Code of ConductCode of Conduct of Boers & Co Precision Solutions December 2025
Supplier and Business Partner Code of Conduct
1. IntroductionBoers & Co Precision Solutions (Boers & Co) Boers & Co has been active in the manufacturing and assembly of precision parts and components since 1895. We are a leading manufacturer located in the southwestern part of the Netherlands, in an area where the high-tech industry is always close by. All employees at Boers & Co are continuously focused on innovations for better operations, benefiting both our end users and our stakeholders. Corporate Responsibility Being such a company means that Boers & Co has a responsibility as a corporation towards customers, employees, investors, and the public. This Corporate Social Responsibility (CSR) includes compliance at all times with all relevant statutory requirements, alongside respect for ethical values and acting responsibly for both our business and the social environment. By supporting and acting in line with the United Nations Global Compact, Boers & Co has undertaken to consider its principles in the areas of human rights, labour, environmental protection, and anti-corruption. Furthermore, Boers & Co meets the labour standards laid down in the conventions of the International Labour Organization (ILO) and the Dutch labour organizations. Code of Conduct Policy Boers & Co has also established binding guidelines in its Code of Conduct for acting in a responsible and sustainable manner. Expectations for Suppliers and Business Partners In line with the CSR strategy pursued by Boers & Co, the company expects its suppliers (i.e., all contracting parties that supply goods, materials, or services) and business partners (including parties with an intermediary and/or representative function acting in the interests of or on behalf of Boers & Co, such as consultants, agents, trading representatives, authorized dealers/importers, joint venture and syndicate partners, etc.) and their employees to act responsibly and to observe the basic principles outlined in this Boers & Co Supplier and Business Partner Code of Conduct. If suppliers or business partners involve third parties (e.g., subcontractors or representatives) in their business dealings with Boers & Co, Boers & Co expects these third parties to also observe the principles laid down in this Code of Conduct. Corporate Sustainability Reporting Directive (CSRD) In addition to our existing commitment to CSR, Boers & Co aligns its sustainability and transparency obligations with evolving European guidelines. The Corporate Sustainability Reporting Directive (CSRD) is a European Union directive that obliges companies to report transparently on the impact of their activities on people, the environment, and society. This extends to both our own operations and those within our supply chain, with a focus on ESG themes (Environment, Social, Governance) such as climate, human rights, working conditions, business ethics, and governance. Boers & Co recognizes that even companies not directly subject to the CSRD (such as certain SMEs and supply partners) may be asked to provide information supporting the reporting obligations of larger, CSRD-covered clients. We therefore expect our suppliers and business partners to:
This includes conducting due diligence on negative impacts for people and the environment, and openly reporting risks, impacts, and improvement actions when requested. In this way, we collectively strengthen responsible value chains and sustainable business practices in line with both legal requirements and market expectations.
2. Applicable Legal and Regulatory FrameworkBoers & Co and its suppliers and business partners commit to full compliance with all applicable national and international laws, regulations, and standards. This Code of Conduct is designed to support compliance with key legal frameworks across jurisdictions in which Boers & Co and its partners operate.
2.1 European Union LegislationSuppliers and business partners operating within or supplying to the European Union must comply with: Labour and Social Law
Data Protection
Product Safety and Chemical Substances
Sustainability and Due Diligence
2.2 United States LegislationSuppliers shall continuously monitor updates to the European Union’s REACH candidate list of Substances of Very High Concern (SVHC) and promptly inform Boers & Co if any supplied articles contain SVHCs in concentrations above the applicable legal thresholds. Where such substances are present, suppliers must provide up‑to‑date safety data sheets or equivalent documentation and support Boers & Co in fulfilling information and notification duties towards customers and authorities. For electrical and electronic equipment, suppliers shall ensure full compliance with RoHS requirements regarding restricted substances and provide appropriate conformity declarations and supporting evidence on request. For suppliers and business partners involved in activities related to the United States market, compliance is required with applicable federal and state laws, including but not limited to: Product Safety and Chemical Substances
Conflict Minerals
Trade Compliance
Labour and Employment
2.3 International Standards and FrameworksBoers & Co and its suppliers commit to alignment with internationally recognized standards:
Boers & Co suppliers and business partners are expected to:
3. Corporate Social ResponsibilityCorporate Social Responsibility involves a duty to comply with all official and applicable regulations and resolutions in force. Boers & Co expects its suppliers and business partners (henceforth referred to as “Boers & Co suppliers”) to particularly observe the following basic principles:
3.1 Human RightsBoers & Co suppliers respect the regulations in force worldwide to protect human rights as a fundamental and general requirement. This also involves Boers & Co suppliers refraining from the use of forced labour or child labour. Suppliers and business partners comply with the rules laid down in ILO Convention 138 concerning the minimum age of employment for children and in ILO Convention 182 concerning the Prohibition and Immediate Elimination of the Worst Forms of Child Labour. 3.2 Human TreatmentBoers & Co suppliers have disciplinary policies and procedures stating there is to be no harsh and inhumane treatment, including sexual harassment, sexual abuse, corporal punishment, mental or physical coercion, or verbal abuse of employees, nor the threat of any such treatment. 3.3 Equal Opportunity and Non-DiscriminationBoers & Co suppliers do not discriminate on grounds of national or ethnic origin, race, sexual orientation, political affiliation, union membership, religion, views, age, disability, marital status, or any other legally protected characteristics, unless the law requires otherwise. Employees with disabilities will be provided with the job working environment required for them to perform their job function. 3.4 Environmental ProtectionBoers & Co suppliers take responsibility when it comes to environmental protection concerns and comply with all applicable legislation relating to the environment and sustainability. They use natural resources sparingly and minimize harm to the environment. All required environmental permits, approvals, and registrations are to be obtained, maintained, and kept current. Suppliers will make continual progress towards eliminating and reducing waste of all kinds, including water and energy, at source or by practices such as modifying production, maintenance and facility processes, materials substitution, conservation, recycling, and re-using materials. 3.5 Hazardous SubstancesBoers & Co suppliers should use materials in their products which do not contain any hazardous, ozone-depleting substances, asbestos, or nuclear-contaminated substances at any time. Materials applied are compliant with the various European Union legislations and regulations imposed, including REACH, RoHS, and POP Regulation. 3.6 Conflict MaterialsBoers & Co suppliers must comply with EU Regulation 2017/821 on Conflict Minerals and US Dodd-Frank Act Section 1502. Suppliers are expected to:
3.7 Product SafetyBoers & Co suppliers comply with all applicable legal product-safety regulations and requirements, particularly legal requirements pertaining to safety, labelling, and packaging of products, as well as to the use of dangerous substances and materials. 3.8 Working HoursBoers & Co suppliers’ working hours are not to exceed applicable legal limits. Suppliers will provide employees with all legally mandated leave, including maternity leave, paternity leave, compassionate leave, and annual leave. 3.9 Safety in the WorkplaceBoers & Co suppliers comply with the relevant legal regulations for health and safety in the workplace. They support the further development and improvement of working conditions. Employees are to be provided with appropriate, well-maintained, personal protection equipment where necessary. 3.10 Minimum WagesBoers & Co suppliers ensure that their employees are commensurately remunerated. Salaries and other benefits shall be paid to employees in compliance with all applicable local wage laws and Labour Organizations and/or collective bargaining and the respective job market, including those relating to minimum wages, overtime hours, and legally mandated benefits. 3.11 Data Protection and GDPR ComplianceSuppliers and business partners who process personal data on behalf of Boers & Co must comply with the General Data Protection Regulation (GDPR / AVG) and all applicable national data protection laws. They shall implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including confidentiality, integrity, availability, and resilience of processing systems and services. Suppliers acting as data processors must enter into a written data processing agreement with Boers & Co, ensure that personal data is processed only on documented instructions from Boers & Co, and refrain from engaging sub‑processors without prior written authorization. They shall notify Boers & Co without undue delay of any personal data breach, assist Boers & Co in responding to data subject requests and regulatory inquiries, and make available all information necessary to demonstrate compliance with applicable data protection obligations. 3.12 Anti‑Corruption and Business EthicsBoers & Co requires its suppliers and business partners to comply with all applicable anti‑corruption and anti‑bribery laws, including relevant provisions of national criminal law, international anti‑corruption conventions, and industry‑specific regulations. Any form of bribery, facilitation payments, kickbacks, embezzlement, or other corrupt practices in dealings with public officials or private business partners is strictly prohibited. Suppliers shall maintain accurate books and records, implement effective internal controls, and provide training where appropriate to prevent, detect, and remediate corruption risks. Any suspected or actual violation of anti‑corruption obligations related to Boers & Co’s business must be reported promptly to Boers & Co via the designated compliance contact point, and suppliers shall cooperate fully with any investigation or remedial action.
4. Supply Chain Due Diligence & ResponsibilityBoers & Co is committed to responsible value chain management in line with the OECD Due Diligence Guidance and the emerging EU Corporate Sustainability Due Diligence Directive (CSDDD). We expect our suppliers and business partners to conduct their own due diligence to identify, prevent, mitigate, and account for adverse impacts on human rights, labour rights, and the environment.
4.1 Risk-Based Due Diligence ProcessBoers & Co Suppliers and business partners shall establish or participate in accessible and trusted grievance mechanisms that enable workers, communities, and other stakeholders to raise concerns related to human rights, labour conditions, environmental impacts, and business ethics. Such mechanisms should be transparent, predictable, and designed to avoid retaliation, and they should include clear procedures for receiving, assessing, responding to, and tracking grievances and agreed remediation. 4.2 Supplier ExpectationsBoers & Co suppliers must:
4.3 Continuous ImprovementBoers & Co recognizes that full compliance may require time and resources, particularly for smaller suppliers. We encourage:
Suppliers are expected to demonstrate measurable progress and to integrate responsible business practices into their management systems. 4.4 CSDDD‑Aligned Due Diligence ObligationsIn line with the Corporate Sustainability Due Diligence Directive (CSDDD) and comparable national due diligence laws, Boers & Co expects suppliers and business partners to conduct ongoing human rights and environmental due diligence in their own operations and supply chains. This includes identifying, preventing, mitigating, and, where necessary, remediating actual and potential adverse impacts related to labour conditions, human rights, environmental harm, and business ethics. Suppliers shall cooperate with Boers & Co’s due diligence processes by providing relevant information, participating in risk assessments and audits where appropriate, and establishing or joining accessible grievance mechanisms for workers and affected stakeholders. Where adverse impacts are identified, suppliers are expected to engage in remediation efforts, track the effectiveness of corrective measures, and transparently communicate on progress to Boers & Co upon request.
5. Transparent Business RelationshipsOpenness and transparency are key to credibility and trust in business practice. Boers & Co expects suppliers and business partners to particularly observe the following basic principles:
5.1 Free CompetitionBoers & Co suppliers comply with the applicable antitrust legislation. 5.2 Export Controls and SanctionsBoers & Co suppliers and business partners shall comply with all applicable export control and sanctions laws and regulations, including controls on dual‑use items and embargoes administered by relevant authorities. They must ensure that no goods, software, technology, or services supplied to Boers & Co are exported, re‑exported, or transferred in violation of such controls, and must promptly inform Boers & Co if any restrictions or licensing requirements apply to supplied items. 5.3 Anti‑Money Laundering and Know‑Your‑Customer MeasuresBoers & Co suppliers shall only conduct business with partners whose integrity and legitimacy can be reasonably verified and shall take appropriate steps to prevent their operations from being used for money laundering or terrorist financing. This includes maintaining accurate records of transactions, cooperating with lawful requests from competent authorities, and promptly reporting any suspicious activities related to Boers & Co’s business were permitted by law. 5.4 Accurate Business Information and ReportingBoers & Co suppliers shall provide complete, accurate, and timely business information to Boers & Co and relevant authorities, including information related to compliance, product characteristics, and supply chain due diligence. Misrepresentation, falsification of records, or deliberate omission of material information is prohibited and may lead to corrective measures, including suspension or termination of the business relationship. 5.5 Protection of Confidential Information, Intellectual Property, and Company AssetsBoers & Co suppliers shall protect Boers & Co’s confidential information, trade secrets, and intellectual property against unauthorized access, use, disclosure, or loss, and shall only use such information for legitimate business purposes as agreed with Boers & Co. Tangible and intangible assets of Boers & Co, including tools, equipment, data, and IT systems, must be used responsibly, safeguarded against misuse or damage, and returned or deleted as instructed at the end of the business relationship or upon request.
6. Consequences of Non‑Compliance with this CodeBoers & Co expects suppliers and business partners to comply with this Supplier and Business Partner Code of Conduct and to remedy any identified non‑conformities without undue delay. Where breaches occur, Boers & Co may require corrective action plans, additional audits, enhanced reporting, or other proportionate remedial measures, taking into account the severity and recurrence of the issue. In cases of serious or repeated violations, refusal to cooperate with reasonable due diligence requests, or failure to implement agreed corrective measures, Boers & Co reserves the right to suspend deliveries, restrict cooperation, or terminate the business relationship, and may take further legal action where appropriate. Nothing in this Code limits any contractual or statutory rights that Boers & Co may have under applicable law.
7. Definitions and ClarificationsThis Annex forms an integral part of the Boers & Co Supplier and Business Partner Code of Conduct. Definitions:
8. Information referencesThis Supplier and Business Partner Code of Conduct is based on, and intended to align with, a number of public laws, regulations and international standards. The main sources include, among others, the following categories of official information: European Union legislation on data protection, product safety, chemicals, sustainability reporting and due diligence, such as the General Data Protection Regulation (GDPR), REACH, RoHS, the POP Regulation, the Conflict Minerals Regulation, the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD). These instruments can be consulted via the official EU legislation portal (EUR‑Lex) and other EU institutions’ websites. Dutch labour and working conditions law, including the Dutch Civil Code (Burgerlijk Wetboek), the Working Conditions Act (Arbowet) and the Working Hours Act (Arbeidstijdenwet), as well as guidance from competent Dutch authorities on occupational health and safety and data protection. These sources are available via the official Dutch government legislation and information portals. International labour and human rights standards, such as the core conventions of the International Labour Organization, the principles of the UN Global Compact, the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises, which can be consulted through the official websites of the UN, ILO and OECD. United States federal and state legislation relevant to product safety, chemicals, conflict minerals, export controls, sanctions and consumer protection, including the Toxic Substances Control Act (TSCA), the conflict minerals provisions of the Dodd‑Frank Act and California Proposition 65. Official information on these frameworks can be accessed via the websites of U.S. federal and state authorities and securities and market regulators. In preparing this Code of Conduct the following sources were used:
For more information/contact: solutions@boers.nl |
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