Code of responsible supplier

Code of responsible supplier

Code of responsible supplier

Mission

Goal of OJSC “BSW - management company of “BMC” holding” (later referred to as BSW) is safe, energy efficient and high-tech production of steel products.

To achieve this goal work with suppliers will be carried in the following direction:

  • ensure rational supply chain;
  • develop supply solutions in accordance with the needs and expectations of customers, regulating institution sand interested parties;
  • ensure long-term cooperation and risk reduction for our business, for the business of oursuppliers and in relation to the interests of otherparties concerned.

These goals will be achieved through the implementation of responsible supplier standards, collaboration, innovation and use of responsible supplier principles in our processes.

Introduction

Code of responsible supplier (the Code) of BSW includes principles of work with suppliers (including service providers) and requirements to them on observance of minimum acceptable ethical and environmental standards, and also human rights, norms of labor protection and safety measures. We encourage oursuppliers to work together to reveal shortcomings and continuously improve the effectiveness of our responsible supplier program. We hope that the Code will contribute to the implementation of high standards of business by our suppliers.

BSW defines a supply chain as the goods and services that are purchased and used in the production process. These include primary raw materials (scrap, HBI, ferroalloys, various alloys, electrodes, refractories, non-ferrous metals, etc.), energy, buildings and structures, capital expenditures, training and repair services, transportation and logistics. The principle of a responsible supplier is a key principle in BSW approach to procurement and it is taken into account along with other factors such as price and quality.

When fulfilling its obligations under the contracts, BSW does not pay, does not offer to pay, and does not allow payment of any funds or valuables, directly or indirectly, to any persons in order to influence actions or decisions of those persons to obtain any unlawful advantages or other unlawful purposes.

When fulfilling its obligations underthe contracts, BSW does not carry out actions qualified by the current legislation, such as giving a bribe, receiving a bribe, mediation in bribery, accepting illegal remuneration, commercial bribery, as well as actions that violate the requirements of current legislation and international acts on counteringthe legalization (laundering) of proceeds from crime.

Sphere of activity

The Code applies to all suppliers (including service providers) and their affiliated companies, as well as to all products and services purchased by the enterprise. We encourage our suppliers to apply the provisions of the Code in their supply chain. We will approve actions of the suppliers aimed to comply with the provisions of the Code.

Obligations to the suppliers

To follow the Code OJSC “BSW - management company of “BMC” holding” undertakes to:

  • cooperate, i.e. interact with the suppliers to improve ethical, environmental and social standards, including observance of human rights, occupational safety and health norms.

This interaction can include joint assessments, such as visits to production facilities to determine compliance with the Code.

  • support, i.e. assist suppliers in identifying activities that do not meet the requirements of the Code, and work towards timely improvement of production conditions;
  • identify priorities, i.e. focus on those elements of the supply chain where risk of non-compliance with the Code is the highest and where maximal improvements can be achieved;
  • respect, i.e. conduct business with suppliers honestly, objectively, transparently and professionally.

This includes compliance with the same standards of work both for the employees of suppliers located on the territory of BSW within the framework of concluded contracts, the same standards and regulations in the field of human rights and labor relations as forthe company's own personnel (including with regard to personal data protection).

  • promote, i.e. fight for responsible practices in supply chains;
  • inform and train, i.e. ensure that all employees of the company are aware of the  Code, as well as provide appropriate training to all persons (including with regard to personal data protection) responsible for procurement;
  • improve,  i.e.   revise,   where  appropriate,  standards  to  ensure  that procurement practices are consistent with our vision of the responsible supplier.

BSW requires from its suppliers to approve and apply the company's policy regarding  compliance with ethical business  standards, as well as the adoption of the principles   ofthe Code of Ethics and anti-corruption principles.

Expectations from the suppliers

We encourage our suppliers to cooperate with BSW to identify opportunities for further improvement of health and safety, human rights, ethics and environmental standards in the supply chain.

Labor and health protection

BSW carries out systematic and constant work on elimination of in juries and accidents, and also on labor protection and health at workplaces and outside of the enterprise. This is confirmed by the Corporate Policy and procedures for labor protection and safety that support promotion of our philosophy of environmentally safe and hi-tech production of steel products. BSW requires from its suppliers compliance with health and safety standards in order to avoid injury of employees and customers at the working place.

Respecting of human rights

BSW respects human rights of its employees, employees of suppliers located on the territory of BSW within the framework of concluded contracts, and the local population and encourages its suppliers to do the same, which is reflected in the company's Code of Ethics. BSW encourages suppliers to improveand implement human rights standards and norms in their own activities and those of their suppliers.

The supplier shall at all times comply with the strictest requirements of applicable legislation (including the ones with regard to personal data protection), human rights policy or this Code. If local law prohibits supplier to follow certain aspects of this Code or human rights policy, the supplier shall comply with local law and make every effort to respect human rights.

Ethics

BSW adheres to the principles of honest, ethical and transparent business conduct based ontrustand respect.

BSW does not purchase services or materials that do not meet the requirements ofnationalorinternational lawsand conventions.

BSW uses only raw materials of legal and environmentally safe origin and will not purchase raw materials from suppliers whose activities are contrary to these principles.

Environment protection

BSW is committed to make steel production more environmentally friendly. To achieve this goal, the company implements its own and best international practices to develop more environmentally friendly production processes and reduce pollution ofthe environment. We strive to work with suppliers that share our principles and carry on their activities in accordance with the strictest requirements to environment protection, including rational use of resources, preservation of biological variety, reduction ofcostsandprocessingofsecondary raw materials.

BSW requires from its suppliers to use effective standards, processes and procedures to protect the environment and conduct business in accordance with the Corporate Policy ofthe enterprise in terms of environmental protection.

Documentation and control

BSW offers to itssuppliers to:

  • fill in the information questionnaire ofthe supplier based on the Code;
  • provide BSW or its representatives copies of all relevant documents, assist and make reasonable efforts to ensure that suppliers provide them (including suppliers of services);
  • demonstrate measures taken by suppliers to meet the requirements ofthe Code.

This Code is an integral part of the supplier relationship management system and the supplier evaluation procedure. When assessing compliance of the activities ofthe supplier to the requirements ofthe Code BSW will use approach based on risk assessment. Monitoring can be carried out when visiting the production facilities of the supplier, as well as monitoring the implementation of corrective measures. BSW will work with its suppliers in orderto eliminate detected non-conformities in their operations. BSW reserves the right to refuse from services ofthe suppliers in line with the law ofthe Republic of Belarus in place who do not comply with the requirements of the Code or unable to provide or implement the improvement plan.

General Director OJSC “BSW-management company of “BMC” holding” Dmitriy Korchik, 15.02.2024