EICC Code of Conduct

As a leader in designing, manufacturing and providing global data communication solutions, Multi-Tech Systems, Inc. has voluntarily adopted the EICC Code of Conduct and is committed to promoting the principles discussed therein, both internally and with significant suppliers of components. Accordingly, MultiTech has established appropriate standards and policies to implement the EICC Code of Conduct as it relates to MultiTech’s operations at its corporate and manufacturing headquarters in Minneapolis, Minnesota, and will endeavor to continuously improve its adherence to the Code of Conduct.

To further promote the EICC Code of Conduct and MultiTech’s Business Principles and Environmental Objectives, MultiTech expects certain of its suppliers to adhere to the EICC Code of Conduct as well. Suppliers are expected to be familiar with the business practices of their suppliers and sub-contractors to ensure they operate within the Code. If requested by MultiTech in writing, Supplier shall verify that it is operating within the code, by presenting MultiTech with documented audit and management reviews of its performance. Failure to comply with the Code may result in the discontinuance of our business relationship.

The EICC Code of Conduct provides guidelines and compliance with critical corporate social responsibility policies, including Labor, Health & Safety, Environment, Management System and Ethics. MultiTech Systems has adopted the EICC Code of Conduct.

Business Principles

MultiTech is committed to conducting its business in an ethical and responsible manner, creating a safe and healthy work environment and adhering to applicable laws. These Business Principles are approved by executive management and apply to all employees of MultiTech and are designed to provide guidance to employees in complying with compliance and ethical issues. Additional guidance may be found in the MultiTech Personnel Policies Manual, which each employee has received and is expected to read and become familiar to its provisions, and in our Quality Management System, which may be requested by contacting the Director of Quality Control.

These Business Principles are not intended to be all-inclusive, and as such they may not address every question or issue that may arise. If you have any questions about proper conduct in a situation that may be covered by these standards, please consult with your supervisor, the Human Resources Director, or the in-house corporate counsel. MultiTech assures that employees will not be subject to any retaliation for reporting improper conduct.

Senior management will regularly conduct internal corporate reviews of these Business Principles, with the expectation that performance against them will continuously improve:

Compliance with Applicable Laws
All employees of MultiTech are required to respect and obey all applicable laws, rules and regulations. While employees are not expected to know the details of the laws that apply to Multi-Tech Systems, Inc. these Business Principles highlight some basic principles to serve as compliance guidance. However, if a law conflicts with these Business Principles, compliance with such law is required.

Ethical Conduct
Generally. Each employee is required to perform their duties in an ethical and positive manner, so as to promote the best interests of MultiTech. This includes maintaining the integrity of confidences and intellectual property, and competing in a fair manner.

Conflicts of Interest. MultiTech policy provides that employee relationships with third parties be free of conflicts of interest. Accordingly, employee decisions made during the course of such relationships and transactions must not be influenced by the employee’s self-interest that is actually or may potentially be in conflict with the best interest of MultiTech. Examples, as well as other standards of employee conduct, are available in MultiTech’s Personnel Policies Manual.

Labor and Hiring
Compensation and Working Hours. All employees will be paid at least the minimum wages and overtime rates required by law and any applicable collective labor agreements. If no such laws or agreements apply, wages will be paid in accordance with market conditions. MultiTech will comply with all applicable laws and rules, as well as any relevant industry practices, governing the hours of work for employees.

No Discrimination or Harassment. Each employee is expected to treat their co-workers with dignity and respect. Multi-Tech Systems, Inc. prohibits harassing or discriminatory conduct in the workplace, whether based on race, color, religious belief, national origin, age, sex, disability, or any other characteristic protected by applicable law including sexual harassment, regardless of whether it is committed by supervisory or non-supervisory personnel. This applies to all terms and conditions of employment, including hiring, placement, job assignments, promotion, discipline, termination, layoff, transfer, recall, leave of absence, benefits, compensation and training.

Forced or Child Labor. All employees shall be voluntary, freely choosing to be employed by MultiTech, as well as having the freedom to associate and join labor unions. Child labor is prohibited, and all employees must be at least 16 (or younger where the law of the country of hire permits).

Safe and Healthy Working Environment
As set forth in MultiTech’s internal policies, all employees are expected to be safety conscious and to assist in preventing and avoiding workplace conditions that may cause an accident or injury. All applicable state and federal Occupational Safety and Health Administration regulations and safety guidelines must be followed by employees and supervisors at all times. Any employee who is furnished safety equipment by MultiTech will be required to wear such safety equipment at all times while doing the work for which the equipment is furnished. Employees are required to immediately report any unsafe condition or any injury received, no matter how minor, while at work, to your supervisor or the Human Resources Department.

Environmental Objectives
Responsible product design and manufacture, as well as sophisticated facility management, has been at the core of MultiTech’s business for more than 20 years. The results of this effort are available here in a document , which includes an overview of MultiTech’s historic and current usage, and sets future reduction objectives, in relation to energy conservation, Scope 1 and Scope 2 greenhouse gas emissions, and waste management. MultiTech adheres to all applicable laws, including local regulations of wastewater and air emissions, as well as customer requirements (e.g., RoHS or other banned substances, WEEE).

Environmental Objectives

At Multi-Tech Systems, Inc. we are committed to developing and manufacturing products in an environmentally responsible manner. For over 30 years, MultiTech has been implementing its “Design for Environment” initiative, aggressively pursuing pollution prevention, energy conservation, waste reduction and better product design for easy recycling and legal compliance. As we look to the future, MultiTech will continue to seek improvement in our environmental initiatives and will annually review our progress towards a more environmentally sustainable business.

Supplier Declaration

To further promote the EICC Code of Conduct and MultiTech’s Business Principles and Environmental Objectives, MultiTech expects certain of its suppliers to adhere to the EICC Code of Conduct as well. Suppliers are expected to be familiar with the business practices of their suppliers and sub-contractors to ensure they operate within the Code. If requested by MultiTech in writing, Supplier shall verify that it is operating within the code, by presenting MultiTech with documented audit and management reviews of its performance. Failure to comply with the Code may result in the discontinuance of our business relationship.

Conflict Minerals Statement

As a global electronics manufacturer, Multi-Tech Systems, Inc. is committed to ethical business principles, including responsible manufacturing and materials sourcing. Recently, the SEC has promulgated regulations requiring supply chain reporting and reasonable due diligence with respect to the sourcing of certain materials (tin, tantalum, tungsten and gold) mined in conflict areas under the control of armed groups in the region of the Democratic Republic of Congo and adjoining countries (the “conflict minerals”).

To that end, MultiTech is diligently evaluating our supply chain with regards to these conflict materials, working to identify and verify the sources of the minerals used in the components that are incorporated in our products, and using the Conflict Minerals Reporting Template provided by EICC-GeSI to collect such information. As we gather information and analyze the collected data, we will be working with our suppliers towards a goal of conflict mineral free sourcing.

If you have a specific question or concern related to MultiTech’s products, please contact us at sales@multitech.com.