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1.4 Ethics & Integrity

Integrity is the bedrock of competitive trust,trust. essentialIn forthe maintainingEMS strongindustry, relationshipswe withexist customersto protect and ensuringexecute theour securitycustomers' of the global supply chain.vision. This chapterrequires establishes the mandatory ethical framework,a formal Code of Conduct,Conduct and strict policies governing externalhow interactionswe thathandle allthe personnelsensitive mustdata follow.and intellectual property (IP) entrusted to us.

Code of Conduct and Conflict Management

The Ethical Mandate

All personnel are required to adhere to the organization's formal Code of Conduct. This is not optional; it is a condition of employment.

  • Core Principles: Honesty, transparency, compliance with all local and international laws, and the unwavering protection of company and customer confidential information.laws.
  • Whistleblower Protection: The organization maintains a confidential reporting mechanism for ethical violations. Retaliation against whistleblowers is strictly prohibited.

Conflict of Interest

Personnel must proactively disclose any situation that could compromise — or appear to compromise — their professional judgment.

  • Mandate: Any personal financial interest, familial relationship, or outside employment connected to a supplier, customer, or competitor must be formally disclosed.
  • Recusal: Individuals with a conflict of interest must recuse themselves from decision-making processes involving the conflicting party.

Customer Data Protection and IP Sanctity

Protecting customer data is our highest responsibility. A breach here is not just a security failure; it is an existential threat to the company.

The Stewardship Mandate

  • Definition: Customer data includes Intellectual Property (Gerbers, Firmware, Schematics), Commercial Data (Volumes, Pricing, Launch Dates), and Strategy.
  • Policy: We treat customer data with higher security standards than our own internal data.
  • Segregation: Customer data must be logically and physically segregated. Teams working on Competitor A must not have access to data from Competitor B (Chinese Wall protocol).

Data Handling Protocol

  • Need-to-Know: Access to customer technical files is granted strictly on a need-to-know basis. General access to the engineering drive is prohibited.
  • Encryption & Transfer: Customer data must never be transferred via unapproved channels (personal email, public cloud storage, chat apps). Only the secure, encrypted MES/PLM portals may be used.
  • No "Reference" Reuse: It is strictly prohibited to use one customer's design (e.g., a specific layout block or BOM choice) as a "reference" or "shortcut" for another customer's project.

Supplier and Supply Chain Ethics

The integrity of the supply chain is critical for preventing fraud, ensuring material quality,fraud and guaranteeingensuring reliable delivery.

Zero Tolerance for Corruption

  • Prohibition: Offering, soliciting, or accepting bribes, kickbacks, or gifts of significant value to influence purchasing or business decisions is strictly prohibited.
  • Policy:Fair Dealing: Gifts and entertainment must be nominal in value, transparent, and infrequent. Any exception requires explicit management approval.

Fair Dealing

  • Objective Criteria: Procurement and sourcingSourcing decisions must be based solely on documentedobjective suppliermetrics performance metrics—specifically (PPM (Quality) and, OTD, (On-Time Delivery)—and total cost of ownership. Personal relationships or favoritism areTCO), not validpersonal criteria.
  • Competition: Suppliers should be treated fairly and given equal opportunity to compete for business based on merit.relationships.

Intellectual

IP PropertySecurity (IP)with Protection

Intellectual Property is the lifeblood of the organization and its customers. Protecting it globally is a primary responsibility.

The NDA MandateSuppliers

  • Requirement:Sanitization: ConfidentialWhen information,sending includingdata componentto samples,suppliers schematics,for BOMs,quoting andor manufacturingfabrication, files,share mustonly neverthe minimum necessary. (e.g., Send only the PCB Gerber layer required for the stencil, not the full schematic).
  • NDA Mandate: No technical data package may be sharedreleased withto suppliersa or third partiessupplier without a fully executed Non-Disclosure Agreement (NDA) inon place.
  • Release Control: Only Design Engineering or authorized program management personnel have the authority to release technical data packages. Unauthorized sharing is a severe security breach.file.

Final Checklist

Mandate

Criteria

Verification Action

Code of Conduct

All personnel havePersonnel signed and acknowledged the Code of Conduct.Code.

Annual HR audit verifies 100%$100\%$ completion of ethics training and acknowledgment.compliance.

ConflictData DisclosureSegregation

PotentialCustomer conflictsdata ofis interestisolated; areno formallycross-customer disclosed and managed.access.

ReviewIT ofsecurity disclosure forms ensures appropriate recusals are in place.

Procurement Integrity

Supplier selection is driven by objective data (PPM, OTD).

Audit of purchasing recordsaudit confirms decisionspermission alignstructures withprevent suppliercross-team scorecards.access.

IP SecuritySanctity

NDANo requiredcustomer beforeIP sharingis anyreused technicalor shared without authorization.

Design review process checks for unauthorized "reuse" of blocks.

Supplier NDAs

Active NDAs verified for all vendors receiving data.

Document control system blocks RFQ release of files without confirmationNDA of active NDA.flag.

Anti-Corruption Control

ZeroPurchasing tolerancedecisions policyare fordata-driven bribery and kickbacks is actively enforced.(Scorecards).

InternalPeriodic auditsaudit reviewof expensepurchasing reportslogs andvs. supplier interactions for compliance.performance.