Sparton is committed to the highest standards of product quality, business ethics, and corporate compliance. It is Sparton's policy to deal only with organizations that have ethical standards compatible with its own. A basic component of Sparton's policy on business conduct is, of course, compliance with law. Sparton and its employees are subject to and must comply with all applicable laws of the United States and the countries in which they do business. While some Sparton policies are based on the requirements of applicable law, others embody our company's broader commitment to ethical business conduct. As a result, all suppliers and the Sparton employees who work with suppliers are expected to conduct themselves with the highest standards of honesty, fairness, and personal integrity and avoid even the perception of impropriety or conflict of interest.
To ensure that our relationships with suppliers meet and support these standards, all Sparton suppliers are expected to acknowledge their agreement with the Sparton Procurement Policy On Business Ethics and apply this policy in all dealings with Sparton.
1. Sparton suppliers shall comply with all laws, regulations and policies applicable to them and their dealings with Sparton, including all applicable government contractual requirements which flow down to the supplier through its contracts with Sparton. This includes, but is not limited to Small Business rules and regulations, Affirmative Action and Equal Employment Opportunity rules and regulations, and the rules regarding suspension and debarment of companies from doing business with the U.S. Government.
2. No supplier, or its representatives or employees, shall offer to any Sparton employee a kickback, favor, gratuity, entertainment or anything of value to obtain favorable treatment from Sparton. Therefore, suppliers should refrain from offering anything other than modest promotional items to Sparton. Sparton employees are similarly prohibited from soliciting such items. This prohibition extends to immediate family members of both suppliers and Sparton employees. As long as a gift is not intended to obtain favorable treatment for the suppliers and does not create the appearance of a bribe, kickback, payoff or irregular type of payment, Sparton employees are not prohibited from accepting the gift if: (1) it is $20 or less in value, (2) public disclosure would not embarrass Sparton, (3) acceptance is consistent with Sparton business practices and (4) acceptance of the gift does not violate any applicable law. In no event may the total amount of gifts from any one Supplier to Sparton employees, cumulatively, exceed $50.00 in one calendar year. Furthermore, Sparton employees are prohibited from accepting IPO stock for Sparton suppliers.
3. No supplier shall enter into a financial or any other relationship with a Sparton employee that creates a conflict of interest for Sparton. A conflict of interest arises when the material personal interests of the Sparton employee are inconsistent with the responsibilities of his/her position with the company. All such conflicts must be disclosed and corrected. Even the appearance of a conflict of interest can be damaging to Sparton and to the supplier and therefore must be disclosed and approved by Sparton management.
4. Sparton suppliers shall not engage in collusive bidding, price fixing, price discrimination, or other unfair trade practices in violation of federal or state antitrust laws.
5. Sparton suppliers will supply products that conform in all respects with the requirement of their contracts with Sparton including, in particular, all applicable quality requirements.
6. Sparton employees are expected to act fairly at all times. This includes avoiding doing anything that might create the appearance that customers or suppliers have "a friend at Sparton" who could exert improper influence on their behalf.
7. Honesty is an integral part of ethical behavior, and trustworthiness is essential for strong, lasting relationships. Sparton employees may not misrepresent themselves or the company to anyone. We expect the same of our suppliers.
8. Because of its size, Sparton gains some legitimate advantages such as those derived from large-scale buying and selling. However, Sparton employees should never use Sparton's size to intimidate, threaten, or slight another person or organization.
9. Sparton respects the confidentiality of proprietary information received from bidders and suppliers, and Sparton employees will not improperly use or disclose such information. Likewise, when suppliers have access to information that is proprietary to Sparton, we expect that they will protect and maintain its confidentiality as well.
10. Employee participation in outside activities should not infringe on an employee's ability to do his or her assigned Sparton job and may require advance approval. Sparton employees may not, as a general rule, be a supplier to Sparton or work for a potential supplier while employed by Sparton.
Sparton suppliers shall promptly notify the Sparton Director of Corporate Contracts & Compliance at (386) 740-5472 of any known or suspected improper behavior by suppliers relating to their dealings with Sparton, or any known or suspected improper behavior by Sparton employees.
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