Selecting and Managing Our Vendors

CODE PRINCIPLES

The effective procurement of goods, services and raw materials is critical to the development and expansion of our sites, and the manufacture and supply of our products to customers. We select vendors based on objective criteria and their alignment with our Core Values.

  • We seek to ensure that prospective and existing vendors comply with applicable laws; supply with integrity; minimize their adverse impact on the environment and local communities; provide a safe and healthy workplace; and respect basic human rights of employees and laws relating to conflict minerals and child labor.
  • We conduct tender processes with transparency, treat vendor bids as confidential and do not provide any current or prospective vendor with an unfair or improper advantage.
  • We monitor prospective and existing vendors to ensure they are not engaging in collusion or inappropriately exchanging competitively sensitive information relating to Albemarle.
  • We seek to avoid actual or potential conflict of interest arising from the selection or use of a vendor.
  • We treat our vendors with respect, communicate our requirements with clarity and transparency, and pay valid invoices on time.
  • We expect our contractors and vendors to comply with our health and safety requirements.
  • We prohibit our vendors from engaging in bribery, including facilitation payments, on Albemarle’s behalf.
  • We only pay for goods and services provided, and monitor our vendors for evidence of fraud or corruption.
  • We do not use vendors if we suspect that such activity will contravene export or sanctions laws or regulations.
  • We do not ask, expect or allow a vendor to carry out acts that would be a violation of this Code or applicable laws.
  • We avoid business relationships with vendors that may be engaged in money laundering.

Our Code Principles in Action

  • Comply with the Global Procurement Policy when undertaking procurement-related activity.
  •  Only use your travel & expenses credit card in accordance with this Code (Managing your Business Expenses) and company purchasing cards in accordance with the Purchasing Card Policy.
  • Conduct appropriate checks on prospective vendors in accordance with the Vendor Qualification Policy. 
  • Obtain pre-approval in accordance with the Global Procurement Policy, Anti-Corruption Policy and Compliance Sensitive Vendor Procedure before:
  • Negotiate, authorize and sign vendor agreements in accordance with the Vendor Agreements Policy, and ensure that they clearly reflect the services or products to be purchased, as well as the price.
  • Ensure that the vendor has received a valid purchase order before they start supplying the goods or services.
  • Check vendor invoices carefully to ensure they accurately reflect goods and services purchased, and ensure they are charged to the correct Group Ledger account.
  • Prior to approving invoices, check for red flags such as:
    • vague or unclear descriptions of items to be paid;
    • unexpected deviations from agreed-upon goods, services or amounts;
    • payments directed to anyone other than the vendor that actually provided the goods and services; and
    • payments to bank accounts that are outside of the vendor’s home country, where it does business or where goods or services were provided.
  • Follow the Guidance on Effective Monitoring of Vendors, and immediately contact Global Ethics & Compliance if you suspect a vendor is acting in violation of this Code or our Core Values.
  • Follow the Code (Managing a Conflict of Interest) if you, your spouse, your partner or a relative has a significant interest in a prospective or existing vendor of products or services in relation to which you have influence on the selection of the vendor.
  • Follow the Code (Offering or Accepting Gifts & Hospitality) if you intend to accept an offer of a gift, meal, entertainment or anything else of value from an existing or prospective vendor.
  • Provide all existing and prospective vendors with a copy of Albemarle’s Code of Conduct for Business Partner.
  • Consult with the Legal Department or Global Ethics & Compliance if a vendor requires Albemarle to sign an end use certificate, an ethics and compliance certification or any other type of certification.
  • Immediately contact the Legal Department or Global Trade Compliance Operations if you know or suspect that a customer or third party sales representative is:
    • requiring Albemarle to refuse to do business with or in Israel or with:
      • businesses operating in Israel;
      • businesses which have relationships with other businesses which operate in Israel; or
      • other persons on the basis of race, religion, sex, national origin or nationality; or
    • seeking information about Albemarle’s direct or indirect business activities with or in Israel.

待定

DEFINED TERMS

贿赂

贿赂是指以不正当影响任何人采取行动以获取不正当利益为目的,给予、提供或接受任何有价物。例如,这可能包括在以下方面的不正当影响:

  • 关于是否接受申请、正式表格或任何其他类型的文件的决策;
  • 允许接收者从事特定活动的执照、许可证、额度、签证或任何其他奖励的授予或撤销;
  • 商业采购或销售合同的授予;
  • 关于对公司或个人执行或不执行特定法律或法规的决策;
  • 关于执行或不执行履约保证等合同条款的决策;
  • 关于是否要求付款或付款金额(例如税款)的决策;以及
  • 对现有法律变更的支持或批准。

贿赂还包括支付疏通费

合规敏感型供应商

Vendors who:

  • you know, or suspect, are directly or indirectly owned by a government official or a close relative of a government official;
  • will, or may, engage with a government official with or on behalf of Albemarle; or
  • are recommended by a government official (including employees of a state-owned enterprise).
冲突矿物

在武装冲突区的一个地区开采矿物,进行非法贸易以资助或以其他方式使战斗持续下去。 示例包括但不限于钴、锡石(用于锡)、黑钨矿(用于钨)、铌钽矿(用于钽)、金矿和钻石。

腐败

处于有影响力或权威地位的人为个人利益而进行的不诚实或不道德的行为

进口/出口管制法律

Laws and regulations, which regulate the movement of specific items across national borders. For example, export control laws may require a licence to be obtained or otherwise prohibit (whether a license is required depends on the classification of the item to be exported, the intended destination, and the intended end use as well as end user):

  • any export or re-exports of specific items listed on various ‘controlled lists’ maintained by the United States, the European Union and other countries. These items are often capable of being used in military applications, i.e., they are dual use items that have a predominantly commercial end use but that also have some military utility, which is why their export is restricted;
  • transfer of controlled technology, including via email and other online or physical means; and
  • exports (and temporary imports) of defence-related articles, technical data, and services
疏通费

Small payments made to lower-level government officials as a personal benefit to them to secure or speed up a performance of a routine action (e.g. licenses, permits, visas, customs clearance).

clearance). Facilitation payments are illegal in most countries and can open the door to more serious corruption issues.

制裁法

Sanctions laws consist of a wide range of political and/or economic measures to influence the decisions and behavior of a particular country’s regimes, individuals, or groups.  They may be comprehensive, prohibiting commercial activity with a country (absent a license), or targeted, blocking transactions of and with specific businesses, individuals, or groups. Generally, these laws, regulations, and compulsory measures directly or indirectly restrict trade or other dealings, e.g., financial restrictions with particular countries, regimes, entities and/or individuals. For example, trade sanctions laws may prohibit:

  • imports from or exports to a sanctioned country or region (e.g. Cuba, Iran, Syria, North Korea, or Crimea);
  • exports/imports or other dealings in property originating from a sanctioned country, or other transactions and/or dealings, directly or indirectly, with sanctioned governments, individuals or entities, such as designated terrorist groups; or
  • U.S. persons from approving, financing, facilitating or guaranteeing any transaction by a foreign person where that transaction would be prohibited if performed by a U.S. person.
重大利益

一般来说,如果您拥有一个与雅保有业务往来的实体少于5%的股份,您的利益就不会被认为是重要的。 然而,即使低于 5%,但如果您的利益足够大,以至于它可能会看起来,或事实上会影响您在履行工作时的业务判断和对雅保的忠诚,那么您也应该认为利益是重大的。 例如,如果利益占您个人净资产的很大一部分,虽然还不到实体的 5%,那么它就应该被认为是重大的。

竞争性敏感信息

The following types of information are considered to be examples of CSI:

  • marketing plans and proprietary perspectives on the market;
  • cost data less than 12 months old;
  • details of negotiations with individual customers or suppliers;
  • current or recent terms of sale or purchase (price, margins, commission and credit terms);
  • strategic information (site expansion and closure plans);
  •  salaries and other terms of employee remuneration less than 12 months old;
  • innovation plans and intellectual property; and
  • production, export, sales and purchase data less than 12 months old.

CSI does not include:

  • information that is publicly available, including through subscription services;
  • information that is more than 12 months old and would not be considered to give a competitive advantage if shared with, or by, a competitor;
  • health, safety or environmental data; or
  • information relating to the technical performance of equipment.
洗钱

指确保与犯罪活动有关的资金的性质和来源隐藏在合法的商业交易中的过程,或当合法资金被用于支持包括恐怖主义在内的犯罪活动时。它通常由三个步骤组成:放置、分层和整合。

菜单