TowerJazz Panasonic Semiconductor Co., Ltd. (hereafter TPSCo) is committed to ensuring our employees act in a lawful and ethical manner. We expect our employees, in all of their activities, to operate in full compliance with all applicable laws, rules and regulations.
The following corporate social responsibility principles are modeled on and contain language from the Electronic Industry Citizenship Coalition (EICC) Code of Conduct, which establishes standards to ensure that working conditions in the electronics industry supply chain are safe, that workers are treated with respect and dignity and that business operations are environmentally responsible.
TPSCo expects all employees to abide by these Principles, and we will actively evaluate compliance with these Principles to ensure sound business practices within our company.
Labor and Human Rights
TPSCo is committed to ensuring the human rights of our workers, and treat them with dignity and respect as understood by the international community. This applies to all workers including temporary, migrant, student, contract, direct employees, and any other type of worker.
The labor and human rights policies are:
- Freely Chosen Employment
We do not use any forced, bonded or indentured labor, involuntary prison labor, slavery or trafficking of persons. This includes transporting, harboring, recruiting, transferring or receiving persons by means of threat, force, coercion, abduction or fraud for the purpose of exploitation. All work is voluntary, and workers are free to leave upon reasonable notice. Workers are not required to hand over government-issued identification, passports or work permits as a condition of employment.
- Child Labor Avoidance
Child labor is strictly prohibited. As used here, the term “child” refers to any person under the age of 15, or under the age for completing compulsory education, or under the minimum age for employment in the country, whichever is greatest. The use of legitimate workplace apprenticeship programs, which comply with all laws and regulations, is permitted. Workers under the age of 18 are not allowed to perform work that is likely to jeopardize their health or safety.
- Working Hours
Workweeks do not exceed the maximum set by local law.
- Wages and Benefits
Compensation paid to workers complies with all applicable wage laws, including those relating to minimum wages, overtime hours and legally mandated benefits. In compliance with local laws, workers are compensated for overtime at pay rates greater than regular hourly rates. Deductions from wages as a disciplinary measure are not permitted. The basis on which workers are being paid is provided in a timely manner via pay stub or similar documentation. All use of temporary, dispatch and outsourced labor will be within the limits of the local law.
- Humane Treatment
There is to be no harsh and inhumane treatment including any sexual harassment, sexual abuse, corporal punishment, mental or physical coercion or verbal abuse of workers; nor is there to be the threat of any such treatment. Disciplinary policies and procedures in support of these requirements shall be clearly defined and communicated to workers.
We are committed to a workforce free of harassment and unlawful discrimination. Employees are not allowed to engage in discrimination based on race, color, age, gender, sexual orientation, ethnicity, disability, pregnancy, religion, political affiliation, union membership or marital status in hiring and employment practices such as promotions, rewards, and access to training. In addition, employees or potential employees cannot be subjected to medical tests that could be used in a discriminatory way.
- Freedom of Association
In conformance with local law, we respect the right of all workers to form and join trade unions, to bargain collectively and to engage in peaceful assembly. Workers and/or their representatives shall be able to openly communicate and share ideas and concerns with management regarding working conditions and management practices without fear of discrimination, reprisal, intimidation or harassment.
Health and Safety
TPSCo recognizes that in addition to minimizing the incidence of work-related injury and illness, a safe and healthy work environment enhances the quality of products and services, consistency of production and worker retention and morale. As a result, we are committed to creating safe working conditions and a healthy work environment for all of our employees.
The health and safety policies are:
- Occupational Safety
Worker exposure to potential safety hazards (e.g., electrical and other energy sources, fire, vehicles, and fall hazards) are to be controlled through proper design, engineering and administrative controls, preventative maintenance and safe work procedures (including lockout/tagout), and ongoing safety training. Where hazards cannot be adequately controlled by these means, workers are to be provided with appropriate, well-maintained, personal protective equipment and educational materials about risks to them associated with these hazards. Workers shall be encouraged to raise safety concerns.
- Emergency Preparedness
Potential emergency situations and events are to be identified and assessed, and their impact minimized by implementing emergency plans and response procedures including: emergency reporting, employee notification and evacuation procedures, worker training and drills, appropriate fire detection and suppression equipment, adequate exit facilities and recovery plans. Such plans and procedures shall focus on minimizing harm to life, the environment and property.
- Occupational Injury and Illness
Procedures and systems are to be in place to prevent, manage, track and report occupational injury and illness including provisions to: encourage worker reporting; classify and record injury and illness cases; provide necessary medical treatment; investigate cases and implement corrective actions to eliminate their causes; and facilitate return of workers to work.
- Industrial Hygiene
Worker exposure to chemical, biological and physical agents are identified, evaluated, and controlled. Engineering or administrative controls are used to control overexposures. When hazards cannot be adequately controlled by such means, worker health is protected by appropriate personal protective equipment programs.
- Physically Demanding Work
Worker exposure to the hazards of physically demanding tasks, including manual material handling and heavy or repetitive lifting, prolonged standing and highly repetitive or forceful assembly tasks are identified, evaluated and controlled.
- Machine Safeguarding
Production and other machinery are evaluated for safety hazards. Physical guards, interlocks and barriers are provided and properly maintained where machinery presents an injury hazard to workers.
- Sanitation, Food, and Housing
Workers are provided with ready access to clean toilet facilities, potable water and sanitary food preparation, storage, and eating facilities. Worker dormitories provided by the company are maintained clean and safe, and provided with appropriate emergency egress, hot water for bathing and showering, and adequate heat and ventilation and reasonable personal space along with reasonable entry and exit privileges.
- Health and Safety Communication
We are committed to provide workers with appropriate workplace health and safety training in their primary language. Health and safety related information shall be clearly posted in the facility.
TPSCo recognizes that environmental responsibility is integral to producing world class products. In manufacturing operations, adverse effects on the community, environment and natural resources are to be minimized while safeguarding the health and safety of the public.
The environmental policies are:
- Environmental Permits and Reporting
All required environmental permits (e.g. discharge monitoring), approvals and registrations are to be obtained, maintained and kept current and their operational and reporting requirements are to be followed.
- Pollution Prevention and Resource Reduction
The use of resources and generation of waste of all types, including water and energy, are to be reduced or eliminated at the source or by practices such as modifying production, maintenance and facility processes, materials substitution, conservation, recycling and re-using materials.
- Hazardous Substances
Chemicals and other materials posing a hazard if released to the environment are to be identified and managed to ensure their safe handling, movement, storage, use, recycling or reuse and disposal.
- Wastewater and Solid Waste
We are committed to implementing a systematic approach to identify, manage, reduce, and responsibly dispose of or recycle solid waste (non-hazardous). Wastewater generated from operations, industrial processes and sanitation facilities are to be characterized, monitored, controlled and treated as required prior to discharge or disposal. In addition, measures should be implemented to reduce generation of wastewater. Participant shall conduct routine monitoring of the performance of its wastewater treatment systems.
- Air Emissions
Air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting chemicals and combustion by-products generated from operations are to be characterized, routinely monitored, controlled and treated as required prior to discharge. We are committed to conducting routine monitoring of the performance of its air emission control systems.
- Materials Restrictions
We are committed to adhering to all applicable laws, regulations and customer requirements regarding prohibition or restriction of specific substances in products and manufacturing, including labeling for recycling and disposal.
- Storm Water Management
We are committed to implementing a systematic approach to prevent contamination of storm water runoff and to preventing illegal discharges and spills from entering storm drains.
- Energy Consumption and Greenhouse Gas Emissions
Energy consumption and greenhouse gas emissions are to be tracked and documented, at the facility and/or corporate level. We are to look for cost effective methods to improve energy efficiency and to minimize their energy consumption and greenhouse gas emissions
To meet social responsibilities and to achieve success in the marketplace, we are committed to upholding the highest standards of ethics.
The ethic policies are:
- Business Integrity
The highest standards of integrity are to be upheld in all business interactions. We have a zero tolerance policy to prohibit any and all forms of bribery, corruption, extortion and embezzlement. All business dealings should be transparently performed and accurately reflected on business books and records. Monitoring and enforcement procedures shall be implemented to ensure compliance with anti-corruption laws.
- No Improper Advantage
Bribes or other means of obtaining undue or improper advantage are not to be promised, offered, authorized, given or accepted. This prohibition covers promising, offering, authorizing, giving or accepting anything of value, either directly or indirectly through a third party, in order to obtain or retain business, direct business to any person, or otherwise gain an improper advantage.
- Disclosure of Information
Information regarding participant labor, health and safety, environmental practices, business activities, structure, financial situation and performance is to be disclosed in accordance with applicable regulations and prevailing industry practices. Falsification of records or misrepresentations of conditions or practices in the supply chain are unacceptable.
- Intellectual Property
Intellectual property rights are to be respected; transfer of technology and knowhow is to be done in a manner that protects intellectual property rights; and, customer information is to be safeguarded.
- Fair Business, Advertising and Competition
Standards of fair business, advertising and competition are to be upheld. Appropriate means to safeguard customer information must be available.
- Protection of Identity and Non-Retaliation
Programs that ensure the confidentiality, anonymity and protection of supplier and employee whistleblowers are to be maintained, unless prohibited by law. We are committed to a communicated process for our employee to be able to raise any concerns without fear of retaliation.
- Responsible Sourcing of Minerals
We are committed to a policy to reasonably assure that the tantalum, tin, tungsten and gold in the products they manufacture does not directly or indirectly finance or benefit armed groups that are perpetrators of serious human rights abuses in the Democratic Republic of the Congo or an adjoining country. We exercise due diligence on the source and chain of custody of these minerals and make our due diligence measures available to customers upon customer request.
We are committed to protecting the reasonable privacy expectations of personal information of everyone they do business with, including suppliers, customers, consumers and employees. Participants are to comply with privacy and information security laws and regulatory requirements when personal information is collected, stored, processed, transmitted, and shared.
We are committed to adopting or establishing a management system whose scope is related to the content of these policies. The management system shall be designed to ensure: (a) compliance with applicable laws, regulations and customer requirements related to the participant’s operations and products; (b) conformance with these policies; and (c) identification and mitigation of operational risks related to these policies. It should also facilitate continual improvement.
The management system should contain the following elements:
- Company Commitment
A corporate social and environmental responsibility policy statements affirming TPSCo’s commitment to compliance and continual improvement endorsed by executive management and posted in the facility in the local language.
- Management Accountability and Responsibility
We clearly identify senior executive and company representative[s] responsible for ensuring implementation of the management systems and associated programs. Senior management reviews the status of the management system on a regular basis.
- Legal and Customer Requirements
A process to identify, monitor and understand applicable laws, regulations and customer requirements, including the requirements of these policies.
- Risk Assessment and Risk Management
A process to identify the legal compliance, environmental, health and safety and labor practice and ethics risks associated with TPSCo’s operations. Determination of the relative significance for each risk and implementation of appropriate procedural and physical controls to control the identified risks and ensure regulatory compliance.
- Improvement Objectives
Written performance objectives, targets and implementation plans to improve the TPSCo’s social and environmental performance, including a periodic assessment of TPSCo’s performance in achieving those objectives.
Programs for training managers and workers to implement these policies, procedures and improvement objectives and to meet applicable legal and regulatory requirements.
A process for communicating clear and accurate information about these policies, practices, expectations and performance to workers, suppliers and customers.
- Worker Feedback and Participation
Ongoing processes to assess employees’ understanding of and obtain feedback on practices and conditions covered by these policies and to foster continuous improvement.
- Audits and Assessments
Periodic self-evaluations to ensure conformity to legal and regulatory requirements, the content of these policies and customer contractual requirements related to social and environmental responsibility.
- Corrective Action Process
A process for timely correction of deficiencies identified by internal or external assessments, inspections, investigations and reviews.
- Documentation and Records
Creation and maintenance of documents and records to ensure regulatory compliance and conformity to company requirements along with appropriate confidentiality to protect privacy.
- Supplier Responsibility
A process to communicate TPSCo’s requirements to suppliers and to monitor supplier compliance to these policies.