Supplier Code of Conduct
Motorola Solutions’ Supplier Code of Conduct (Code) 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 in alignment with the UN Guiding Principles on Business and Human Rights and are consistent with the core tenets of the International Labour Organization's (ILO) Declaration on Fundamental Principles and Rights at Work and the United Nations Universal Declaration of Human Rights as well as the Organization for Economic Cooperation and Development (OECD) Guidelines for Multinational 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 requires the same of our suppliers. We are committed to maintaining a high-quality program through self-assessments, industry collaboration, capability building, benchmarking and stakeholder engagement. We offer training to our suppliers on topics covered under this Code.
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. The RBA Code of Conduct (RBA Code) is consistent with our Code of Business Conduct and provides additional clarity with regard to Labor, Health and Safety, Environmental, Ethics and Management Systems expectations of our suppliers. Motorola Solutions expects all suppliers to comply with the requirements in the RBA Code and the requirements in this Motorola Solutions Supplier Code of Conduct. We also expect our suppliers to adhere to our Human and Labor 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 compliance 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 a 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 a 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.
Along with expecting our suppliers to conform to the RBA Code, additional requirements for Supplier business conduct are:
LABOR
All Suppliers must document compliance with the requirements of the Labor section of the RBA Code, 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 slavery and trafficking in persons, b) slavery and 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 any 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 or ILO housing and safety legal requirements or explains any variance; 5) procedures to prevent agents, sub-agents and subcontractors at any tier from engaging in slavery, labor transfer programs, and/or trafficking in persons and to monitor, detect and terminate any agents, sub-agents, subcontractors, or subcontractor employees that have engaged in such activities.
Suppliers will prohibit harsh and inhumane treatment including violence, gender-based violence, sexual harassment, sexual abuse, corporal punishment, mental or physical coercion, bullying or public shaming or verbal abuse of workers; nor is there to be threat of any such treatment. Suppliers' disciplinary policies and procedures in support of these requirements shall be clearly defined and communicated to all workers.
Suppliers are prohibited from participating in labor-transfer programs, sponsored by any government, that coerce or force workers into designated positions (e.g. factories or agriculture).
ENVIRONMENT
1) Reducing Environmental Impact
Motorola Solutions recognizes our responsibility for minimizing environmental impact and is committed to reducing our Carbon Footprint through programs involving but not limited to: Greenhouse Gas (GHG) emissions, water emissions and solid waste. As part of our value chain, our Suppliers’ activities contribute to our overall Carbon Footprint. Therefore, Suppliers are required to establish Environmental Impact reduction plans which align with Motorola Solutions’ goals and also to report regularly on the status as it relates to Motorola Solutions’ operations, per our defined process.
Suppliers are also required to comply with Motorola Solutions’ process to report their metrics, including but not limited to the percentage of the Supplier’s emissions and waste attributed to their support of Motorola Solutions. Upon request, Supplier will obtain a subscription to a designated platform for data submission. Suppliers’ participation and progress towards their goals are considered when making sourcing decisions.
2) 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
3) Ozone-Depleting Substances and Air Emissions
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: (https://www.motorolasolutions.com/en_us/about/environmental-social-corporate-governance-esg/environment/ozone-depleting-substances.html) 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.
4) Safety Data Sheets
Supplier will: (i) electronically provide safety data sheets in accordance to the Globally Harmonized System of classification and labelling 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: https://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).
MANAGEMENT SYSTEMS
1) Corporate Social and Environmental Policy Statement and Compliance
Where required, 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 relevant 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. Upon request, Supplier will obtain a subscription to the online system RBA-ON at https://www.responsiblebusiness.org/tools/rbaonline/ and complete the Supplier Self-Assessment questionnaire within that system.
2) Audits and Assessments
Periodic self-evaluations will be conducted to ensure conformity to legal and regulatory requirements, the content of the RBA Code, and customer contractual requirements related to social and environmental responsibility. 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.
OTHER REQUIREMENTS
1) Utilization of Small and Medium Business Concerns
Supplier will promote business opportunities to a diverse supply chain, including 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. International Small and Medium businesses are defined by local guidelines. In the United States, small businesses are defined by the Small Business Administration and suppliers must 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.
2) 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 602). https://www.motorolasolutions.com/en_us/about/careers.html
3) 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.
4) 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).
5) 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.
6) Supplier Diversity
Supplier will track and report its Tier 2 spend with certified minority-owned, women-owned, disabled-owned, veteran-owned, LGBT-owned, small and medium business enterprises. Supplier and Motorola Solutions will agree on a goal for Supplier’s diverse spend, based upon a percentage of Supplier’s total gross revenue. If requested by Motorola Solutions, Supplier will submit quarterly spend reports through the Motorola Solutions Tier 2 Portal by the fifteenth day of the month following the end of each calendar quarter.
Questions or escalations should be directed to: supplier.diversity@motorolasolutions.com. Diverse suppliers must be certified by a third party, private or public, and must maintain current diversity certifications. Private certifications are issued by one or more of the following organizations: National Minority Supplier Development Council (NMSDC), Women’s Business Enterprise National Council (WBENC), National Veterans Business Development Council (NVBDC), National LGBT Chamber of Commerce (NGLCC), Disability: IN or applicable Global certifying organization. Public certifications include local, state, or federal government programs that verify minority, women, veteran, LGBTQ, or disability-owned status.
Misrepresentation of diversity or small business status is unacceptable and may be cause for contract cancellation.
7) Anti-Corruption / Bribery
The highest standards of integrity are to be upheld in all business interactions. Participants shall have a zero-tolerance policy to prohibit any and all forms of bribery, corruption, extortion and embezzlement.
Paying bribes, including the giving of cash, cash-equivalents, anything of value, or other means of obtaining undue or improper advantage are not to be promised, offered, authorized, given, or accepted. 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. Monitoring, record keeping, and enforcement procedures shall be implemented to ensure compliance with anti-corruption laws.
8) Responsible Sourcing of Minerals
In addition to the requirements in the RBA Code referenced above, Suppliers will ensure that the tin, tantalum, tungsten and gold used in components and products supplied are conflict-free. Suppliers must assure that the procurement of these metals does not either directly or indirectly benefit illegal armed groups through mining or mineral trading. Suppliers are to 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. To enable us to evaluate supplier components and products for conflict-free status, if requested, Suppliers must provide disclosures as outlined in the industry developed Conflict Minerals Reporting Template (CMRT).