CORPORATE AND SOCIAL RESPONSIBILITY
CODE OF CONDUCT AND BUSINESS ETHICS
The following elements are the key principles that drive decisions and acceptable behaviour at Nanoptix: integrity, respect, diversity and inclusion, kindness, transparency and professionalism. These principles can be found in the statements and policies on our website and reflect our commitment to fight corrupt and unethical behaviours and practices as we conduct our business. We expect our employees, suppliers, and all our stakeholders to follow these principles. Nanoptix Inc. also provides a venue to anonymously report all policy, code-of-conduct and ethical infractions.
ANTI-BRIBERY AND CORRUPTION POLICY
Nanoptix has a zero-tolerance policy against all forms of bribery and corruption. We abide by the Criminal Code of Canada and the Corruption of Foreign Public Officials Act “CFPOA” which govern our business dealings both domestically and abroad. Our management team promotes a culture of compliance and transparency by following proper accounting practices and providing awareness to all employees, vendors, and business partners during the on-boarding process.
MODERN SLAVERY COMPANY POLICY AND STATEMENT
Nanoptix Inc. is committed to acting ethically and with integrity. As part of this commitment, Nanoptix has adopted a zero-tolerance approach to modern slavery – whether in the form of servitude; forced, bonded, or indentured labour; slavery; human trafficking or any other activity that amounts to an unreasonable restriction on the free movement of workers.
Our mission is to provide our customers with the most advanced, reliable ad innovative printing solutions and technologies in the market, while operating under the guiding principles of sustainability, human rights and providing opportunities for employees and suppliers to grow and succeed. In meeting our customers’ requirements, we operate procurement programmes through global supply chains, involving a wide network of suppliers and distributors where it is recognised that the potential exists for the human rights of individual workers to be violated.
This statement sets out Nanoptix’ approach to ensuring that modern slavery does not take place anywhere within our own business and, to the best of our ability, eliminate the risk of modern slavery occurring in our supply chains. The following steps have been, or are in the process of being, taken in this regard:
- The senior management team of Nanoptix Inc. has adopted this policy on Modern Slavery (the “Policy”), setting out the standards we expect from all our employees, contractors, suppliers, distributors, and other business partners. The Policy was first developed in 2021 and will be reassessed regularly as part of our ongoing compliance procedures. A copy of the Policy will be posted on our website.
- The standards of behaviour we expect under the Policy, have been specifically referenced in our employee manuals. The manuals are provided to all employees. Both the manuals and our Policy make specific reference to the Nanoptix Inc.’ reporting/suggestion system which is available to report alleged breaches of the Policy on an anonymous basis. Staff operating in key roles (including sales, operations, engineering and finance) are required to confirm on an annual basis that they understand and will comply with the requirements of the Policy.
- Nanoptix Inc. continues to make a formal commitment to uphold the human rights of workers (at all points in the supply chain) and to treat them with dignity and respect as understood by the international community. This includes concepts covered by the 2015 Modern Slavery Act such as “freely chosen employment” and treatment of young workers.
- We have conducted a further assessment of our employment practices and processes, which has re-confirmed that our activities are in line with the requirements of our Policy. We will continue to monitor compliance and implement modifications to our activities as required.
- Nanoptix Inc. engages its supplier base to ensure compliance with our core values. As part of our due diligence processes to verify compliance across a range of “corporate responsibility” items, we conduct on-site visits whenever possible, and require vendors to respond to detailed modern slavery questionnaires for all new relations. We will continue with this initiative and monitor our suppliers. We will ensure that this programme is expanded to cover new suppliers introduced as part of future acquisition activity. We have included specific terms and conditions in our purchase orders contractual arrangements against the use of forced, compulsory or trafficked labour, and we expect our suppliers to hold their own suppliers to the same high standards.
- Nanoptix Inc. intends to provide training and awareness on modern slavery to key personnel and employees interacting with vendors.
Nanoptix Inc. will continue to review its policies and processes, for the benefit of all our stakeholders, in order to raise standards with regards to operating in an ethical and sustainable manner across our supply chains.
DIVERSITY, EQUITY & INCLUSION POLICY
NANOPTIX is committed to fostering a work environment that is inclusive, equitable and diverse. One where we celebrate differences; where each employee is treated fairly and is respected for those differences; and where every team member has an equal opportunity to contribute to the success of our company and reach their full potential. This commitment stems from our senior leaders and includes every member of our team.
This policy applies to all current employees (full-time, part-time, contractual, permanent, and temporary) of NANOPTIX and it extends to our treatment of vendors and suppliers, contractors, visitors, customers and job applicants.
For the purpose of this policy and for interpretation by our employees:
Diversity refers to the differences in the make-up of our employees, including age, race, colour, national or ethnic origin, family or marital status, sex, gender identity or expression, sexual orientation, language, physical and mental ability, genetic characteristics, political affiliation, religion, socio-economic status, and other characteristics that make our employees unique.
Equity means ensuring fair access to all employment opportunities for everyone, regardless of diversity or difference. Equity addresses the effects of colonization, economic and social disparity, and injustices against marginalized groups. It also addresses systemic barriers to access and participation in employment opportunities, sometimes through practices that may not appear to be “equal”.
Inclusion is the process through which the company builds community and where employees and the organization at large experience the benefits of diversity. Inclusion provides everyone with the right to participate in our workplace.
As a company, NANOPTIX is committed to:
Creating an environment where the individual differences and contributions of all employees are recognized and valued.
Maintaining a work environment that promotes dignity and respect for every employee. Attracting and retaining a skilled and diverse workforce that best represents the talent that is available within the communities in which we operate.
Ensuring all selection-based criteria are appropriate and based on diverse skills, experience, and perspectives when both hiring new staff and promoting current team members. Selecting team members for new jobs or promotions based solely on merit. Regularly reviewing and updating as required all employment practices and policies that do not support the intention behind this policy – including, but not limited to: recruitment and selection; compensation and benefits; professional development and training; promotions; transfers; social and recreational programs; terminations; and the ongoing development of a work environment built on the premises of diversity, equity, and inclusion.
Reviewing diversity statistics on an ongoing basis to ensure representation of our communities within and at all levels of our workforce.
Complying with all associated legislation requirements. Encouraging respectful communication at all times.
Actively discouraging, and addressing through appropriate disciplinary action, any forms of intimidation, bullying, victimization, vilification, or harassment that result from or are contrary to the intentions of this policy.
Additionally, we expect our company leaders to:
Understand their role in promoting diversity, equity, and inclusion within our company. Act in accordance with this policy at all times.
Actively discourage and address any actions that are contrary to this policy.
And we require all employees to:
- Treat all employees with dignity and respect at all times. Act in accordance with this policy at all times.
- Identify and bring forward any situations that are contrary to this policy.
It is the expectation of NANOPTIX that all employees adhere to the commitments outlined above. Should you witness any breach of this policy, please advise Director of HR immediately.
If you are personally in violation of any commitments or the general intention of this policy, disciplinary action, up to and including termination, may be taken. The disciplinary action will be in direct correlation to the nature and extremity of the violation.
Any employee who files a valid complaint in accordance with this policy will not be subject to any form of retaliation either direct (e.g., dismissal or demotion) or indirect (e.g., being passed over for a promotion).
OUR COMMITMENT TO OUR EMPLOYEES
We take our responsibility towards our employees seriously; we promise to protect, support and prepare our employees for successful careers. Our efforts are focused on leading by example in areas such as workplace safety, health and wellness, diversity and inclusion and training and development. We strictly comply with applicable laws and regulations including but not limited to human rights, labour, employment, health and safety legislation. We believe in opportunity for all and are steadfast in our commitment to equal opportunity, the protection of human rights, and the prevention of human trafficking.
Environmental Policy Statement
Our policy is to reduce the impact of the company’s operations on the environment. The goal is to promote sustainability and environmental awareness at all levels of the company by:
- Complying with all applicable environmental legislation and sustainability commitments
- Preventing pollution and reducing consumption of resources through waste management strategies that promote waste minimisation re-use, recovery and recycling, as appropriate.
- Incorporating energy efficiency measures into the firm’s facilities and promoting efficient energy use in all areas of business activity
- Promoting and continuing to invest in technologies that provide alternatives to business travel.
- Adopting a procurement programme which takes into account the environmental impact of products and services and supports the purchase of sustainable products.
- Ensure our staff are aware of the environmental impacts of their work activities and encourage them through regular awareness to minimise those impacts.
- Promoting the protection and enhancement of biodiversity and ecosystems through employee awareness and stakeholder engagement.
- Reviewing our Environmental Policy and related objectives and targets, policies and practices on a regular basis.
CONFLICT MINERALS STATEMENT
As a global supplier of electronic and electrical components, Nanoptix is aware of our obligations with regards to laws and regulations regarding Conflict Minerals, specifically the Dodd-Frank Wall Street Reform and Consumer Protection Act, Section 1502.
Nanoptix does not directly source or process conflict minerals such as Tin, Tantalum, Tungsten, or Gold. Conflict minerals are contained in our products in the form of solder, or as a component in metal alloys. As part of a reasonable and responsible due diligence process, Nanoptix contacts our vendors and component suppliers within our supply chain and require them to answer conflict mineral surveys during onboarding and on an as needed basis to verify their continued compliance with the regulations.
Based on the information received thus far we declare that our products contain Conflict Minerals sourced from conflict-free areas.
Our Whistleblower policy is intended to enable employees and partners to raise serious concerns anonymously so that Nanoptix can recognize and correct inappropriate conduct. It is the responsibility of all officers and employees to report suspected violations of ethics or any laws or regulations that govern our operation.
To submit a report of a violation, please access the supplied form below and complete it to the best of your abilities. The report should be detailed enough to explain the violation and the situation in which it took place, including the location, parties involved, date, and any documentation that supports the report.
Any individual who submits a written complaint concerning ethical or legal violations must do so in good faith and have reasonable grounds for believing the report indicates a violation. Any report which can be proven to be unsubstantiated, malicious, or knowingly false will be viewed as a serious disciplinary offense.
These policies and statements will be reviewed on a regular basis to evaluate continued relevance and to monitor compliance.