with suppliers and service providers. We comply with all regulations and contractual commitments regarding the use of intellectual property and with the law in all jurisdictions in which we do business, including especially any competition law requirement. The Division is committed to protecting the environment, respecting human rights, and maintaining a safe and friendly workplace, throughout its supply chain.
The information contained within this manual applies throughout Global Sourcing & Purchasing organization to our employees, customers, suppliers, consultants, or any other party with which we would enter into a contractual relationship.
Our Code of Conduct
ZF and our Commercial Vehicle Control Systems Division place the upmost priority on appropriate, responsible and sustainable business behavior, which is the basis for the trust it has established with society and its customers, shareholders and business partners. We must continue to earn this trust each and every day. To do so, we must base our actions on the highest business and ethical standards and commitments, applicable laws and ZF policies.
ZF Code of Conduct is the key to achieving and maintaining our direction, providing us with the foundation of our values and core principles. The Code of Conduct provides us with guidance when faced with questions about proper behavior and compliance. These values and core principles establish the ground rules that must guide us in our business decisions. It is critical that we not only read and understand these values and principles in our Code of Conduct, but that we also follow and live by them in our day-to-day business activities. We bear responsibility for our products and our work.
We also have an ethical responsibility towards our employees, society, business partners, and the environment. In order to fulfill this responsibility, we must and expect our business partners to all act in a way that is lawful, honest, and responsible. We also expect our business partners to adhere to all applicable laws, generally accepted standards of social responsibility, and basic principles of integrity and to ensure that the same is put into practice throughout the business partners’ supply chain.
Conflict Mineral Policy
The Conflict Mineral Policy has been designed to support the humanitarian objective of ending ongoing violence funded by the trade of conflict minerals from the eastern portion of the Democratic Republic of the Congo and surrounding countries ("Conflict Region").
WABCO fully supports U.S. legislation on the supply of conflict minerals, including the rules adopted by Securities Exchange Commission. Conflict minerals include gold, tin, tantalum and tungsten. The U.S Secretary of State may designate other minerals in the future.
WABCO endorses the objectives of the U.S. legislation to address the trade of conflict minerals.
WABCO will not knowingly procure minerals from the Conflict Region unless they are certified as conflict-free by an independent third party.
WABCO is committed to complying with the due diligence requirements to determine the source of conflict minerals used within its products and expects its suppliers to assist with this task.
We expect our suppliers to ensure compliance with U.S. legislation on the supply of conflict minerals, including the rules adopted by Securities Exchange Commission.
Should you like to learn more, please visit our webpage where you will find WABCO Conflict Mineral Policy.
Protection of the environment is an integral part of WABCO’s vision. All of WABCO’s manufacturing plants are certified according to ISO 14001, based on the firm believe that ‘excellence in execution’ will only be achieved by continually improving our environmental performance, including the use of permitted materials, energy conservation and waste reduction.
WABCO implements ISO150001 Energy management at larger locations, to ensure a higher focus on energy conservation and with that, CO2 reduction.
We expect our suppliers to ensure compliance with all relevant environmental legislation and regulations in force in the country where their products are delivered. In terms of environmental management, suppliers must conform to the latest version of ISO 14001. In addition, suppliers must comply with WABCO’s environmental policy and the WABCO JED Standards to avoid hazardous substances (JED-762).
Any complaints from WABCO suppliers should be addressed in line with REACH Regulation (EC) No. 1907/2006 (Registration, Evaluation, Authorization and Restriction of Chemicals).
Parts are only to be provided with the material data MDS record (Material Datasheet) and must include the IMDS ID number in the initial sample cover sheet (PPAP PSW). MDS is recorded in the IMDS (International Material Data System).
We expect our suppliers to protect the environment by being responsible and by ensuring excellence in the design, manufacturing, distribution, recycling and disposal of the products they create.
Health and Safety
At WABCO we value people and take health and safety very seriously. As such, WABCO has implemented and is certificated for the Occupational Health and Safety standard OHSAS18001 (ISO45001). We lead by example and nurture a culture of responsibility towards health and safety among our colleagues, customers and business partners.
WABCO has a specific policy for health and safety which we expect our suppliers to adhere to. This includes:
- Safety principles govern our daily work – working safely is a condition of employment at WABCO
- Our processes are designed to perform better than, rather than just comply with, laws, rules and regulations determined by local, state, province or federal jurisdictions
- WABCO has a comprehensive ergonomic program in place to protect our people today, but also for the future
- We have a moral obligation to report all health and safety risks. This includes reporting any incidences of child labour and other exploitative activities
- We treat all incidents regarding safety, health, assets and property damage as a process deficiency that can be avoided based on Six Sigma Lean principles. We truly believe that preventing accidents is an important part of our social responsibility
- All accidents must be investigated by a formal procedure. In case of an accident involving WABCO employees at our supplier site, our supplier must take full responsibility for the care and needs of the affected employees
- We communicate to all our employees in an honest, clear and fair manner about the relationship between our processes, safety, health and the environment
- We expect all WABCO suppliers to conduct business in the same honest, clear and fair manner and that goods and services should be delivered to our locations in a safe, ergonomic and healthy fashion
- We encourage all suppliers to follow the principles and implementation requirements of OHSAS 18001 (ISO45001) in their activities, including making a commitment to the prevention of injury and ill health. We expect them to pursue continuous improvement
- Suppliers must understand and respect WABCO’s commitment to safety, health, environment & security
- When suppliers visit our facilities they must obey all warning signs and plant visitor rules. When WABCO employees visit supplier sites, the supplier must provide them with the necessary information and instruction to ensure their safety. As appropriate, this will include the provision of adequate personal protection equipment
- WABCO suppliers are responsible for making sure that their suppliers also meet these environmental, health and safety requirements in order to protect WABCO’s supply chain.