UAB “QS Lasers”

SUPPLIER CODE OF CONDUCT

UAB “QS Lasers”

SUPPLIER CODE OF CONDUCT

UAB “QS Lasers” (“QS Lasers”, “we”, “our”) designs and manufactures laser systems, laser modules, and laser components for industrial, scientific, and advanced technology applications. We are committed to lawful, ethical, and sustainable sourcing. All suppliers, subcontractors, and service providers (collectively “Suppliers”) that do business with QS Lasers must comply with this Code of Conduct (“the Code”). Where stricter laws, customer flow-down requirements, or contractual clauses apply, Suppliers must follow the higher standard.

This Code covers the following areas:

  1. Legal and Regulatory Compliance
  2. Business Integrity
  3. Export Controls and Sanctions
  4. Human Rights and Labour
  5. Health, Safety, and Environment
  6. Quality and Product Compliance
  7. Information Security and Confidentiality
  8. Monitoring and Enforcement
  9. Acceptance

1. Legal and Regulatory Compliance

1.1 General Compliance

Suppliers shall observe all applicable national, EU, and international laws and regulations, including but not limited to competition law, data protection, environmental law, labour law, and export-control statutes. Suppliers are responsible for maintaining all licences, permits, and registrations required for their operations.

1.2 Subcontracting

Suppliers may not subcontract any work covered by a QS Lasers purchase order without prior written consent. Any approved subcontractor must be bound by obligations at least equivalent to those set out in this Code.

2. Business Integrity

2.1 Anti-Bribery and Anti-Corruption

Suppliers shall not offer, pay, solicit, or accept any bribe, kickback, facilitation payment, or other improper benefit in connection with QS Lasers business. Suppliers must maintain effective anti-bribery controls and comply with all applicable anti-corruption laws.

2.2 Conflicts of Interest

Suppliers shall promptly disclose to QS Lasers any actual or potential conflict of interest that could influence business decisions between the parties.

2.3 Accurate Records

All books, records, and documentation shall reflect transactions completely, accurately, and in compliance with applicable accounting standards. Falsification of records is strictly prohibited.

2.4 Fair Competition

Suppliers shall comply with all applicable competition and antitrust laws. No anti-competitive agreements, market allocation, or price-fixing shall be entered into.

3. Export Controls and Sanctions

3.1 Compliance Obligations

Suppliers must comply with all applicable export-control laws and sanctions regimes, including Regulation (EU) 2021/821, Council Regulation (EU) No 833/2014, the Lithuanian Law on the Control of Strategic Goods No. I-1022, and any other EU, UN, or national measures applicable to the transaction.

3.2 Sanctions-Screened Supply Chain

Suppliers shall ensure that no goods, components, raw materials, software, services, or financing used to fulfil a QS Lasers purchase order:

  • originate from, are routed through, or directly benefit entities domiciled in the Russian Federation, the Republic of Belarus, or any other jurisdiction subject to EU comprehensive sanctions; nor
  • involve persons or entities listed on the EU Consolidated Financial Sanctions List, UN Sanctions Lists, or equivalent national lists.

Suppliers shall cascade this requirement through their own supply chain and provide documentary proof on request.

3.3 Classification and Licensing

Where goods or technology supplied to QS Lasers are subject to export licensing requirements, the Supplier shall obtain all necessary licences prior to supply and shall promptly notify QS Lasers of any licensing restrictions that may affect delivery or use.

3.4 Breach Consequences

Breach of this Section 3 constitutes a material breach of any agreement with QS Lasers and triggers, without prejudice to any other remedy, liquidated damages equal to the greater of one hundred percent (100%) of the purchase-order value or fifty thousand euro (€50,000), payable on written demand.

4. Human Rights and Labour

4.1 No Forced or Child Labour

All employment must be voluntary. Workers must be at least fifteen (15) years old or the legal minimum employment age in the country of operation, whichever is higher. Workers under eighteen (18) years of age shall not perform hazardous tasks.

4.2 Non-Discrimination and Equal Treatment

Hiring, compensation, promotion, and other employment decisions shall be based on merit and relevant qualifications. Discrimination based on gender, race, religion, national origin, age, disability, sexual orientation, or any other protected characteristic is prohibited.

4.3 Freedom of Association

Workers may lawfully form, join, or refrain from joining trade unions and worker representative bodies without retaliation.

4.4 Fair Compensation and Working Hours

Suppliers shall pay wages at least equal to the applicable legal minimum, and shall not require employees to work in excess of legally permitted hours without appropriate compensation and consent.

5. Health, Safety, and Environment

5.1 Safe Workplace

Suppliers shall provide a healthy and safe working environment in compliance with applicable law and, where relevant, ISO 45001 or equivalent standards. Risks shall be identified, assessed, and mitigated. Workers shall have access to appropriate personal protective equipment.

5.2 Hazardous Materials

Hazardous substances shall be identified, labelled, stored, handled, and disposed of in accordance with applicable law. Suppliers shall maintain current Safety Data Sheets (SDS) for all hazardous materials.

5.3 Environmental Stewardship

Suppliers shall comply with all applicable environmental laws. Emissions, effluents, and waste shall be minimised. The use of ISO 14001 or equivalent environmental management systems is encouraged. Suppliers shall not use substances prohibited under applicable law (e.g., REACH, RoHS) in goods supplied to QS Lasers.

6. Quality and Product Compliance

6.1 Quality Management

Suppliers shall operate a quality-management system appropriate to the nature and complexity of their products and services. ISO 9001 certification, or equivalent, is strongly encouraged. QS Lasers may require evidence of quality-management capability as a condition of qualification.

6.2 Conformity to Specifications

All goods and services supplied shall conform to the specifications, drawings, and standards stated in QS Lasers’ purchase order. Suppliers shall notify QS Lasers without delay of any non-conformity, deviation, or change in production process, materials, or subcontractors that may affect conformity.

6.3 Traceability and Record Retention

Suppliers shall maintain records that enable full traceability of materials, components, and processes for at least five (5) years after delivery, or longer if required by contract or applicable law. Records shall be made available to QS Lasers upon reasonable request.

7. Information Security and Confidentiality

7.1 Confidential Information

Technical, commercial, and personal data received from QS Lasers shall be kept strictly confidential, used only for the intended business purpose, and protected by appropriate technical and organisational measures.

7.2 Cyber Security

Suppliers shall implement reasonable cyber-security controls, including access control, encryption of data in transit, anti-malware protection, and regular backups, to protect QS Lasers data and systems. Suspected security incidents affecting QS Lasers data must be reported without undue delay.

7.3 Data Protection

Where Suppliers process personal data on behalf of QS Lasers, they shall comply with Regulation (EU) 2016/679 (GDPR) and any applicable national data protection laws, and shall execute a data processing agreement if required.

8. Monitoring and Enforcement

8.1 Right to Audit

QS Lasers or its authorised representative may audit Supplier facilities, records, and processes on reasonable prior notice to verify compliance with this Code and any applicable purchase order terms.

8.2 Corrective Action

Upon identification of a non-conformity with this Code, the Supplier shall promptly investigate and implement corrective action within a timeframe agreed with QS Lasers. Serious, repeated, or uncorrected breaches may result in:

  • suspension or termination of the Supplier relationship;
  • financial claims for damages incurred by QS Lasers; and
  • notification to relevant regulatory authorities.

8.3 Reporting Channel

Suspected or actual violations of this Code may be reported in confidence to: [email protected]. Reports may be made anonymously. QS Lasers prohibits retaliation against any person who reports a concern in good faith.

9. Acceptance

By supplying goods or services to UAB “QS Lasers”, the Supplier:

  • acknowledges receipt of this Code;
  • agrees to comply with its provisions and to flow equivalent obligations down to its own subcontractors and sub-suppliers; and
  • consents to QS Lasers conducting compliance audits as described in Section 8.

QS Lasers may update this Code from time to time. The version in effect at the time of order placement shall apply. The current version is available at www.qslasers.com.