Supplier Code of Conduct
PURPOSE
Sustainable and responsible development across our supply chain is a key pillar of this commitment. This Supplier Code of Conduct (“Code”) applies to all suppliers and vendors doing business with TCR. It sets out the core principles, values, and expectations that TCR requires from all its suppliers. While we recognize that many suppliers have their own codes of conduct, this document aims to clearly communicate the standards we expect from our business partners and serve as a reference point in our qualification processes.
SCOPE OF THE CODE OF CONDUCT
This code of conduct applies to all TCR group suppliers
CODE OF CONDUCT CONTENT
We expect our suppliers not only to comply with the standards outlined in this Code, but also to promote these standards among their employees, as well as their own suppliers and subcontractors. The overarching objective of this Code is to drive continuous improvement throughout our supply chain in alignment with ESG principles and business ethics principles, while supporting TCR’s ambition to remain a leading provider of airport equipment solutions. TCR implements due diligence processes and may conduct audits to assess supplier compliance with this Code. Adherence to and engagement with this Code also supports joint efforts to identify, assess, and mitigate ESG-related risks.
As a Supplier, you are expected to acknowledge and agree with:
Environment:
Reduce environmental impact:
Suppliers are expected to actively minimize the environmental impact of their operations by continuously improving environmental protection measures and adopting more sustainable practices. This includes reducing the use of natural resources, hazardous materials, energy, and water, as well as minimizing waste, CO₂ emissions, and other greenhouse gases.
Manage security:
Suppliers must ensure the protection of health and safety for all stakeholders involved in their operations. While manufacturing products or delivering services, suppliers must take necessary precautions to safeguard the well-being of others and ensure that the materials and products used are appropriate in origin, quality, and suitability. Suppliers granted access to TCR premises, or of TCR’s customers or business partners, are required to adhere to all applicable health and safety policies and guidelines.
Social
Human rights and fundamental rights at work
Suppliers must respect and uphold internationally recognized human rights and labor standards in all their operations, in line with the United Nations Guiding Principles on Business and Human Rights, the UN Universal Declaration of Human Rights, and the International Labour Organization’s (ILO) Declaration on Fundamental Principles and Rights at Work. This includes, but is not limited to, ensuring:
Freedom of association and the effective recognition of the right to collective bargaining;
The elimination of all forms of forced or compulsory labor, including modern slavery and human trafficking;
The effective abolition of child labor, in accordance with minimum age and hazardous work restrictions;
The elimination of discrimination in respect of employment and occupation.
Suppliers are also expected to comply with applicable national laws and international due diligence legislation, such as the EU Corporate Sustainability Due Diligence Directive, the German Supply Chain Due Diligence Act (LkSG), and any other relevant legal requirements, and to take proactive steps to identify, prevent, and mitigate adverse human rights impacts in their operations and value chains.
Employment Practices
Working Hours and Fair Remuneration
Suppliers must ensure that all employees work in compliance with applicable laws governing working hours, including overtime regulations and rest periods. No employee shall be required to work more than the maximum hours permitted by local labor laws. All employees must be compensated fairly, at a minimum in accordance with applicable legal wage standards, including overtime pay where required, and receive all legally mandated benefits.
Equality, Diversity, and Non-Discrimination
Suppliers shall provide a workplace free from all forms of discrimination and ensure equal opportunity in all aspects of employment. Discrimination on the basis of race, ethnic or social origin, nationality, religion or belief, gender, gender identity or expression, sexual orientation, age, disability, marital status, political opinion, union membership or any other status protected by applicable law is strictly prohibited. Hiring, promotion, compensation, and access to training must be based on ability and performance.
Respect for Personal Dignity and Humane Treatment
Suppliers are expected treat all workers with respect and dignity. Any form of abuse, harassment, intimidation, or inhumane treatment, including physical, verbal, psychological, or sexual abuse, is strictly prohibited. This includes threats of violence, coercion, bullying, or any degrading treatment of employees or their family members. Disciplinary practices must be fair, transparent, and in accordance with applicable law and international standards.
Health and safety at work
Suppliers are expected to ensure a safe, healthy, and hygienic working environment for all employees, in accordance with applicable health and safety laws and internationally recognized standards. This includes, but is not limited to, the provision of appropriate and properly maintained personal protective equipment (PPE), machine safeguarding mechanisms, fire prevention and emergency response systems, adequate lighting, ventilation, and temperature control. Suppliers must also ensure employees have unrestricted access to clean drinking water, sanitary restroom facilities, and first aid supplies. Proactive measures must be taken to prevent workplace accidents and occupational illnesses, including regular risk assessments, safety training, and emergency preparedness drills.
Governance
Business integrity
Anti-Bribery and Corruption
Suppliers shall not engage in, tolerate, or benefit from any form of bribery, corruption, extortion, or fraud.
This includes offering, promising, giving, requesting, or accepting any financial or other advantage to secure or reward improper conduct or gain an unfair business advantage. Gifts, hospitality, entertainment, and charitable contributions must never be used to influence decision-making or circumvent ethical business practices.
Suppliers must not offer or provide lavish gifts, excessive hospitality, or entertainment to any TCR employee, representative, or business partner in an attempt to improperly influence business decisions or gain preferential treatment. Any such gestures must be modest, infrequent, and compliant with applicable laws and TCR’s internal policies. Suppliers are expected to establish and enforce internal policies and controls to prevent corruption and ensure compliance with all applicable anti-corruption laws and regulations, including but not limited to:
The U.S. Foreign Corrupt Practices Act (FCPA)
The UK Bribery Act 2010
The OECD Anti-Bribery Convention
The EU Directives on combating corruption in the private and public sectors
Any applicable local anti-bribery and corruption laws
Anti-Trust and Fair Competition
Suppliers must comply with all applicable antitrust and competition laws. They shall avoid anti-competitive behaviour such as price-fixing, bid-rigging, market sharing, or abuse of dominant position. Suppliers are also expected to avoid any actual or perceived conflicts of interest in their dealings with TCR and its affiliates. Applicable legal frameworks include:
EU Competition Law (Articles 101 and 102 TFEU)
U.S. Sherman Antitrust Act
National competition regulations in the jurisdictions where the supplier operates
Anti-Money Laundering (AML)
Suppliers must not participate in, facilitate, or be complicit in money laundering or financing of terrorism. Suppliers are expected to implement risk-based due diligence, maintain accurate financial records, and promptly report any suspicious transactions to the appropriate authorities.
Compliance should be aligned with international AML frameworks, including:
The EU Anti-Money Laundering Directives (AMLD)
The Financial Action Task Force (FATF) Recommendations
The U.S. Bank Secrecy Act (BSA) and Patriot Act
Relevant national AML legislation
Suppliers are expected to act honestly and transparently in all business dealings, including interactions with customers, business partners, and public authorities. Misrepresentation, deception, concealment of material facts, and unethical conduct are strictly prohibited.
International trade and sanctions
Suppliers are expected to fully comply with all applicable international, national, and regional trade laws, including but not limited to export control regulations, customs requirements, and economic and trade sanctions (such as those imposed by the European Union, the United States, the United Nations, and other relevant authorities). Suppliers must not, directly or indirectly, engage in any transactions or business relationships with individuals, entities, governments, or organizations that are designated on applicable sanctions lists, or that are owned, controlled by, or acting on behalf of such sanctioned parties.
Suppliers are expected to implement robust internal controls, due diligence procedures, and screening mechanisms to prevent any dealings that would violate these trade laws or expose TCR to legal or reputational risk.
Protection of information and personal data
Suppliers shall not infringe any intellectual property rights and use confidential information in an appropriate manner. Suppliers commit to protect all personal data that they collect from TCR or process on TCR’s behalf in accordance with obligations under applicable data protection laws.
Tax evasion
TCR Suppliers will:
Not engage in any activity, practice or conduct which would constitute either:
A UK tax evasion offence within the meaning of section 45(4) of the CFA 2017 ("UK Tax Evasion Offence");
A foreign tax evasion offence within the meaning of section 46(5) of the CFA 2017 ("Foreign Tax Evasion Offence");
A facilitation of UK Tax Evasion Offence within the meaning of section 45(5) of the CFA 2017;
Or facilitation of Foreign Tax Evasion Offence within the meaning of section 46(6) of the CFA 2017; or
Failure to prevent a Facilitation Offence within the meaning of sections 45 or 46 of the CFA 2017.
Have and maintain in place such policies and procedures reasonable to prevent the facilitation of tax evasion by another person related to the Supplier, as defined within the Criminal Finances Act 2017).
Whistleblowing
Suppliers shall establish accessible and secure mechanisms for their employees and other stakeholders to confidentially report concerns regarding unlawful, unethical, or otherwise improper operational or business practices. This includes violations of laws, regulations, internal policies, or fundamental company values. All reported concerns must be duly recorded, investigated, and resolved in a timely and transparent manner. Suppliers must strictly prohibit and prevent any form of retaliation against individuals who report such concerns in good faith.
Additionally, any complaints or concerns involving the conduct of TCR or its representatives may also be
submitted directly through TCR’s official reporting mechanisms, which are available on TCR’s website.
This Supplier Code of Conduct outlines TCR’s expectations with respect to the ethical, legal, social, and environmental standards that all suppliers and vendors must uphold when conducting business with TCR and its affiliates. It is intended to serve as a general framework for responsible business practices and shall be read in conjunction with, and in addition to, any specific requirements set forth in:
TCR’s Code of Conduct and any other relevant corporate policies
Any request for proposal, request for quotation, or procurement-related documentation issued by TCR; and
Any agreement, contract, or purchase order entered between TCR and the supplier or vendor.
In the event of any inconsistency between this Code and a specific contractual obligation, the stricter or more protective provision for TCR shall prevail. Any unilateral deviation from or exclusion to the principles set forth in this Supplier Code of Conduct shall be deemed null and void unless expressly agreed in writing by TCR. Failure to comply with the obligations set forth in this Supplier Code of Conduct may result in immediate termination of the business relationship.
Approved and accepted by
Jason Watson, CEO Peter Grypdonck, COO
Acknowledgment and Agreement
By engaging in business with TCR and the signature herein, the supplier hereby acknowledges and agrees to comply with the principles and requirements outlined in this Supplier Code of Conduct. The supplier further agrees to promote and ensure adherence to these standards within its own operations, as well as across its supply chain, including subcontractors and business partners.
Compliance with this Code forms an integral part of TCR’s ongoing supplier qualification, performance monitoring, and relationship management processes. TCR reserves the right to verify compliance through assessments, audits, or other due diligence measures.