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Our Code Of Ethics
CPQ employees, clients and all vendors and factories at which we provide services shall strictly abide by this “Code of Ethics” and associated compliance principles as published in manuals, procedures and contracts. To ensure a clear understanding among CPQ, our employees, our clients and the vendors and factories where we provide services, we require that all related parties sign this document as a condition of employment, having services performed at your
factory or on your products, or having services performed on your behalf.
Should a factory or vendor at any time encounter a CPQ employee or representative who requests or implies he/she would like to receive a reward, gift, favor in return for, or dependent on, the outcome of any work, or any special benefit of any kind, the factory or vendor should notify CPQ management IMMEDIATELY by phone to Cindy Chen – Director of Compliance – Shenzhen Office: +86-755-27853986. A factory or vendor is never to fulfill such a request.
Integrity and Anti-bribery
1. CPQ holds all of our personnel to the highest level of integrity. All CPQ employees must read, understand, and agree to our Code of Ethics. Any employee found to be in violation of this code will meet with strict disciplinary action up to and including dismissal.
2. CPQ personnel are never to accept bribes, gifts or favors of any kind. Employees who have been made such an offer must report the occurrence to management immediately. Employees are to kindly refuse any small offerings such as individual cigarettes, tea, coffee, gum, etc., with the exception of water.
3. CPQ prohibits (a) the offering, giving, or accepting of a bribe in any form, including kickbacks on any portion of a contract payment, or (b) the use of other routes or channels for provision of improper benefits to, or receipt of improper benefits from customers, agents, contractors, suppliers, employees of any such party or government officials.
4. CPQ’s work will be carried out in a professional, independent and impartial manner at all times. All employees are to report all data, test results and other findings accurately and honestly no matter what the result, with no tolerance for any deviation from approved methods and procedures or the reporting of accurate results. CPQ employees and the factories/vendors at which CPQ provides services should always act in good faith. CPQ staff and management will never attempt to influence the result of a service rendered in the interests of company or personal gain (i.e. favoring a FAIL or HOLD result in order to encourage the demand for more services).
5. CPQ and its employees shall carry out its work in accordance with all laws, legislation, and regulations of the countries in which it operates.
6. CPQ encourages open and honest communication between staff and management at all times. We encourage all employees to speak freely about concerns, problems, and any issues they encounter in work or personal life about which they feel the need to discuss. In the event that an employee is unsure if there has been a violation of our Code of Ethics he/she must contact his/her team leader or top level management to consult. All communication thereafter will be kept confidential within reasonable bounds to protect the source of the information. All employees are required to inform management of any condition that creates a danger to the environment, poses health or safety hazards, or may be a violation of law or ethical conduct. CPQ provides facilities to enable confidential reporting of such conditions.
7. All CPQ work is subject to periodic audit by trained personnel regarding applicable laws, regulatory requirements and CPQ company policies and procedures. Corrective actions will be taken in a timely and effective manner and will be monitored, tracked and reviewed by CPQ management.
8. CPQ employees are prohibited from engaging in the following activities with personnel from any vendor or factory at which CPQ performs services (even if the employee engaged is not directly involved in those services), unless there is explicit and written approval provided by the CPQ Director of Compliance:
a) The consumption of any form of alcohol.
b) Attendance of KTV, Karaoke, sight-seeing, sport activity, or any leisure activity.
c) Any activity outside of the normal realm of the work that CPQ is providing.
9. While CPQ is a customer centered company, it will not tolerate any breach of ethics, law, or company policy in order to satisfy customer requirements, whether stated or implied. Any attempt to subvert this policy is to be reported to CPQ executive management either through normal channels or the confidential facility. Furthermore, CPQ will represent the interests of its clients’ only to the extent that the client’s interests are fair and reasonable. CPQ will not take responsibility for or attempt to impose on any factory or vendor the unreasonable or unfair demands of a client.
10. Vendor/Factory Disagreement – Vendors and factories have the right to respectfully disagree and provide explanation and/or evidence of their position in the case that they oppose a CPQ result or procedure. In such cases CPQ will make its best effort to record all such explanation/evidence and report it clearly back to the client. Furthermore in the case of disagreement the vendor/factory is encouraged to write down any remarks on the appropriate acknowledgment form which is later provided to the client. The vendor/factory may also contact directly with CPQ management to express such concern. However, the vendor/factory should at no time raise their voice with, forcibly argue, or in any way threaten a CPQ auditor or other employee in an attempt to express their discontent with a CPQ employee’s judgment or in an effort to affect the outcome of a service rendered.
Confidentiality
11. All data and information either provided by, or related to our client or client’s product is to be kept confidential at all times, other than what must be released in order to complete our job. Data is never to be given to any party outside of CPQ except, as necessary, to the factories and consultants who are directly related to providing quality services to our clients. CPQ shall treat all information received in the course of the provision of its services as business confidential to the extent that such information is not already published, generally available to third parties or otherwise in the public domain.
Conflict of Interest
12. CPQ and its employees will at no time involve itself with buyers or sellers in a way that creates a conflict of interest to our mission.
13. CPQ employees are prohibited from engaging in any personal business transaction with any factory, vendor, client or supplier with which CPQ does business or performs work with, unless there is explicit written consent from CPQ executive management. This includes but is not limited to buying from, selling to, providing services for or working on behalf of the factory, vendor, client or supplier.
Meal Policy
14. In most cases CPQ employees will take measures to eat on their own, not with the factory. In the case that the factory provides lunch for a CPQ employee on-site at a factory location (take-in meal) the factory may do so if it so desires, but at no more than the value of 20 RMB per CPQ employee. The factory is in no way requested or required to provide this service and CPQ employees are prohibited from requesting it. In the case that the factory takes an CPQ employee other than executive management off-site to dine, such an event MUST be approved beforehand by a phone call from the CPQ employee to a member of CPQ’s senior management. As mentioned above in this document, all CPQ employees are prohibited from consuming alcoholic beverages with any factory staff.
Transportation Policy
15. In most cases CPQ employees will rely on CPQ vehicles and public transportation to go to and from the factory. In some cases, and as reasonable, the factory may provide assistance with transportation such as pick-up from or drop-off at the local bus station, train station or airport. CPQ employees shall make no unnecessary or unreasonable demands on the factory for transportation assistance. In the instance that equally safe and secure transportation is available publicly (such as private car rental, bus, train, etc.) CPQ employees should seek such methods first. In regard to this policy factories and vendors should, however, always act in good faith and with the concern for the CPQ employee’s wellbeing, as CPQ employees are often traveling in remote and unfamiliar areas.
factory or on your products, or having services performed on your behalf.
Should a factory or vendor at any time encounter a CPQ employee or representative who requests or implies he/she would like to receive a reward, gift, favor in return for, or dependent on, the outcome of any work, or any special benefit of any kind, the factory or vendor should notify CPQ management IMMEDIATELY by phone to Cindy Chen – Director of Compliance – Shenzhen Office: +86-755-27853986. A factory or vendor is never to fulfill such a request.
Integrity and Anti-bribery
1. CPQ holds all of our personnel to the highest level of integrity. All CPQ employees must read, understand, and agree to our Code of Ethics. Any employee found to be in violation of this code will meet with strict disciplinary action up to and including dismissal.
2. CPQ personnel are never to accept bribes, gifts or favors of any kind. Employees who have been made such an offer must report the occurrence to management immediately. Employees are to kindly refuse any small offerings such as individual cigarettes, tea, coffee, gum, etc., with the exception of water.
3. CPQ prohibits (a) the offering, giving, or accepting of a bribe in any form, including kickbacks on any portion of a contract payment, or (b) the use of other routes or channels for provision of improper benefits to, or receipt of improper benefits from customers, agents, contractors, suppliers, employees of any such party or government officials.
4. CPQ’s work will be carried out in a professional, independent and impartial manner at all times. All employees are to report all data, test results and other findings accurately and honestly no matter what the result, with no tolerance for any deviation from approved methods and procedures or the reporting of accurate results. CPQ employees and the factories/vendors at which CPQ provides services should always act in good faith. CPQ staff and management will never attempt to influence the result of a service rendered in the interests of company or personal gain (i.e. favoring a FAIL or HOLD result in order to encourage the demand for more services).
5. CPQ and its employees shall carry out its work in accordance with all laws, legislation, and regulations of the countries in which it operates.
6. CPQ encourages open and honest communication between staff and management at all times. We encourage all employees to speak freely about concerns, problems, and any issues they encounter in work or personal life about which they feel the need to discuss. In the event that an employee is unsure if there has been a violation of our Code of Ethics he/she must contact his/her team leader or top level management to consult. All communication thereafter will be kept confidential within reasonable bounds to protect the source of the information. All employees are required to inform management of any condition that creates a danger to the environment, poses health or safety hazards, or may be a violation of law or ethical conduct. CPQ provides facilities to enable confidential reporting of such conditions.
7. All CPQ work is subject to periodic audit by trained personnel regarding applicable laws, regulatory requirements and CPQ company policies and procedures. Corrective actions will be taken in a timely and effective manner and will be monitored, tracked and reviewed by CPQ management.
8. CPQ employees are prohibited from engaging in the following activities with personnel from any vendor or factory at which CPQ performs services (even if the employee engaged is not directly involved in those services), unless there is explicit and written approval provided by the CPQ Director of Compliance:
a) The consumption of any form of alcohol.
b) Attendance of KTV, Karaoke, sight-seeing, sport activity, or any leisure activity.
c) Any activity outside of the normal realm of the work that CPQ is providing.
9. While CPQ is a customer centered company, it will not tolerate any breach of ethics, law, or company policy in order to satisfy customer requirements, whether stated or implied. Any attempt to subvert this policy is to be reported to CPQ executive management either through normal channels or the confidential facility. Furthermore, CPQ will represent the interests of its clients’ only to the extent that the client’s interests are fair and reasonable. CPQ will not take responsibility for or attempt to impose on any factory or vendor the unreasonable or unfair demands of a client.
10. Vendor/Factory Disagreement – Vendors and factories have the right to respectfully disagree and provide explanation and/or evidence of their position in the case that they oppose a CPQ result or procedure. In such cases CPQ will make its best effort to record all such explanation/evidence and report it clearly back to the client. Furthermore in the case of disagreement the vendor/factory is encouraged to write down any remarks on the appropriate acknowledgment form which is later provided to the client. The vendor/factory may also contact directly with CPQ management to express such concern. However, the vendor/factory should at no time raise their voice with, forcibly argue, or in any way threaten a CPQ auditor or other employee in an attempt to express their discontent with a CPQ employee’s judgment or in an effort to affect the outcome of a service rendered.
Confidentiality
11. All data and information either provided by, or related to our client or client’s product is to be kept confidential at all times, other than what must be released in order to complete our job. Data is never to be given to any party outside of CPQ except, as necessary, to the factories and consultants who are directly related to providing quality services to our clients. CPQ shall treat all information received in the course of the provision of its services as business confidential to the extent that such information is not already published, generally available to third parties or otherwise in the public domain.
Conflict of Interest
12. CPQ and its employees will at no time involve itself with buyers or sellers in a way that creates a conflict of interest to our mission.
13. CPQ employees are prohibited from engaging in any personal business transaction with any factory, vendor, client or supplier with which CPQ does business or performs work with, unless there is explicit written consent from CPQ executive management. This includes but is not limited to buying from, selling to, providing services for or working on behalf of the factory, vendor, client or supplier.
Meal Policy
14. In most cases CPQ employees will take measures to eat on their own, not with the factory. In the case that the factory provides lunch for a CPQ employee on-site at a factory location (take-in meal) the factory may do so if it so desires, but at no more than the value of 20 RMB per CPQ employee. The factory is in no way requested or required to provide this service and CPQ employees are prohibited from requesting it. In the case that the factory takes an CPQ employee other than executive management off-site to dine, such an event MUST be approved beforehand by a phone call from the CPQ employee to a member of CPQ’s senior management. As mentioned above in this document, all CPQ employees are prohibited from consuming alcoholic beverages with any factory staff.
Transportation Policy
15. In most cases CPQ employees will rely on CPQ vehicles and public transportation to go to and from the factory. In some cases, and as reasonable, the factory may provide assistance with transportation such as pick-up from or drop-off at the local bus station, train station or airport. CPQ employees shall make no unnecessary or unreasonable demands on the factory for transportation assistance. In the instance that equally safe and secure transportation is available publicly (such as private car rental, bus, train, etc.) CPQ employees should seek such methods first. In regard to this policy factories and vendors should, however, always act in good faith and with the concern for the CPQ employee’s wellbeing, as CPQ employees are often traveling in remote and unfamiliar areas.
