Nexans’s commitment to Corporate Social Responsibility (CSR)

Nexans Purchasing’s commitment to CSR

Nexans takes into account several criteria to award business to suppliers, the supplier CSR performance being one of the criteria.

Supplier’s CSR performance is notably based on the supplier’s CSR scorecard (certificate), issued by an independent CSR expert, internationally recognized (such as EcoVadis) as well as CSR audits on site, if any.

Nexans suppliers are encouraged to get their CSR performance assessed, certified by a CSR scorecard, and up-dated regularly.

Nexans reserves the status of preferred supplier to suppliers with a good CSR performance (among other strengths) and supports suppliers who improve their CSR performances in a continuous and sustainable way.

Nexans reserves the right to delist a supplier who would not respect the CSR principles.

Nexans Suppliers’ commitment to CSR

Nexans suppliers shall commit to the CSR principles described below, for all their activities and sites, and ensure that their own suppliers adhere to similar principles.

Nexans suppliers shall implement a continuous improvement CSR action plan. Areas for improvement are also highlighted in the supplier CSR scorecard. Nexans will be glad to support suppliers to identify actions and share the best practices.

1. Human Rights & Labour Standards

Forced & Child labour

Nexans suppliers shall eliminate all forms of illegal, forced, or compulsory labour and modern slavery, defined as the recruitment, movement, harbouring or receiving of children, women, or men using force, coercion, abuse of vulnerability, deception, or other means for the purpose of exploitation.

The term “children” refers to any person under the age of 16, or under the age for completing compulsory education, or under the minimum age for employment in the country, whichever is greatest. Workers under the age of 18 shall not perform work that is likely to jeopardize their health or safety, including night shifts.

All work must be voluntary, and workers shall be free to leave work at any time or terminate their employment.

Employers and agents may not hold or otherwise destroy, conceal, confiscate or deny access by employees to their identity or immigration documents, such as government-issued identification, passports or work permits, unless such holdings are required by law.

Workers shall not be required to pay employers’ or agents’ recruitment fees or other related fees for their employment. Deductions from wages as a disciplinary measure shall not be permitted.

Diversity & Fairness

Nexans suppliers shall respect equal opportunities rights and seek to provide their employees with a work environment free of discrimination or harassment of any kind whatsoever. Nexans suppliers’ employees are treated with fairness and dignity.

Labour relations

Nexans suppliers shall respect the right of associations, in compliance with local laws. Suppliers respect the right of employees to form or join the unions and workers’ organizations of their choice and to participate in collective negotiations.

Working hours & Training

Nexans suppliers shall comply with local legislation regarding working hours and minimum wages and strive to provide its employees with development programs and trainings.

Notwithstanding the provisions of the local law, a workweek should not be more than 60 hours per week, including overtime, except in emergency or unusual situations. Workers must be allowed at least one day off every seven days.

Health & Safety

Nexans suppliers shall deploy necessary resources to ensure the health and safety of their employees in their workplace. Risks linked to their activities shall be identified, evaluated and either eliminated or mitigated through a health and safety management plan, established on the basis of international standards.

Goods & Conflict minerals

Nexans suppliers who supply goods containing minerals extracted from mines, shall meet the standards of international responsible sourcing of minerals. That is of the upmost importance to prevent child labour, forced labour and the financing of armed groups in politically unstable areas.

Nexans suppliers shall make their due diligence on the origin of the minerals they use and ensure that all the suppliers in their supply chain (up to the mines), respect the CSR principles. They shall inform Nexans if any of the minerals integrated in the goods supplied fall into the category known as “conflict minerals”. If so, suppliers are to provide the legally required information.

2. Environment & Product

Environment

Nexans suppliers shall minimize impact on the environment of their activities and develop solutions that contribute to preserve, save water and energy.

Nexans suppliers shall implement environmental management principles, in order to minimize or avoid all hazardous releases to air, soil and water and greenhouse gas emissions. Suppliers shall avoid the use of hazardous substances. In the event no alternative is available, suppliers shall ensure their safe handling and disposal.

Product responsibility

Nexans suppliers shall incorporate environmental, health and safety criteria into their goods, in order to reduce their impact throughout their lifecycle while maintaining and/or improving their quality.

Nexans suppliers shall provide Nexans with all regulatory information and data relating to the goods, e.g. content of hazardous substances, safety, composition, etc.

Nexans values suppliers proposing goods with reduced environmental impact, focusing on:

• promoting circular economy (reduce resource consumption, use recycled and/or recyclable materials, optimize durability, repairability, recyclability…)
• minimising the use of hazardous substances and scarce resources
• reducing its carbon footprint during the whole life cycle

Waste

Nexans suppliers shall endeavour to reduce waste generated from their operations and ensure the disposal of such waste in a manner that is respectful to the environment. Waste must be identified, controlled, and treated.

3. Ethics and Business Conduct

Anti-corruption

Nexans suppliers shall ban corruption, bribes, kickbacks and other means of obtaining an undue or improper advantage. This includes the promising, offering, authorizing, giving or accepting of cash, fees, commissions, credits, gifts, favors, or anything of value that is either directly or indirectly provided in return for favourable treatment.

Data privacy

Nexans suppliers shall protect, including ensure IS security of, personal data of everyone they do business with, including suppliers, customers, consumers and employees (including IS security protection).

Suppliers shall comply with privacy and information security laws and regulatory requirements when personal information is collected, stored, processed, transmitted, and shared.

Gifts & Invitations

Pursuant to Nexans internal procedure:

• Nexans employees (including their families or relatives) must not accept gifts nor invitations. Sole exception are gifts offered purely as a courtesy, with a value lower than 50€, and no more than once a year from the same Nexans’ business partner.
• Nexans employees must not promise or offer gifts to our business partners (including their family or relatives) if the value exceeds 100€, and no more than once a year to the same business partner, unless duly authorized by a high-ranking manager. In which case, the authorized gifts and invitations must remain within the reasonable limits fixed by applicable laws and customary commercial practices.
• Nexans employees will never promise, accept or give gifts in cash.

Conflict of interest

A “conflict of interest” exists when an employee’s private interests supersede or interfere with his/her professional interests, or when an employee or a close relative might benefit personally from a transaction involving a supplier and Nexans. Nexans suppliers shall never take part in or seek to influence decision under circumstances that can create an actual or perceived conflict of interest. If Nexans suppliers become aware of a potential conflict of interest affecting Nexans, they will, without delay, notify Nexans.

Competition law

Nexans pursues to build a business relationship based on honesty, trust, and mutual interest, and select suppliers through open and competitive bidding. Nexans suppliers shall act in accordance with the principles of fair competition and apply standards of fair business.

Continuous commitment to CSR

Nexans’ objective is to build long-term relationships with its suppliers. Improvement in CSR area contributes to strengthen these relationships. A key element of the continuous improvement of Nexans own CSR performance is our work with our suppliers.

Whatever the current CSR performance of a supplier, Nexans values suppliers who are motivated to implement further actions for sustainable development. By signing this Charter, Nexans suppliers formally commit to respect the above-described CSR principles and to improve their CSR performance whenever possible.

As a supplier to Nexans, we hereby confirm that we have carefully read and understood the present Nexans Supplier CSR Charter. We commit to implement its principles towards our employees and to ensure that our own suppliers adhere to equivalent principles.

To illustrate the CSR principles in practical terms, the present Charter contains examples of indicators monitored by suppliers with good CSR performance

1. Human rights & Labour standards

• Are your workers provided with a writ ten employment agreement in their native language that contains a description of terms and conditions of employment?
• Do you have a whistle blowing line for harassment?
• Are your plants equipped with a time clocking device?
• Does your company monitor the number and severity of accidents? Is your machinery which presents an injury hazard to workers protected by barriers or physical guards?
• When applicable, does your company update the Conflict Minerals Reporting Template (CMRT) every year?

2. Environment

• Is your company ISO 14001 certified? Does your company monitor water/energy consumption, the use of non-renewable resources and/or greenhouse gas emissions?
• Does your company have a life cycle assessment process (ISO 14040)?
• Does your company measure its Carbon Footprint (ISO 14067) or comply with the Environmental Product Declaration (ISO 14025)?
• Have any of your products obtained a responsible production certification?
• Does your company monitor waste reduction and waste valorisation? Has your company taken action to reduce packaging?

3. Ethics and business conduct

• Does your company have internal procedures to ensure compliance with anti-corruption laws, such as the review and approval of all sales intermediaries?
• Does your company have an internal policy to approve and record personal expenses, gifts, hospitality and entertainment expenses?
• Has your company established a policy about meeting with competitors?
• Does your company have an ethics incident reporting system? Do your employees receive training, to enable them to identify a conflict of interest situation?

Nexans complies with international and local laws and regulations related to CSR.

In particular, French law on the Corporate Duty of Vigilance (Loi n° 2017-399 du 27 mars 2017), requires French companies like ours, to identify and prevent adverse human rights and environmental impacts resulting from our own activities and activities of our suppliers.

The following standards were used in preparing this CSR Charter. Nexans encourages its suppliers to refer to the below rules and international guidelines, as well as join initiatives related to CSR.

• Universal Declaration of Human Rights
• United Nations Convention Against Corruption
• United Nations Global Compact
• Eco Management & Audit System
• Ethical Trading Initiative
• ILO Code of Practice in Safety and Health
• ILO International Labor Standards
• ISO 14001; ISO 14040; ISO 14025; ISO 14067 and ISO 26000 https://www.iso.org/home.html
• OECD Guidelines for Multinational Enterprises
• OHSAS 18001
• United States Federal Acquisition Regulation
• SA 8000
• Social Accountability International (SAI)
• RoHS: EU Directive 2002/95/EC of 27 January 2003 on the restriction of the use of certain hazardous substances in electrical and electronic equipment
• REACH: consolidated version of Regulation (EC) 1907/2006 on the Registration, Evaluation, Authorisation and Restriction of Chemicals
• Data Protection: Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data
• National Fire Protection Association

Conflict Minerals:

• Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010
• OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict- Affected and High Risk Areas
• EU Regulation n°2017/821 of 17 May 2017 laying down supply chain due diligence obligations for Union importers of tin, tantalum and tungsten, their ores, and gold originating from conflict-affected and high-risk areas
• Rules laid down by the China Chamber of Commerce of Metals Minerals & Chemicals Importers & Exporters (CCCMC)

Nexans Code of Ethics & Business Conduct, available on our website