Supplier Guide

Anti-corruption and anti-money laundering: suppliers must not participate in or condone corrupt practices in any form, including offering or accepting bribes, gifts or excessive hospitality, or facilitation payments. Suppliers must not facilitate or support money laundering. Suppliers must report any suspicious transactions and be vigilant for signs of money laundering.

Data protection and security: suppliers must respect privacy and civil liberties with regard to the collection, storage, use, or disclosure, as well as any other processing of personal data.

Financial responsibility / Accuracy of records: suppliers must conduct their business transactions transparently and accurately reflect them in financial reports and corporate filings. Suppliers must confirm that an adequate financial reporting control system is in place.

Information disclosure: suppliers must disclose financial and non-financial information in accordance with applicable regulations and industry practices.

Conflicts of interest: suppliers must ensure that their employees avoid and disclose situations where their financial or other interests conflict with their professional responsibilities or situations giving any appearance of impropriety.

Counterfeit parts: suppliers must minimize the risk of introducing counterfeit and/or diverted parts and materials into deliverables and comply with relevant technical regulations in the product design process.

Intellectual property: suppliers must respect intellectual property rights in force.

Export controls, trade and economic sanctions: suppliers must comply with applicable restrictions on the export or re-export of goods, software, services, and technologies, as well as applicable restrictions on trade involving certain countries, regions, companies or entities, and individuals.

Grievance mechanism: suppliers must establish an effective grievance mechanism, consistent with UN Guiding Principle 31, that allows concerns related to business ethics, human rights, or any other subject to be raised anonymously, confidentially, and without retaliation.

Remediation: suppliers must provide for or cooperate in remediation through legitimate processes where their business activities cause or contribute to negative environmental or social impacts.

Non-retaliation: suppliers must avoid any form of threat, intimidation, and physical or legal attack against stakeholders, including those exercising their legal rights to freedom of expression, association, peaceful assembly, and protest against their business activities.

Carbon neutrality: suppliers must strive to set science-based and time-bound emission reduction targets, as well as renewable energy targets consistent with the Paris Agreement, and implement measures that advance decarbonization across the entire value chain.

Promotion of environmental management throughout the life cycle: It is important to consider the overall environmental impact of our products throughout their lifetime, which is called life cycle assessment (LCA). SEAC's suppliers will play an important role in reducing LCA impacts. SEAC welcomes ideas and suggestions from suppliers regarding part design, material selection, or new manufacturing technologies that will reduce the LCA impact of our products. To promote LCA, SEAC asks its suppliers to implement initiatives to reduce the carbon footprint throughout the life cycle of delivered products.

Water quality, consumption and management: suppliers must reduce/minimize water consumption, efficiently reuse and recycle water with responsible wastewater discharge treatment, and prevent potential flood impacts from stormwater runoff, as required by and in accordance with applicable law.

Air quality: suppliers must regularly monitor and disclose, appropriately control, reduce/minimize, and, where possible, eliminate emissions contributing to air pollution, as required by and in accordance with applicable law. Suppliers must assess the cumulative impacts of pollution sources in their facilities and mitigate their pollution levels accordingly.

Responsible chemical management: suppliers must identify, reduce/minimize, or eliminate the use of regulated substances in manufacturing processes and finished products to ensure regulatory compliance. Companies must also be aware of any use of restricted substances in processes and finished products, and actively seek appropriate substitutes to maintain good product and environmental stewardship.

REACH and other chemical regulations: REACH is a European regulation that came into force in 2007, aimed at ensuring that the manufacture, placing on the market, and use of chemicals do not affect human health and the environment. For SEAC, all substances – alone, in mixtures, or in certain articles – that are produced, imported, or used in total quantities exceeding one ton per year must be classified and registered with ECHA (European Chemicals Agency). SEAC uses IMDS-based material data management globally as a tool to control chemical substances and vehicle recyclability rates.

Circularity: suppliers must promote closed-loop systems by supporting the use of sustainable and renewable natural resources while reducing waste and increasing reuse and recycling.

Animal welfare: suppliers must respect the five animal freedoms formalized by the World Organisation for Animal Health (formerly Office International des Épizooties or OIE) concerning animal welfare. No animal shall be raised and killed solely for use in an automotive product.

Biodiversity, land use and deforestation: suppliers must protect ecosystems, particularly key biodiversity areas, affected by their activities, and avoid illegal deforestation in accordance with international biodiversity regulations, including IUCN resolutions and recommendations on biodiversity.

Soil quality: where applicable, suppliers must monitor and control their impact on soil quality to prevent erosion, nutrient degradation, subsidence, and soil contamination.

Noise emissions: where applicable, suppliers must monitor and control industrial noise levels to avoid noise pollution.

Child labor and young workers: suppliers must respect the minimum age for admission to employment in their business activities and throughout their supply chain, in accordance with the ILO Convention on Minimum Age for Admission to Employment, and ensure that child labor is not tolerated in any form.

Wages and benefits: suppliers must provide their workers with compensation in accordance with applicable regulations and prevailing industry practices, i.e., compensation must be sufficient to cover basic needs and allow a decent standard of living for workers and their families, which implies compliance with minimum wages, overtime compensation, medical leave, and government-mandated benefits.

Working hours: suppliers must comply with local laws and collective agreements (where applicable) regarding working hours or with ILO standards on working time in the absence of relevant local regulations.

Modern slavery: suppliers must prohibit all forms of slavery, servitude, or forced labor, including human trafficking.

Ethical recruitment: suppliers must not mislead or defraud potential workers regarding the nature of the work, require workers to pay recruitment fees, and/or confiscate, destroy, conceal, and/or deny access to workers' passports and other government-issued identity documents. Workers must receive a written contract or employment notice at the beginning of their recruitment in a language they understand well, truthfully and clearly indicating their rights and responsibilities.

Freedom of association and collective bargaining: suppliers must allow workers to communicate openly with Management regarding working conditions and management practices, without fear of retaliation, intimidation, or harassment. Companies must respect workers' rights to associate freely, to join or not join unions, to bargain collectively, to seek representation, and to join workers' councils.

Non-discrimination and harassment: suppliers must not tolerate any form of discrimination or harassment in employment and occupation. In addition, they must provide equal employment opportunities regardless of the worker's or candidate's characteristics, such as age, gender, sexual orientation, gender identity, ethnic or national origin, disability, pregnancy, religion, political affiliation, union association, covered veteran status, genetic information, or marital status.

Women's rights: suppliers must provide equal employment opportunities and commit to ensuring equal pay for equal work.

Diversity, equity and inclusion: suppliers must develop and promote inclusive cultures where diversity is valued and celebrated, and where everyone is able to contribute fully and reach their full potential. Suppliers must encourage diversity at all levels of their staff and management, including on boards of directors.

Rights of minorities and indigenous peoples: suppliers must respect the rights of local communities to decent living conditions, education, employment, and social activities, as well as the right to Free, Prior, and Informed Consent (FPIC) for developments affecting them and the lands on which they live, with particular attention to the presence of vulnerable groups.

Land rights and forced eviction: suppliers must avoid forced eviction and land, forest, and water deprivation when acquiring, developing, or otherwise using land, forests, and waters.

Private or public security forces: suppliers must not mandate or use private or public security forces to protect their business project if, due to lack of training or control by the company, the deployment of security forces may result in human rights violations.

Workspace: suppliers must ensure a work environment that meets or exceeds local and national legislation on safety, occupational health, and fire safety, in addition to encouraging remote workers to understand and apply best practices.

Personal protective equipment: where applicable, suppliers must provide their personnel with necessary personal protective equipment (PPE) and ensure they understand how and when it should be used.

Emergency preparedness: suppliers must reduce occupational risks and develop an emergency preparedness and response plan.

Incident and accident management: suppliers must implement hazard and risk analysis systems to minimize/reduce the risk of incidents or accidents in the workplace. An investigation system must determine root cause, and a corrective action system must ensure that all permanent measures have been taken to reduce/minimize the risk of recurrence.

Contractors: suppliers must properly manage the health and safety of subcontractors within the company's extended supply chain. Suppliers must coordinate their procurement processes to identify hazards and assess and control risks arising from the contractor's business activity with the supplier, and the company's business activity that impacts contractor workers.

Due diligence: suppliers must conduct due diligence on their direct suppliers and subcontractors in accordance with OECD Guidelines on Due Diligence for Responsible Business Conduct, promote transparency and traceability, and do their utmost to implement, further down the supply chain, environmental, social, and governance (ESG) criteria as well as, in cascade, the Guiding Principles of this guide.

Responsible sourcing of raw materials and minerals: suppliers must responsibly source raw materials and minerals used in their products by developing a management system that promotes supply chain traceability and transparency, and by implementing due diligence measures in accordance with OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.

Suppliers must help SEAC comply with legislative requirements. SEAC requires tier 1 suppliers who use conflict minerals in their supply chain to complete the Conflict Minerals Reporting Template (CMRT) annually for parts and raw materials supplied to SEAC.