Creation Code of Conduct PDF

It is the policy of Creation Technologies Inc. and its subsidiaries and affiliates (collectively, “Creation” or the “Company”) to comply fully with all laws governing its operations and to conduct business in keeping with the highest moral, legal and ethical standards. To that end, the Board of Directors has adopted this Creation Code of Ethics and Business Conduct. Creation is built upon a foundation of strong corporate values and business practices.

Our Code of Business Conduct and Ethics is designed to deter wrongdoing and to promote:

• Honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships;
• Compliance with applicable laws, rules, and regulations;
• The prompt internal reporting of violations of this Code; and
• Accountability for adherence to this Code.

This Code should help guide your conduct in the course of our business. Many of the principles described in this Code are, however, general in nature, and the Code, as is the case with any code or policy, cannot anticipate every situation that may arise. Use common sense and good judgment in applying this Code. If you have any questions about applying the Code, it is your responsibility to seek guidance.

Scope
All officers, directors, and employees of Creation, as well as third-party suppliers, subcontractors, vendors, agents, representatives, consultants and other business partners (“Company Personnel”) are required to perform their duties on behalf of the Company honestly, responsibly, and diligently, and in full compliance with this Code. No Company Personnel shall engage in any conduct that might reasonably be expected to raise questions as to the Company’s honesty and reputation or otherwise cause harm or embarrassment to the Company.

This Code of Conduct defines and creates the expectations for the supplier concerning responsibilities towards employees, stakeholders and the environment. Creation Technologies reserves the right to reasonably change the requirements of this Code of Conduct.

Respect for Human Rights

• To promote opportunities for and treatment of its employees irrespective of skin color, race, nationality, social background, disabilities, sexual orientation, political or religious conviction, sex or age
• To respect the personal dignity, privacy and rights of each individual
• To refuse to employ or make anyone work against their will
• To prohibit behavior that is coercive, threatening, abusive or exploitative
• To comply with working hours and working conditions laid down in the applicable laws
• To refuse to tolerate any unacceptable treatment of employees, including harassment, discrimination or cruelty

Safety and Health of Employees

• To take responsibility for the health and safety of employees in the work place
• To control hazards and take precautionary measures against accidents and occupational diseases
• To provide training and ensure that employees are educated in health and safety issues

Sourcing and Supply Chain

• To promote among suppliers compliance with this Code of Conduct
• To comply with the principles of non-discrimination with regard to supplier selection and treatment
• To protect intellectual property rights
• To have a policy that assures responsible sourcing of materials, including the sourcing of Conflict Minerals, and we expect that our suppliers committed to responsible sourcing.
• To conduct due diligence on the source and chain of custody of these minerals and make their due diligence measures available to customers upon customer request

Global Environmental Protection

• To act in accordance with the applicable standards regarding environmental protection on a global basis
• To minimize environmental pollution  and impact while making continuous improvements in environmental protection

Underage Labor Prohibition

• Employ no workers under the age of 15 or, in those countries subject to the developing country exception of theology Convention 138, to employ no workers under the age of 14

Prohibition of Corrupt Practices

• Not to engage in any form of corruption or bribery, including payment or other form of benefit conferred on any government official for the purpose of influencing decision making in violation of law. This includes the mandates for individuals outlined in the Foreign Corrupt Practices Act.

Legal Compliance

• To comply with the laws of the applicable legal system(s)

Creation Technologies is a recognized leader in the electronic manufacturing services industry and is a socially responsible company committed to the long term sustainability of our environment.

We achieve this through:

Being a good corporate citizen

Committed to compliance with applicable legal and other requirements

Being a company with whom people want to be associated
Committed to the prevention of pollution and sharing objectives and targets with our employees, our customers, our suppliers and the general public

Being a company that exceeds expectations
Continual improvement through reducing the use of hazardous substances and waste going to landfill, conserving natural resources, and minimizing the release of contaminants into our environment (air; water).

Being a company where employees are proud to work
Committed to provide ongoing training and skills development and working together to improve our environment

Partners in business, working together to build the future!

On August 22, 2012, the Securities and Exchange Commission adopted Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Conflict Minerals Law”). The Conflict Minerals Law requires all publically traded companies to report annually to the SEC whether they use Conflict Minerals including gold, wolframite, casserite, columbite-tantalite and their derivative metals, which include tin, tungsten, tantalum and any other compounds designated by the U.S. Secretary of State.

We at Creation Technologies fully support the objectives of this legislation, which aims to prevent the use of minerals that directly or indirectly finance or benefit armed groups in the Democratic Republic of the Congo or in adjoining countries. Because Creation is not a publicly traded company, we are not required to file reports with the SEC and as such are not directly subject to the requirements of the Conflict Minerals Law. We manufacture custom electronic products in strict accordance with written specifications provided to us by our customers and therefore have limited control over components which our customers may specify for use in their final products.

However, in support of the objectives of the legislation, we at Creation are committed to doing all that we can to support our customers in ensuring that the products we manufacture meet the requirements of the Conflict Minerals Law and that our supply chain does not knowingly contribute to such human rights violations. Where the supply chain has been established by Creation, rather than our customer, Creation will complete a reasonable country of origin inquiry for any consumable materials used in the manufacturing process that are not listed on the Bill of Materials. In this process, we ask our respective suppliers to confirm their compliance with the Conflict Minerals Law by providing the necessary declarations to us in an accepted industry-standard Conflict Minerals Reporting template (e.g., the Electronic Industry Citizenship Coalition (EICC) / Global e-Sustainability Initiative (GeSI)). We provide copies of such declarations to Customer upon request.

Creation Technologies is a socially responsible company committed to the long term sustainability of our communities.

​Creation Technologies helps OEMs consider their environmental impact during the earliest stages of product design through End-of-Life.

We help you find ways to create products that use less energy, fewer materials (including in packaging), have longer lifecycles, and a smart supply chain that minimizes your carbon footprint.

Creation’s Environmental Compliance Services Include:

• Product Design and Component Engineering
• DFE & RoHS-Specific DFM
• Materials Compliance Review
• Manufacturability & Process Compatibility Analysis
• Rapid Prototyping
• Board & System-Level Materials Declaration
• Product Take-Back and Recycling Services, WEEE

As part of the No Surprises Act and Transparency in Coverage Final Rule set forth by the U.S. Department of the Treasury, the U.S. Department of Labor, and the U.S. Department of Health and Human Services, group health plans and health insurance issuers are required to make available to the public negotiated rates for all covered items with in-network providers, and historical payments to and billed charges from, out-of-network providers through machine-readable files (MRFs) posted on an internet website, updated monthly. These files will permit the public to have access to health plan payment information that can be used to understand health plan pricing and the cost for health care services.

Blue Cross Machine Readable File Links