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Supplier Code of Conduct

Supplier Code of Conduct

Public safety agencies and governments can choose from a variety of mission-critical communications providers. They consistently choose Motorola Solutions because we provide exceptional solutions at competitive prices, as well as service and support to ensure those solutions meets our customers’ specific, demanding job requirements.

Motorola Solutions’ Supplier Code of Conduct describes corporate responsibility requirements for our suppliers. This code is based on our long-standing key beliefs of uncompromising integrity and constant respect for people. These requirements are consistent with the core tenets of the International Labour Organization's (ILO) fundamental conventions and the United Nations Universal Declaration of Human Rights as well as the Organization for Economic Cooperation and Development (OECD) Guidelines for Multi-National Enterprises and informed by other internationally recognized standards including those of the Responsible Business Alliance (RBA) of which we are a member. Motorola Solutions continually seeks opportunities for improving its human rights program and expects the same of our suppliers. We are committed to maintaining a high-quality program through self-assessments, industry collaboration, benchmarking and stakeholder engagement.

It is Motorola Solutions’ policy to conduct business in compliance with the law and widely accepted norms of fairness and human decency (see “Motorola Solutions Code of Business Conduct”), and we require our suppliers to act similarly. We also expect our suppliers to adhere to our Human Rights Policy and Privacy Policy. As a condition of doing business with Motorola Solutions, we expect suppliers to conform to these requirements and expect their sources in the supply chain to do so as well. We assess conformance to these requirements through mandatory self-assessment questionnaires and periodic on-site audits and consider a supplier's progress in meeting these requirements and their ongoing performance in making sourcing decisions.

Suppliers are expected to correct non-conformance issues identified during assessments. We want to work with our suppliers to improve conditions, because the situation for workers can deteriorate if we simply terminate contracts. If a supplier refuses or is unable to correct the non-conformance to our satisfaction, we will terminate the relationship as a last resort.

If Supplier has any ethics concerns relating to business conducted by Motorola Solutions, Supplier may contact Motorola Solutions at: Phone: U.S, Canada or Puerto Rico at 800-5Ethics (800-538-4427) or internationally +1 847-576-1878 or send an e-mail to Motorola Solutions’ Ethics Line at ethicsline@motorolasolutions.com.

If Supplier has any privacy concerns or needs to report an incident relating to business conducted by Motorola Solutions, Supplier may contact Motorola Solutions Security Operations Center 24x7 at: Phone: 1 (302) 444-9838 or send an e-mail to privacy1@motorolasolutions.com.

Our requirements for supplier business conduct are:

ETHICS

1) Business Integrity

Supplier at all times will conduct itself, directly through its employees and officers, and indirectly through third parties, in their business performance honestly and fairly, using the highest ethical standards, and treat its employees, agents, contractors and customers with dignity. 

2) No Improper Advantage

Supplier will conduct their business to uphold the highest standards of integrity without engaging in corrupt practices, including public or private bribery or kickbacks. Supplier will not promise, offer, authorize, give or accept bribes or other means of obtaining undue or improper advantage. This prohibition covers promising, offering, authorizing, giving or accepting anything of value, either directly or indirectly through a third party, in order to obtain or retain business, direct business to any person, or otherwise gain an improper advantage. Supplier will implement monitoring and enforcement procedures to ensure compliance with anti-corruption laws. Supplier will comply fully with all applicable laws including, but not limited to, the U.S. Foreign Corrupt Practices Act ("FCPA"), the UK Bribery Act, and local anti-corruption laws.

3) Disclosure of Information

Supplier will transparently perform and accurately reflect all business dealings on Supplier's business books and records. Information regarding participant labor, health and safety, environmental practices, business activities, structure, financial situation and performance is to be disclosed in accordance with applicable regulations and prevailing industry practices. Falsification of records or misrepresentation of conditions or practices are unacceptable.

4) Intellectual Property

Supplier will respect intellectual property rights, transfer technology and know-how in a manner that protects intellectual property rights, and will safeguard information from customers and suppliers.

5) No Unfair Business Practices

Supplier will act with integrity and lawfully in the proper handling of competitive data, proprietary information and other intellectual property, and comply with legal requirements regarding fair competition, antitrust, and accurate and truthful marketing.

6) Reporting and Transparency 

Supplier will offer their workforces, as well as their customers and their sources in the supply chain, the ability to report, on a confidential basis, potential violations of this Code and other policies through a number of resources such as the Motorola Solutions’ Global EthicsLine. Motorola Solutions investigates such reports and provides timely remedial or corrective action when appropriate. On an annual basis, Motorola Solutions provides aggregate data related to EthicsLine intakes in the Motorola Solutions’ Corporate Responsibility Report.

7) Responsible Sourcing of Minerals

Supplier will have a policy to reasonably ensure that the materials (tin, tantalum, tungsten and gold) used in components and products do not directly or indirectly finance or benefit illegal, armed groups through mining or mineral trading.  Supplier will establish policies, due diligence frameworks, and management systems, consistent with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. If requested, suppliers must provide disclosures as outlined in the industry-developed Conflict Minerals Reporting Template.

8) Privacy

Supplier will commit to respect the privacy rights of everyone with whom they do business, including suppliers, customers, consumers, and staff. Supplier will comply with privacy and information security laws and regulatory requirements when personal information is collected, processed, transmitted, shared and stored.

LABOR

1) Freely Chosen Employment

Supplier will not use forced, bonded (including debt bondage), involuntary, slave, prison, indentured or exploitative labor, or engage in trafficking of persons. This includes transporting, harboring, recruiting, transferring or receiving persons by means of threat, force, coercion, abduction or fraud for labor or services. There shall be no unreasonable restrictions on workers’ freedom of movement in the facility or unreasonable restrictions on entering or exiting company-provided facilities, including hostel accommodations. Supplier will ensure that the terms of employment for supplier employees or contract or migrant workers are voluntary. All fees related to employment, such as agency recruitment fees, employment relocation and end-of-service fees, will be paid by Supplier. If any fees are found to have been paid by workers, all fees shall be repaid to the worker. Supplier will provide transportation from and to the worker’s country of origin. Upon the end of employment supplier will protect and interview any workers suspected of being victims or witnesses to prohibited trafficking activities, prior to returning to their country of origin. If housing is arranged, housing must meet host country or ILO housing and safety standards, whichever is more stringent. Supplier will not require any supplier employee or contract or migrant worker to remain in employment for any period of time against his or her will, or engage in practices that restrict the worker’s movement or ability to terminate employment. Supplier employees and contract and migrant workers will not be required to lodge "deposits" or hand over government-issued identification, passports or work permits as a condition of employment, unless required by law. In no event will supplier destroy, confiscate, conceal, or in any way deny employee access to their government-issued identification or immigration documents, passports or work permits. Supplier and their sub-agents will not use deceptive, misleading or fraudulent practices during recruitment of employees or contract or migrant workers. Supplier must establish a management system to identify, monitor and eradicate such practices.  As part of the hiring process, supplier will provide written employment agreements in workers' native language that contain a description of job duties, pay and terms and conditions of employment prior to the worker departing from his or her country of origin and there shall be no substitution or change(s) allowed in the employment agreement upon arrival in the receiving country unless these changes are made to meet local law and provide equal or better terms. Supplier must document compliance with the requirements of this section, provide a certified compliance plan to the contracting officer and post the relevant contents of the compliance plan at the time of initiation of contract performance and annually thereafter for the term of the contract, at the workplace and on the supplier’s website upon request. Supplier is required to include the following elements in the compliance plan: 1) an awareness program to inform supplier employees about a) a zero- tolerance policy with regard to trafficking in persons, b) trafficking-related activities in which the supplier is prohibited from engaging, c) actions that will be taken for violations; 2) a reporting process for workers to use, without fear of retaliation, to report any activity inconsistent with the zero-tolerance policy; 3) a recruitment and wage plan that only permits recruitment companies with trained employees, prohibits charging recruitment fees to the worker, and ensures that wages meet applicable host country requirements or explains any variance; 4) if supplier arranges housing, a housing plan that ensures that supplier provided housing meets host country housing and safety legal requirements or explains any variance; 5) procedures to prevent agents and subcontractors at any tier from engaging in trafficking in persons and to monitor, detect and terminate any agents, subcontractors, or subcontractor employees that have engaged in such activities.

2) No Child Labor

Supplier will not use child labor in any stage of manufacturing. The term “child” refers to any person under the age of 15, or under the age for completing compulsory education, or under the minimum age for employment in the country, whichever is greatest. Supplier will ensure that their hiring practices are in conformance with International Labor Organization (ILO) Conventions for minimum age (Convention 138) and child labor (Convention 182). Supplier is encouraged to develop lawful workplace learning or apprenticeship programs for the educational benefit of their workers, provided that all participants meet the minimum age requirements. Workers under the age of 18 should not perform work that is likely to jeopardize their health or safety, including night shifts and overtime.  Supplier shall ensure proper management of student workers through proper maintenance of student records, rigorous due diligence of educational partners, and protection of students’ rights in accordance with applicable law and regulations. Supplier will provide appropriate support and training to all student workers. In the absence of local law, the wage rate for student workers, interns and apprentices shall be at least the same wage rate as other entry-level workers performing equal or similar tasks.

3) Fair Working Hours

While it is understood that overtime is often required, Supplier will manage operations in compliance with the law and ensure that overtime does not exceed levels that create inhumane working conditions. Supplier will not require, on a regularly scheduled basis, work in excess of 60 hours per week or in excess of six consecutive days without a rest day. Overtime work is not mandatory for employment. 

4) Wages and Benefits

Supplier will offer wages and benefits that meet, at a minimum, applicable legal requirements or where no wage law exists, the local industry standard. In compliance with local laws, Supplier will compensate workers for overtime at a rate greater than regular hourly rates. In any event, wages and benefits should be enough to meet basic needs. For each pay period, the supplier will provide workers with a timely and understandable wage statement that includes sufficient information to verify accurate compensation for work performed. Suppliers will not permit deductions from wages as a disciplinary measure. All use of temporary, dispatch and outsourced labor will be within the limits of the local law.

5) No Harsh or Inhumane Treatment

Suppliers will prohibit harsh and inhumane treatment including abuse and harassment of workers (e.g. sexual abuse or harassment, corporal punishment, mental or physical coercion or verbal abuse) as well as the threat of any such treatment.  Suppliers' disciplinary policies and procedures in support of these requirements shall be clearly defined and communicated to all workers.

6) Anti-Discrimination and Retaliation

Motorola Solutions is committed to a workforce and value chain free of harassment and unlawful discrimination.  Motorola Solutions' Suppliers will not discriminate in hiring and employment practices such as wages, promotions, rewards and access to training on grounds of race, color, religion, age, national origin, citizenship, social or ethnic origin, sexual orientation, gender, gender identity or expression, marital status, pregnancy, genetic information, political affiliation, union membership, protected veteran status, disability or any other legally protected characteristic. Suppliers will provide workers with reasonable accommodation for religious practices.  Supplier will not subject workers or potential workers to medical tests or physical exams that could be used in a discriminatory way. Retaliation against anyone who in good faith reports a concern to the supplier or to Motorola Solutions about actual or suspected violations of this code will not be tolerated.

7) Freedom of Association and Collective Bargaining   

Supplier will recognize the right of workers to form and join or to refrain from joining trade unions and associations of their own choosing as well as the right to collective bargaining and to engage in peaceful assembly, unless otherwise prohibited by law. In all cases, worker rights to open communication, direct engagement, and humane and equitable treatment must be respected. Suppliers acknowledge that workers and their representatives will be able to communicate openly to share ideas and concerns with management relative to management practices and working conditions without fear of reprisal, discrimination, harassment or intimidation. 

HEALTH AND SAFETY

1) Occupational Safety 

Supplier will operate a safe, healthy and respectful work environment.  Supplier will identify and assess worker potential exposures to safety hazards (e.g. electrical and other energy sources, chemical, fire, vehicles, and fall hazards) and will control these factors through proper design, engineering and administrative controls, preventative maintenance and safe work procedures including lockout/tagout, as well as ongoing safety training. Where hazards cannot be adequately controlled by these means, workers are to be provided with appropriate, well-maintained, personal protective equipment and educational materials regarding worker risks associated with these hazards. Supplier must also take reasonable steps to remove pregnant women and nursing mothers from working condition with high hazards, to remove or reduce any workplace health and safety risks to pregnant women and nursing mothers including those associated with their work assignments, as well as include reasonable accommodations for nursing mothers.

2) Sanitation, Food and Safety

Suppliers that provide housing or eating facilities will provide workers with ready access to clean toilet facilities, potable water and sanitary food preparation, storage, and eating facilities. Worker housing or dormitories provided by the Supplier, labor agent, or on behalf of the Supplier, are to be maintained in a clean, sanitary, safe and dignified manner, and provided with appropriate emergency egress, hot water for bathing and showering, adequate lighting, heat and ventilation, individually secured accommodations for storing personal and valuable items, and reasonable personal space according to ILO guidelines or local law, whichever is more stringent, along with reasonable entry and exit privileges. 

ENVIRONMENTAL

1) Environmentally Preferred Products 

Motorola Solutions values environmentally preferred products. We work with and encourage our suppliers to create products that are energy efficient, highly recyclable and contain significant amounts of recycled materials and low amounts of hazardous materials. To enable us to evaluate supplier components and products for environmental performance, suppliers must provide material disclosures as outlined in our controlled and reportable materials disclosure process, available at the following URL: https://www.motorolasolutions.com/en_us/about/company-overview/corporate-responsibility/governance-and-policies/materials-disclosure-process.html

2) Ozone-Depleting Substances 

 It is Motorola Solutions’ policy to eliminate from our products any components — including components provided by our suppliers — that contain or that are manufactured with a process that uses any Class I ozone- depleting substance. As outlined in the Internal Revenue Service's Publication 510, the U.S. government imposes an environmental tax on the sale or use of ozone-depleting chemicals and imported products containing or manufactured with these chemicals. Suppliers need to provide certification that products imported into the U.S. do not contain or are not manufactured with a process that uses any Class I ozone-depleting chemicals and imported products containing or manufactured with these chemicals. Supplier will provide certification (certification form accessible at the following URL: http://responsibility.motorolasolutions.com/index.php/downloads/dow005-ozonedepletingsubstances/) that products imported into the U.S. do not contain or are not manufactured with a process that uses any Class I ozone-depleting chemicals. 

3) Product Safety and Regulatory Compliance

Supplier will adhere to all applicable laws, regulations and customer requirements regarding prohibition or restriction of specific substances in products and manufacturing, including all applicable product safety, environmental, and recycling regulations and laws as well as labeling requirements for recycling and disposal.

4) Safety Data Sheets

Supplier will: (i) electronically provide safety data sheets in accordance to the Globally Harmonized System of classification and labeling of chemicals, or equivalent documentation for all applicable articles supplied to or for Motorola Solutions; (ii) for all chemicals supplied or imported into the United States, certify that the chemicals are listed on the Toxic Substances Control Act, 15 USCS §2601, et.  seq., chemical inventory, or are subject to an exemption specified in the safety data sheets; (iv) for  Products imported into the United States, provide Motorola Solutions with a completed and signed ODS Certification Questionnaire, available at: http://responsibility.motorolasolutions.com/index.php/downloads/dow005-ozonedepletingsubstances/, which may be updated from time to time; and (v) (for Products used as parts or components for Motorola Solutions’ products, including the packaging used with such products) any materials that accompany such products, comply with all provisions of Motorola Solutions’ Controlled and Reportable Materials Disclosure Process available at: https://www.motorolasolutions.com/en_us/about/company-overview/corporate-responsibility/governance-and-policies/materials-disclosure-process.html which may be updated from time to time. Supplier further certifies that all substances, preparations and articles provided to or for Motorola Solutions are in compliance with all applicable EU REACH Directive Requirements (1907/2006 and 1272/2008).

5) Energy Consumption and Greenhouse Gas Emissions 

Supplier will track and document energy consumption and relevant Scope 1 and 2 greenhouse gas emissions at the facility and/or corporate level. Supplier will look for cost-effective methods to improve energy efficiency and to minimize their energy consumption and greenhouse gas emissions. 

MANAGEMENT SYSTEMS 

1) Corporate Social and Environmental Policy Statement and Compliance 

Supplier will publish a corporate social and environmental responsibility policy statement affirming Supplier’s commitment to compliance and continual improvement, endorsed by executive management and posted in the Supplier’s facility in the local language and in all native languages of workers.  Upon Motorola Solutions' request, Supplier will provide a copy of its compliance policies, procedures, and documents and/or complete a Supplier Self-Assessment from Motorola Solutions’ designated industry-recognized third party Corporate Social Responsibility (CSR) program.  Supplier will obtain a subscription to the online system RBA-ON at https://www.rba-online.org/ and complete the ICT Supplier Self-Assessment within that system.    

2) Management System and Management Accountability and Responsibility 

Supplier will adopt or establish a management system that supports the content of this Code. The management system will be designed to ensure (a) compliance with applicable laws, regulations and customer requirements related to supplier's operations and products; (b) conformance with this code; and (c) identification and mitigation of operational risks related to the areas covered by this Code.  The management system should also drive continual improvement.  Suppliers of goods will have an Environmental Management System (EMS) in accordance with ISO 14001 or equivalent.  The EMS must be implemented and functioning.  Third party registration is strongly recommended, but not required.

Supplier will clearly identify senior executive and company representative[s] responsible for ensuring implementation of the management systems and associated programs. Supplier senior management will review the status of the management system on a regular basis.

3) Legal and Customer Requirements      

Supplier will implement a process to identify, monitor and understand applicable laws, regulations and customer requirements, including the requirements of this Code.     

4) Risk Assessment and Risk Management

Supplier will implement a process to identify the legal compliance, environmental, health and safety and labor practice and ethics risks associated with Supplier’s operations.  Supplier will also have a process for determination of the relative significance of each risk and implementation of appropriate procedural and physical controls to control identified risks and ensure regulatory compliance.

5) Training

Supplier will provide programs for training managers and workers to implement Supplier’s policies, procedures and improvement objectives and to meet applicable legal and regulatory requirements.

6) Worker Feedback, Participation and Grievance

Supplier will provide processes, including an effective anonymous grievance mechanism, to assess worker’s understanding of and to obtain feedback on practices and conditions covered by this Code as well as to foster continuous improvement. Suppliers will offer their workforce, as well as their customers and their sources in the supply chain, the ability to report, on a confidential basis, potential violations of this Code and other policies through a number of resources such as the Motorola Solutions’ Global EthicsLine.         

7) Supplier Audits and Assessments 

Supplier may be responsible for the cost of Corporate Responsibility and Labor Supplier audits for compliance up to $15,000 USD per calendar year. Supplier agrees to share audit results in RBA-ON with other RBA members who are also customers of the Supplier. Suppliers are expected to correct non-conformance issues identified during assessments in a timely manner. Additionally, if at any time Supplier fails to fully comply with the requirements or Motorola Solutions has reason to believe that Supplier has failed to comply with the requirements, then the Supplier is responsible for the cost of any additional inspections or audits to verify Supplier’s ongoing compliance with this Supplier Code of Conduct.

8) Corrective Action Process

Supplier will provide for timely correction of deficiencies identified by internal or external assessments, inspections, investigations and reviews.

9) Documentation and Records

Supplier will provide a process for creation and maintenance of documents and records to ensure regulatory compliance and conformity to requirements along with appropriate confidentiality to protect privacy.

10) Supplier Responsibility 

Supplier will communicate requirements of this Code to their suppliers and to monitor their supplier’s compliance to this Code.

11) Utilization of Small and Medium Business Concerns

If applicable, Supplier will comply with the provisions of U.S. Federal Acquisition Regulation (FAR) 52.219-8 pertaining to Utilization of Small Business Concerns, as well as any other state and local, small and other business utilization laws. Supplier will promote business opportunities to a diverse supply chain, in particular to small and medium business enterprises, social enterprises and supported businesses where practical and will promote fair, transparent and inclusive processes to support small and medium enterprises.

12) Equal Opportunity

If applicable, Supplier will comply with the provisions of FAR 52.222-21, 52.222-26, 52.222-35, 52.222-36, and 52.222-50 pertaining to Segregated Facilities, Equal Opportunity, Equal Opportunity for Veterans, Affirmative Action for Workers with Disabilities, and Human Trafficking. If applicable, Supplier will maintain, at each establishment, affirmative action programs required by the rules of the U.S. Secretary of Labor (41 CFR 60-1 and 60-2). https://www.motorolasolutions.com/en_us/about/careers.html

13) Supplier and subcontractors will abide by the requirements of 41 CFR §§60-1.4(a), 60-300(a) and 60-741.5(a). These requirements prohibit discrimination against qualified individuals based on their status as protected veterans or individuals with disabilities, and prohibit discrimination against all individuals based on their race, color, religion, sex, or national origin.

Moreover, these regulations require that covered prime Suppliers and subcontractors take affirmative action to employ and advance in employment individuals without regard to race, color, religion, sex, national origin, protected veteran status or disability. Motorola Solutions is an Equal Opportunity and Affirmative Action employer. Supplier will provide all services and products, as applicable, in compliance with Motorola Solutions’ EO/AA Policy statement, which is available at https://www.motorolasolutions.com/en_us/about/careers.html and which will be mailed or faxed to Supplier upon written request.

14) Imports and Customs

Supplier will comply with all import and customs laws, regulations and administrative determinations of the importing country. Supplier will comply with the security criteria of the importing country’s government security program. If Supplier is providing Products to be delivered to, or Services to support delivery to, the U.S., Supplier will comply with the security criteria of the U.S. Customs and Border Protection’s Customs-Trade Partnership against Terrorism (C-TPAT) Program (available on www.cbp.gov).

15) Export Restriction

If Supplier is the exporter of record for any shipments, Supplier will obtain all export authorizations from the U.S. government or other governments that may be required to lawfully make such shipments.

16) Supplier Diversity

If Supplier is located in the United States or is supplying Products to Motorola Solutions locations based in the United States, Supplier will track and report its Supply Chain’s spend with minority-owned, women-owned and disabled veteran-owned business enterprises located in the United States. Supplier and Motorola Solutions will agree on a goal for Supplier’s Supply Chain spend, based upon a percentage of Supplier’s total gross revenues under this Agreement. If requested by Motorola Solutions, Supplier will submit quarterly progress reports, in a format designated by Motorola Solutions, by the twenty-fifth day of the month following the end of each calendar quarter. All reports will be forwarded to the Motorola Solutions Supplier Diversity Group via email to: supplier.diversity@motorolasolutions.com.                                                               

Motorola Solutions’ Supplier Code of Conduct describes corporate responsibility requirements for our suppliers. This code is based on our long-standing key beliefs of uncompromising integrity and constant respect for people. These requirements are consistent with the core tenets of the International Labour Organization's (ILO) fundamental conventions and the United Nations Universal Declaration of Human Rights as well as the Organization for Economic Cooperation and Development (OECD) Guidelines for Multi-National Enterprises and informed by other internationally recognized standards including those of the Responsible Business Alliance (RBA) of which we are a member. Motorola Solutions continually seeks opportunities for improving its human rights program and expects the same of our suppliers. We are committed to maintaining a high-quality program through self-assessments, industry collaboration, benchmarking and stakeholder engagement.

It is Motorola Solutions’ policy to conduct business in compliance with the law and widely accepted norms of fairness and human decency (see “Motorola Solutions Code of Business Conduct”), and we require our suppliers to act similarly. We also expect our suppliers to adhere to our Human Rights Policy and Privacy Policy. As a condition of doing business with Motorola Solutions, we expect suppliers to conform to these requirements and expect their sources in the supply chain to do so as well. We assess conformance to these requirements through mandatory self-assessment questionnaires and periodic on-site audits and consider a supplier's progress in meeting these requirements and their ongoing performance in making sourcing decisions.

Suppliers are expected to correct non-conformance issues identified during assessments. We want to work with our suppliers to improve conditions, because the situation for workers can deteriorate if we simply terminate contracts. If a supplier refuses or is unable to correct the non-conformance to our satisfaction, we will terminate the relationship as a last resort.

If Supplier has any ethics concerns relating to business conducted by Motorola Solutions, Supplier may contact Motorola Solutions at: Phone: U.S, Canada or Puerto Rico at 800-5Ethics (800-538-4427) or internationally +1 847-576-1878 or send an e-mail to Motorola Solutions’ Ethics Line at ethicsline@motorolasolutions.com.

If Supplier has any privacy concerns or needs to report an incident relating to business conducted by Motorola Solutions, Supplier may contact Motorola Solutions Security Operations Center 24x7 at: Phone: 1 (302) 444-9838 or send an e-mail to privacy1@motorolasolutions.com.

Our requirements for supplier business conduct are:

ETHICS

1) Business Integrity

Supplier at all times will conduct itself, directly through its employees and officers, and indirectly through third parties, in their business performance honestly and fairly, using the highest ethical standards, and treat its employees, agents, contractors and customers with dignity. 

2) No Improper Advantage

Supplier will conduct their business to uphold the highest standards of integrity without engaging in corrupt practices, including public or private bribery or kickbacks. Supplier will not promise, offer, authorize, give or accept bribes or other means of obtaining undue or improper advantage. This prohibition covers promising, offering, authorizing, giving or accepting anything of value, either directly or indirectly through a third party, in order to obtain or retain business, direct business to any person, or otherwise gain an improper advantage. Supplier will implement monitoring and enforcement procedures to ensure compliance with anti-corruption laws. Supplier will comply fully with all applicable laws including, but not limited to, the U.S. Foreign Corrupt Practices Act ("FCPA"), the UK Bribery Act, and local anti-corruption laws.

3) Disclosure of Information

Supplier will transparently perform and accurately reflect all business dealings on Supplier's business books and records. Information regarding participant labor, health and safety, environmental practices, business activities, structure, financial situation and performance is to be disclosed in accordance with applicable regulations and prevailing industry practices. Falsification of records or misrepresentation of conditions or practices are unacceptable.

4) Intellectual Property

Supplier will respect intellectual property rights, transfer technology and know-how in a manner that protects intellectual property rights, and will safeguard information from customers and suppliers.

5) No Unfair Business Practices

Supplier will act with integrity and lawfully in the proper handling of competitive data, proprietary information and other intellectual property, and comply with legal requirements regarding fair competition, antitrust, and accurate and truthful marketing.

6) Reporting and Transparency 

Supplier will offer their workforces, as well as their customers and their sources in the supply chain, the ability to report, on a confidential basis, potential violations of this Code and other policies through a number of resources such as the Motorola Solutions’ Global EthicsLine. Motorola Solutions investigates such reports and provides timely remedial or corrective action when appropriate. On an annual basis, Motorola Solutions provides aggregate data related to EthicsLine intakes in the Motorola Solutions’ Corporate Responsibility Report.

7) Responsible Sourcing of Minerals

Supplier will have a policy to reasonably ensure that the materials (tin, tantalum, tungsten and gold) used in components and products do not directly or indirectly finance or benefit illegal, armed groups through mining or mineral trading.  Supplier will establish policies, due diligence frameworks, and management systems, consistent with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. If requested, suppliers must provide disclosures as outlined in the industry-developed Conflict Minerals Reporting Template.

8) Privacy

Supplier will commit to respect the privacy rights of everyone with whom they do business, including suppliers, customers, consumers, and staff. Supplier will comply with privacy and information security laws and regulatory requirements when personal information is collected, processed, transmitted, shared and stored.

LABOR

1) Freely Chosen Employment

Supplier will not use forced, bonded (including debt bondage), involuntary, slave, prison, indentured or exploitative labor, or engage in trafficking of persons. This includes transporting, harboring, recruiting, transferring or receiving persons by means of threat, force, coercion, abduction or fraud for labor or services. There shall be no unreasonable restrictions on workers’ freedom of movement in the facility or unreasonable restrictions on entering or exiting company-provided facilities, including hostel accommodations. Supplier will ensure that the terms of employment for supplier employees or contract or migrant workers are voluntary. All fees related to employment, such as agency recruitment fees, employment relocation and end-of-service fees, will be paid by Supplier. If any fees are found to have been paid by workers, all fees shall be repaid to the worker. Supplier will provide transportation from and to the worker’s country of origin. Upon the end of employment supplier will protect and interview any workers suspected of being victims or witnesses to prohibited trafficking activities, prior to returning to their country of origin. If housing is arranged, housing must meet host country or ILO housing and safety standards, whichever is more stringent. Supplier will not require any supplier employee or contract or migrant worker to remain in employment for any period of time against his or her will, or engage in practices that restrict the worker’s movement or ability to terminate employment. Supplier employees and contract and migrant workers will not be required to lodge "deposits" or hand over government-issued identification, passports or work permits as a condition of employment, unless required by law. In no event will supplier destroy, confiscate, conceal, or in any way deny employee access to their government-issued identification or immigration documents, passports or work permits. Supplier and their sub-agents will not use deceptive, misleading or fraudulent practices during recruitment of employees or contract or migrant workers. Supplier must establish a management system to identify, monitor and eradicate such practices.  As part of the hiring process, supplier will provide written employment agreements in workers' native language that contain a description of job duties, pay and terms and conditions of employment prior to the worker departing from his or her country of origin and there shall be no substitution or change(s) allowed in the employment agreement upon arrival in the receiving country unless these changes are made to meet local law and provide equal or better terms. Supplier must document compliance with the requirements of this section, provide a certified compliance plan to the contracting officer and post the relevant contents of the compliance plan at the time of initiation of contract performance and annually thereafter for the term of the contract, at the workplace and on the supplier’s website upon request. Supplier is required to include the following elements in the compliance plan: 1) an awareness program to inform supplier employees about a) a zero- tolerance policy with regard to trafficking in persons, b) trafficking-related activities in which the supplier is prohibited from engaging, c) actions that will be taken for violations; 2) a reporting process for workers to use, without fear of retaliation, to report any activity inconsistent with the zero-tolerance policy; 3) a recruitment and wage plan that only permits recruitment companies with trained employees, prohibits charging recruitment fees to the worker, and ensures that wages meet applicable host country requirements or explains any variance; 4) if supplier arranges housing, a housing plan that ensures that supplier provided housing meets host country housing and safety legal requirements or explains any variance; 5) procedures to prevent agents and subcontractors at any tier from engaging in trafficking in persons and to monitor, detect and terminate any agents, subcontractors, or subcontractor employees that have engaged in such activities.

2) No Child Labor

Supplier will not use child labor in any stage of manufacturing. The term “child” refers to any person under the age of 15, or under the age for completing compulsory education, or under the minimum age for employment in the country, whichever is greatest. Supplier will ensure that their hiring practices are in conformance with International Labor Organization (ILO) Conventions for minimum age (Convention 138) and child labor (Convention 182). Supplier is encouraged to develop lawful workplace learning or apprenticeship programs for the educational benefit of their workers, provided that all participants meet the minimum age requirements. Workers under the age of 18 should not perform work that is likely to jeopardize their health or safety, including night shifts and overtime.  Supplier shall ensure proper management of student workers through proper maintenance of student records, rigorous due diligence of educational partners, and protection of students’ rights in accordance with applicable law and regulations. Supplier will provide appropriate support and training to all student workers. In the absence of local law, the wage rate for student workers, interns and apprentices shall be at least the same wage rate as other entry-level workers performing equal or similar tasks.

3) Fair Working Hours

While it is understood that overtime is often required, Supplier will manage operations in compliance with the law and ensure that overtime does not exceed levels that create inhumane working conditions. Supplier will not require, on a regularly scheduled basis, work in excess of 60 hours per week or in excess of six consecutive days without a rest day. Overtime work is not mandatory for employment. 

4) Wages and Benefits

Supplier will offer wages and benefits that meet, at a minimum, applicable legal requirements or where no wage law exists, the local industry standard. In compliance with local laws, Supplier will compensate workers for overtime at a rate greater than regular hourly rates. In any event, wages and benefits should be enough to meet basic needs. For each pay period, the supplier will provide workers with a timely and understandable wage statement that includes sufficient information to verify accurate compensation for work performed. Suppliers will not permit deductions from wages as a disciplinary measure. All use of temporary, dispatch and outsourced labor will be within the limits of the local law.

5) No Harsh or Inhumane Treatment

Suppliers will prohibit harsh and inhumane treatment including abuse and harassment of workers (e.g. sexual abuse or harassment, corporal punishment, mental or physical coercion or verbal abuse) as well as the threat of any such treatment.  Suppliers' disciplinary policies and procedures in support of these requirements shall be clearly defined and communicated to all workers.

6) Anti-Discrimination and Retaliation

Motorola Solutions is committed to a workforce and value chain free of harassment and unlawful discrimination.  Motorola Solutions' Suppliers will not discriminate in hiring and employment practices such as wages, promotions, rewards and access to training on grounds of race, color, religion, age, national origin, citizenship, social or ethnic origin, sexual orientation, gender, gender identity or expression, marital status, pregnancy, genetic information, political affiliation, union membership, protected veteran status, disability or any other legally protected characteristic. Suppliers will provide workers with reasonable accommodation for religious practices.  Supplier will not subject workers or potential workers to medical tests or physical exams that could be used in a discriminatory way. Retaliation against anyone who in good faith reports a concern to the supplier or to Motorola Solutions about actual or suspected violations of this code will not be tolerated.

7) Freedom of Association and Collective Bargaining   

Supplier will recognize the right of workers to form and join or to refrain from joining trade unions and associations of their own choosing as well as the right to collective bargaining and to engage in peaceful assembly, unless otherwise prohibited by law. In all cases, worker rights to open communication, direct engagement, and humane and equitable treatment must be respected. Suppliers acknowledge that workers and their representatives will be able to communicate openly to share ideas and concerns with management relative to management practices and working conditions without fear of reprisal, discrimination, harassment or intimidation. 

HEALTH AND SAFETY

1) Occupational Safety 

Supplier will operate a safe, healthy and respectful work environment.  Supplier will identify and assess worker potential exposures to safety hazards (e.g. electrical and other energy sources, chemical, fire, vehicles, and fall hazards) and will control these factors through proper design, engineering and administrative controls, preventative maintenance and safe work procedures including lockout/tagout, as well as ongoing safety training. Where hazards cannot be adequately controlled by these means, workers are to be provided with appropriate, well-maintained, personal protective equipment and educational materials regarding worker risks associated with these hazards. Supplier must also take reasonable steps to remove pregnant women and nursing mothers from working condition with high hazards, to remove or reduce any workplace health and safety risks to pregnant women and nursing mothers including those associated with their work assignments, as well as include reasonable accommodations for nursing mothers.

2) Sanitation, Food and Safety

Suppliers that provide housing or eating facilities will provide workers with ready access to clean toilet facilities, potable water and sanitary food preparation, storage, and eating facilities. Worker housing or dormitories provided by the Supplier, labor agent, or on behalf of the Supplier, are to be maintained in a clean, sanitary, safe and dignified manner, and provided with appropriate emergency egress, hot water for bathing and showering, adequate lighting, heat and ventilation, individually secured accommodations for storing personal and valuable items, and reasonable personal space according to ILO guidelines or local law, whichever is more stringent, along with reasonable entry and exit privileges. 

ENVIRONMENTAL

1) Environmentally Preferred Products 

Motorola Solutions values environmentally preferred products. We work with and encourage our suppliers to create products that are energy efficient, highly recyclable and contain significant amounts of recycled materials and low amounts of hazardous materials. To enable us to evaluate supplier components and products for environmental performance, suppliers must provide material disclosures as outlined in our controlled and reportable materials disclosure process, available at the following URL: https://www.motorolasolutions.com/en_us/about/company-overview/corporate-responsibility/governance-and-policies/materials-disclosure-process.html

2) Ozone-Depleting Substances 

 It is Motorola Solutions’ policy to eliminate from our products any components — including components provided by our suppliers — that contain or that are manufactured with a process that uses any Class I ozone- depleting substance. As outlined in the Internal Revenue Service's Publication 510, the U.S. government imposes an environmental tax on the sale or use of ozone-depleting chemicals and imported products containing or manufactured with these chemicals. Suppliers need to provide certification that products imported into the U.S. do not contain or are not manufactured with a process that uses any Class I ozone-depleting chemicals and imported products containing or manufactured with these chemicals. Supplier will provide certification (certification form accessible at the following URL: http://responsibility.motorolasolutions.com/index.php/downloads/dow005-ozonedepletingsubstances/) that products imported into the U.S. do not contain or are not manufactured with a process that uses any Class I ozone-depleting chemicals. 

3) Product Safety and Regulatory Compliance

Supplier will adhere to all applicable laws, regulations and customer requirements regarding prohibition or restriction of specific substances in products and manufacturing, including all applicable product safety, environmental, and recycling regulations and laws as well as labeling requirements for recycling and disposal.

4) Safety Data Sheets

Supplier will: (i) electronically provide safety data sheets in accordance to the Globally Harmonized System of classification and labeling of chemicals, or equivalent documentation for all applicable articles supplied to or for Motorola Solutions; (ii) for all chemicals supplied or imported into the United States, certify that the chemicals are listed on the Toxic Substances Control Act, 15 USCS §2601, et.  seq., chemical inventory, or are subject to an exemption specified in the safety data sheets; (iv) for  Products imported into the United States, provide Motorola Solutions with a completed and signed ODS Certification Questionnaire, available at: http://responsibility.motorolasolutions.com/index.php/downloads/dow005-ozonedepletingsubstances/, which may be updated from time to time; and (v) (for Products used as parts or components for Motorola Solutions’ products, including the packaging used with such products) any materials that accompany such products, comply with all provisions of Motorola Solutions’ Controlled and Reportable Materials Disclosure Process available at: https://www.motorolasolutions.com/en_us/about/company-overview/corporate-responsibility/governance-and-policies/materials-disclosure-process.html which may be updated from time to time. Supplier further certifies that all substances, preparations and articles provided to or for Motorola Solutions are in compliance with all applicable EU REACH Directive Requirements (1907/2006 and 1272/2008).

5) Energy Consumption and Greenhouse Gas Emissions 

Supplier will track and document energy consumption and relevant Scope 1 and 2 greenhouse gas emissions at the facility and/or corporate level. Supplier will look for cost-effective methods to improve energy efficiency and to minimize their energy consumption and greenhouse gas emissions. 

MANAGEMENT SYSTEMS 

1) Corporate Social and Environmental Policy Statement and Compliance 

Supplier will publish a corporate social and environmental responsibility policy statement affirming Supplier’s commitment to compliance and continual improvement, endorsed by executive management and posted in the Supplier’s facility in the local language and in all native languages of workers.  Upon Motorola Solutions' request, Supplier will provide a copy of its compliance policies, procedures, and documents and/or complete a Supplier Self-Assessment from Motorola Solutions’ designated industry-recognized third party Corporate Social Responsibility (CSR) program.  Supplier will obtain a subscription to the online system RBA-ON at https://www.rba-online.org/ and complete the ICT Supplier Self-Assessment within that system.    

2) Management System and Management Accountability and Responsibility 

Supplier will adopt or establish a management system that supports the content of this Code. The management system will be designed to ensure (a) compliance with applicable laws, regulations and customer requirements related to supplier's operations and products; (b) conformance with this code; and (c) identification and mitigation of operational risks related to the areas covered by this Code.  The management system should also drive continual improvement.  Suppliers of goods will have an Environmental Management System (EMS) in accordance with ISO 14001 or equivalent.  The EMS must be implemented and functioning.  Third party registration is strongly recommended, but not required.

Supplier will clearly identify senior executive and company representative[s] responsible for ensuring implementation of the management systems and associated programs. Supplier senior management will review the status of the management system on a regular basis.

3) Legal and Customer Requirements      

Supplier will implement a process to identify, monitor and understand applicable laws, regulations and customer requirements, including the requirements of this Code.     

4) Risk Assessment and Risk Management

Supplier will implement a process to identify the legal compliance, environmental, health and safety and labor practice and ethics risks associated with Supplier’s operations.  Supplier will also have a process for determination of the relative significance of each risk and implementation of appropriate procedural and physical controls to control identified risks and ensure regulatory compliance.

5) Training

Supplier will provide programs for training managers and workers to implement Supplier’s policies, procedures and improvement objectives and to meet applicable legal and regulatory requirements.

6) Worker Feedback, Participation and Grievance

Supplier will provide processes, including an effective anonymous grievance mechanism, to assess worker’s understanding of and to obtain feedback on practices and conditions covered by this Code as well as to foster continuous improvement. Suppliers will offer their workforce, as well as their customers and their sources in the supply chain, the ability to report, on a confidential basis, potential violations of this Code and other policies through a number of resources such as the Motorola Solutions’ Global EthicsLine.         

7) Supplier Audits and Assessments 

Supplier may be responsible for the cost of Corporate Responsibility and Labor Supplier audits for compliance up to $15,000 USD per calendar year. Supplier agrees to share audit results in RBA-ON with other RBA members who are also customers of the Supplier. Suppliers are expected to correct non-conformance issues identified during assessments in a timely manner. Additionally, if at any time Supplier fails to fully comply with the requirements or Motorola Solutions has reason to believe that Supplier has failed to comply with the requirements, then the Supplier is responsible for the cost of any additional inspections or audits to verify Supplier’s ongoing compliance with this Supplier Code of Conduct.

8) Corrective Action Process

Supplier will provide for timely correction of deficiencies identified by internal or external assessments, inspections, investigations and reviews.

9) Documentation and Records

Supplier will provide a process for creation and maintenance of documents and records to ensure regulatory compliance and conformity to requirements along with appropriate confidentiality to protect privacy.

10) Supplier Responsibility 

Supplier will communicate requirements of this Code to their suppliers and to monitor their supplier’s compliance to this Code.

11) Utilization of Small and Medium Business Concerns

If applicable, Supplier will comply with the provisions of U.S. Federal Acquisition Regulation (FAR) 52.219-8 pertaining to Utilization of Small Business Concerns, as well as any other state and local, small and other business utilization laws. Supplier will promote business opportunities to a diverse supply chain, in particular to small and medium business enterprises, social enterprises and supported businesses where practical and will promote fair, transparent and inclusive processes to support small and medium enterprises.

12) Equal Opportunity

If applicable, Supplier will comply with the provisions of FAR 52.222-21, 52.222-26, 52.222-35, 52.222-36, and 52.222-50 pertaining to Segregated Facilities, Equal Opportunity, Equal Opportunity for Veterans, Affirmative Action for Workers with Disabilities, and Human Trafficking. If applicable, Supplier will maintain, at each establishment, affirmative action programs required by the rules of the U.S. Secretary of Labor (41 CFR 60-1 and 60-2). https://www.motorolasolutions.com/en_us/about/careers.html

13) Supplier and subcontractors will abide by the requirements of 41 CFR §§60-1.4(a), 60-300(a) and 60-741.5(a). These requirements prohibit discrimination against qualified individuals based on their status as protected veterans or individuals with disabilities, and prohibit discrimination against all individuals based on their race, color, religion, sex, or national origin.

Moreover, these regulations require that covered prime Suppliers and subcontractors take affirmative action to employ and advance in employment individuals without regard to race, color, religion, sex, national origin, protected veteran status or disability. Motorola Solutions is an Equal Opportunity and Affirmative Action employer. Supplier will provide all services and products, as applicable, in compliance with Motorola Solutions’ EO/AA Policy statement, which is available at https://www.motorolasolutions.com/en_us/about/careers.html and which will be mailed or faxed to Supplier upon written request.

14) Imports and Customs

Supplier will comply with all import and customs laws, regulations and administrative determinations of the importing country. Supplier will comply with the security criteria of the importing country’s government security program. If Supplier is providing Products to be delivered to, or Services to support delivery to, the U.S., Supplier will comply with the security criteria of the U.S. Customs and Border Protection’s Customs-Trade Partnership against Terrorism (C-TPAT) Program (available on www.cbp.gov).

15) Export Restriction

If Supplier is the exporter of record for any shipments, Supplier will obtain all export authorizations from the U.S. government or other governments that may be required to lawfully make such shipments.

16) Supplier Diversity

If Supplier is located in the United States or is supplying Products to Motorola Solutions locations based in the United States, Supplier will track and report its Supply Chain’s spend with minority-owned, women-owned and disabled veteran-owned business enterprises located in the United States. Supplier and Motorola Solutions will agree on a goal for Supplier’s Supply Chain spend, based upon a percentage of Supplier’s total gross revenues under this Agreement. If requested by Motorola Solutions, Supplier will submit quarterly progress reports, in a format designated by Motorola Solutions, by the twenty-fifth day of the month following the end of each calendar quarter. All reports will be forwarded to the Motorola Solutions Supplier Diversity Group via email to: supplier.diversity@motorolasolutions.com.