Code of ethics and conduct for suppliers, subcontractors and partners

SFP GROUPE is a Senegalese industrial enterprise project in the process of incorporation, driven by the professional experience of its founder in the mining, industrial and energy sectors.

SFP is preparing a service offering including notably industrial welding, boilermaking, piping, mechanical welded fabrication, metal structures, installation and industrial maintenance.

SFP intends to develop its future business relationships on the following principles:

• integrity and transparency;
• protection of health and safety;
• quality and traceability of work;
• respect for people;
• protection of the environment;
• fair competition;
• development of skills and local content.

This Code establishes the rules of conduct expected of suppliers, subcontractors, consultants, representatives and partners called upon to work with SFP GROUPE.

This Code is based on generally recognised principles regarding human rights, decent work, occupational risk prevention, environmental protection and responsible business conduct.

The principles of ISO 9001, ISO 14001 and ISO 45001 standards may serve as references for good practice depending on the nature of the activities and the level of risk of the services.

The publication of this Code does not mean that SFP GROUPE or its suppliers hold these certifications.

The Code supplements laws, regulations, contracts and clients' specific requirements. It does not replace them.

Where a legal, regulatory or contractual provision imposes a stricter requirement, that requirement must be complied with.

This Code applies to any natural or legal person who supplies or plans to supply SFP GROUPE with:

• materials or consumables;
• equipment or spare parts;
• industrial works;
• labour;
• technical or professional services;
• transport, rental or maintenance services;
• representation, consulting or intermediation services.

It applies to the various stages of the business relationship, notably:

• pre-selection;
• consultation;
• negotiation;
• contracting;
• execution of works;
• delivery;
• acceptance;
• closing of the service.

The supplier remains responsible for the persons, representatives and subcontractors it mobilises to carry out its obligations.

Suppliers, subcontractors and partners must:

• comply with the laws and regulations applicable to their activities;
• hold the necessary authorisations, insurance, licences and qualifications;
• meet their tax, social and administrative obligations;
• provide accurate, complete and verifiable information;
• inform SFP of any suspension, expiry or change to an important authorisation;
• report any situation likely to prevent the correct execution of a service.

The falsification of certificates, qualifications, invoices, professional references, inspection reports or any other document is prohibited.

A supplier must never present SFP as a client, partner or company that has approved its products or services without written authorisation.

Suppliers must respect the dignity, safety and fundamental rights of all persons involved in their activities.

In particular, they must:

• prohibit forced labour, servitude and human trafficking;
• respect the legal minimum age for employment;
• prohibit any form of child labour;
• guarantee working conditions that comply with applicable legislation;
• respect rules on wages, working hours, rest periods and leave;
• allow workers to keep their personal documents;
• protect workers from violence, intimidation, humiliation and harassment;
• respect legally recognised rights to representation and collective dialogue.

No worker shall be penalised for refusing, in good faith, to perform a task that presents a serious and imminent danger.

Decisions relating to recruitment, pay, training, assignment and career progression must be based on competence, qualifications and job requirements.

Any discrimination based on, among other things, origin, nationality, skin colour, sex, age, disability, religion, family status, opinions or union membership is prohibited.

Suppliers must promote a respectful professional environment and ensure fair treatment for comparable work.

Health and safety are essential conditions of any collaboration with SFP GROUPE.

Before starting any activity, the supplier must:

• identify hazards;
• assess risks;
• establish preventive measures;
• assign competent and authorised personnel;
• verify the compliance of equipment;
• provide appropriate personal protective equipment;
• communicate instructions to the workers concerned;
• obtain the necessary permits and authorisations.

Particular attention must be paid to:

• welding, cutting and grinding work;
• hot work;
• lifting and handling;
• confined spaces;
• work at height;
• electrical work;
• excavation work;
• work under pressure;
• lockout of hazardous energy sources;
• the movement of people, machinery and vehicles.

Any person must be able to stop an operation presenting a serious risk without fear of reprisal.

Accidents, incidents, property damage and dangerous situations must be reported immediately.

The supplier must take part in investigations and apply the agreed corrective measures.

The products and services supplied must comply with the applicable drawings, specifications, procedures, standards and contractual requirements.

Depending on the nature of the service, SFP may request:

• material certificates;
• technical data sheets;
• safety data sheets;
• staff qualifications;
• welding procedures and work instructions;
• certificates of conformity;
• calibration certificates;
• inspection and control reports;
• traceability records;
• end-of-works files.

Measuring and control equipment must be suitable, maintained and, where required, calibrated.

Any non-conformity must be reported.

No non-conforming product, material or work shall be replaced, repaired, concealed or accepted without authorisation.

Suppliers must prevent and reduce the environmental impacts associated with their activities.

In particular, they must:

• prevent spills and uncontrolled discharges;
• store oils, fuels, gases and chemical products securely;
• limit fumes, dust, noise and other nuisances;
• manage waste in accordance with applicable rules;
• favour reduction, reuse and recycling;
• make reasonable use of water, energy and raw materials;
• protect soils, water resources and sensitive areas;
• maintain the means necessary to respond in the event of a spill;
• report any environmental incident immediately.

Hazardous waste must be identified, separated, stored and handed over to authorised handlers where regulations require it.

SFP GROUPE applies a zero-tolerance policy towards corruption, fraud, embezzlement and unlawful payments.

It is prohibited to:

• offer, request or accept an undue advantage;
• make a payment intended to influence a decision;
• use an intermediary to circumvent a rule;
• submit a false invoice or a fictitious expense;
• conceal the actual beneficiary of a payment;
• offer or accept a secret commission;
• manipulate a consultation or selection process.

Payments must correspond to a real transaction, be properly documented and be made in accordance with the agreed contractual terms.

Gifts and invitations must never influence, or give the appearance of influencing, a business decision.

They must remain occasional, reasonable, transparent and compliant with the law and with the rules of the organisation concerned.

Suppliers must declare any situation likely to affect their impartiality, notably:

• a family relationship with a person involved in a decision;
• a personal financial interest in a transaction;
• a stake in a competing or candidate company;
• a relationship capable of affecting the objectivity of a selection.

Declaring a conflict of interest allows SFP to assess the situation. It does not automatically lead to the exclusion of the supplier.

Suppliers must adopt honest and fair business practices.

They must not:

• illegally agree on prices;
• artificially allocate markets;
• exchange confidential information with competitors;
• manipulate a tender process;
• present non-existent references or certifications;
• spread false or misleading information about a competitor.

Offers must be genuine, understandable and sufficiently detailed to allow a fair comparison.

Commercial, technical, financial and personal information received in the course of a relationship with SFP must be protected.

The supplier must:

• restrict access to authorised persons;
• use the information solely for the agreed assignment;
• take appropriate measures against loss, unauthorised access and disclosure;
• comply with applicable personal data protection rules;
• promptly inform SFP of any incident affecting confidential data or documents;
• return or destroy information when contractually required.

Without written authorisation, it is prohibited to:

• publish photos or videos of a worksite;
• use SFP's name or logo;
• disclose drawings, methods, quotes or technical documents;
• share personal contact details to which the supplier has had access.

These obligations continue after the end of the business relationship.

Equipment, tools, documents, drawings, software and other property made available must be used solely for the authorised assignment.

The supplier must prevent their loss, deterioration, unauthorised reproduction and use for personal purposes.

Any incident affecting property belonging to SFP, a client or a partner must be reported promptly.

Intellectual property rights and usage rights applicable to drawings, methods, documents or software must be respected.

Using a subcontractor does not release the supplier from its responsibilities.

The supplier must verify that its subcontractors:

• possess the required skills and authorisations;
• comply with safety rules;
• apply social and environmental requirements;
• protect confidential information;
• do not engage in fraudulent or prohibited practices.

Where the contract requires it, subcontracting must receive prior written authorisation.

The supplier remains responsible for the quality, safety and compliance of the services performed by its subcontractors.

Where the necessary skills and capacities are available, SFP encourages:

• local recruitment;
• training and professional development;
• the gradual integration of young workers;
• the use of reliable local suppliers;
• the transfer of skills;
• respect for local populations, authorities and customs.

Suppliers must not make any commitment on behalf of SFP to a community, an authority or a third party without written authorisation.

SFP may assess its suppliers using criteria proportionate to the nature and level of risk of the service, notably:

• safety;
• quality;
• technical skills;
• administrative compliance;
• traceability;
• adherence to deadlines;
• integrity;
• environmental performance;
• responsiveness;
• the ability to correct deviations.

In the context of a contractual relationship, SFP may request reasonable evidence of compliance or arrange a verification, within the limits set out in the contract and subject to respecting the confidentiality of the supplier's information.

Except in urgent situations, the verification will be announced within a reasonable period.

An immediate verification may be requested where a serious danger, suspected fraud or a major non-conformity threatens persons, the environment, property or the quality of the works.

Any supplier, worker, subcontractor or partner may, in good faith, report a situation that is contrary to this Code.

Reports may be sent to:

contact@sfp-industrialgroup.com

Recommended subject line:

Confidential report — Code of Ethics

As far as possible, the report should specify:

• the facts observed;
• the date and place;
• the persons or companies involved;
• any documents or evidence available.

SFP will limit access to the report to the persons necessary for its review and will, as far as possible, protect the identity of the person making it.

Absolute confidentiality cannot, however, be guaranteed where disclosure is necessary for the investigation, for the protection of a person or to comply with a legal obligation.

No retaliatory measures shall be taken against a person who has made a sincere report in good faith.

A report made knowingly falsely, that has been fabricated, or that is made with intent to harm may be subject to appropriate measures.

Where a breach is identified, depending on its nature and severity, SFP may:

• request explanations;
• require additional documents;
• request a corrective action plan;
• suspend a service;
• reject a non-conforming product or work;
• temporarily restrict participation in new consultations;
• terminate a contractual relationship in accordance with the contract and applicable law;
• inform the competent authorities where the situation requires it.

Measures must be proportionate, documented and applied in a manner that respects the rights of the parties.

Except where there is an immediate danger, serious fraud, an act of corruption or a situation requiring urgent suspension, the supplier concerned will be able to present its observations and propose corrective measures before a final decision is made.

This Code is made public on the SFP GROUPE website to present the principles that will govern supplier selection, consultations, partnership approaches and SFP's future business relationships.

Its publication does not, by itself, create any contractual obligation on a third party.

The Code becomes binding on a supplier, subcontractor or partner once a contract, purchase order, letter of commitment, partnership agreement or other document accepted by the parties expressly refers to it.

SFP may amend the Code to take account of changes in its activities, regulations, industrial risks and its clients' requirements.

The version applicable to a contractual relationship will be the one specified in the contract or, failing that, the one in force on the date of the commitment.

Any substantial change applicable to an ongoing contract will be communicated according to the arrangements agreed between the parties.

The Code will be reviewed periodically by SFP GROUPE's management.

Any supplier, subcontractor or partner whose contract or commitment document refers to this Code acknowledges having read it and undertakes to comply with the provisions applicable to it.

Where the nature or level of risk of the service justifies it, SFP may request the signature of a separate declaration of adherence appended to the contract or to the supplier's qualification file.

For any question concerning this Code: