Sustainability Policy

1. Employees and working conditions

SEL is committed to upholding the human rights of workers and to treating them with dignity and respect as understood by the international community. This applies to all workers, including temporary, migrant, student, contract and direct employees.

Our labour standards:

1.1. Freely chosen employment

Forced labour, bonded labour (including debt bondage), indentured labour, involuntary or exploitative prison labour, slavery and human trafficking are prohibited. This includes transporting, harbouring, recruiting, transferring or receiving people by means of threat, force, coercion, abduction or fraud for labour or services. There are no unreasonable restrictions on workers' freedom of movement within the facility or on entering or leaving company-provided facilities. As part of the recruitment process, workers receive a written employment contract setting out their terms and conditions in advance, and this contract is not substituted or altered. Changes are permitted only where they comply with local law and provide equal or better terms. All work is voluntary, and workers are free to leave or end their employment at any time.

1.2. Young workers

Child labour is not used at any stage of production. The term "child" refers to anyone under the age of 15, under the age for completing compulsory education, or under the minimum age for employment in the country, whichever is highest. The use of legitimate workplace learning programmes that comply with all laws and regulations is supported. Workers under 18 (young workers) may not perform work that is likely to jeopardise their health or safety, including night shifts and overtime. SEL ensures that student workers are properly managed by keeping proper student records, carrying out rigorous due diligence on educational partners and protecting students' rights in line with applicable laws and regulations, and it provides all student workers with appropriate support and training. In the absence of local law, student workers, interns and apprentices are paid at least the same rate as other entry-level workers doing equal or similar work.

1.3. Working hours

Working hours do not exceed the maximum set by local law. Overtime may not exceed 270 hours a year. Work beyond 45 hours a week is considered overtime. Workers are given at least one day off after every six days of work.

1.4. Wages and benefits

Pay complies with all applicable wage laws, including those on minimum wages, overtime and legally mandated benefits. In line with local law, overtime is paid at a rate higher than regular hourly pay. Deductions from wages as a disciplinary measure are not permitted beyond the limits set by law, contracts and collective agreements. For each pay period, workers receive a timely and clear pay statement with enough information to verify that they have been paid correctly for the work performed.

1.5. Humane treatment

There is no harsh or inhumane treatment, including sexual harassment, sexual abuse, corporal punishment, mental or physical coercion or verbal abuse of workers, nor any threat of such treatment. Disciplinary policies and procedures supporting these requirements are clearly defined and communicated to workers.

1.6. Non-discrimination

SEL maintains a workforce free of harassment and unlawful discrimination. There is no discrimination based on race, colour, age, gender, sexual orientation, gender identity and expression, ethnicity or national origin, disability, pregnancy, religion, political affiliation, union membership, protected genetic information or marital status. Workers and prospective workers are not subjected to medical tests or physical examinations that could be used in a discriminatory way.

1.7. Freedom of association

In line with local law, SEL respects the right of all workers to form and join trade unions of their own choosing, to bargain collectively and to take part in peaceful assembly, as well as their right to refrain from such activities. Workers and/or their representatives can communicate openly and share their ideas and concerns with management about working conditions and management practices without fear of discrimination, reprisal, threat or intimidation.

2. Health and safety

SEL recognises that, in addition to minimising work-related injury and illness, a safe and healthy working environment improves the quality of products and services, consistency of production and worker commitment and morale.

Our health and safety standards:

2.1. Occupational health and safety

Health and safety risks (for example chemical, electrical and other energy sources, fire, vehicles and fall hazards) are identified, assessed and controlled through appropriate design, engineering and administrative controls, preventive maintenance and safe working procedures. Health and safety training is provided. Where hazards cannot be adequately controlled by these means, workers are given appropriate, well-maintained personal protective equipment and training materials about the risks associated with those hazards. Reasonable measures are taken to adapt job duties and working conditions for pregnant women and nursing mothers.

2.2. Emergency preparedness

Potential emergencies and incidents are identified and assessed, and their impact is minimised 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;
• Clear and unobstructed exits;
• Adequate escape and rescue plans.

These plans and procedures focus on minimising harm to life, the environment and property.

2.3. Occupational injury and illness

Procedures and systems are in place to prevent, manage, track and report occupational injury and illness, including provisions to:

• Encourage workers to report, and classify and record injury and illness cases;
• Provide the necessary medical treatment, investigate root causes and implement corrective action to eliminate them.

2.4. Industrial hygiene

Workers' exposure to chemical, biological and physical agents is identified, assessed and controlled according to the hierarchy of controls. Potential hazards are eliminated or controlled through appropriate design, engineering and administrative controls.

2.5. Physically demanding work

Workers' exposure to the hazards of physically demanding tasks, including manual material handling, heavy or repetitive lifting, prolonged standing and highly repetitive or forceful assembly tasks, is identified, assessed and controlled.

2.6. Machine safeguarding

Production and other machinery is assessed for safety hazards. Physical guards, interlocks and barriers are provided and properly maintained wherever machinery could cause injury to workers.

2.7. Sanitation, food and housing

Workers have ready access to clean toilet facilities, drinking water and hygienic food preparation, storage and eating facilities. SEL provides emergency exits, hot water for bathing and showering, adequate lighting, heating and ventilation, and individually secured areas for storing personal and valuable items, with reasonable rights of access to them.

2.8. Health and safety communication

SEL provides workers with appropriate health and safety information and training, in their own language or a language they can understand, on all identified workplace hazards to which they are exposed, including but not limited to mechanical, electrical, chemical and fire hazards. Health and safety information is clearly posted at the facility in places accessible to workers. All workers receive training before starting work and regularly thereafter, and are encouraged to raise safety concerns.

3. Environment

In our manufacturing operations, adverse effects on the community, the environment and natural resources are minimised while safeguarding public health and safety.

Our environmental standards:

3.1. Environmental permits and reporting

All required environmental permits (for example discharge monitoring), approvals and registrations are obtained and kept up to date, and their operational and reporting requirements are followed.

3.2. Pollution prevention and resource reduction

Emissions and discharges of pollutants and the generation of waste are eliminated at source or minimised through practices such as adding pollution control equipment.

Natural resources, including water, fossil fuels, minerals and forest products, are conserved through practices such as modifying production, maintenance and facility processes, substituting materials, reuse, conservation and recycling.

3.3. Hazardous substances

Chemicals and other materials that pose a hazard to people or the environment are identified and labelled to ensure their safe handling, movement, storage, use, recycling or reuse, and disposal.

3.4. Solid waste

SEL applies a systematic approach to identifying, managing, reducing and responsibly disposing of or recycling solid (non-hazardous) waste.

3.5. Air emissions

Air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone-depleting chemicals and combustion by-products are characterised, routinely monitored, controlled and treated as required before discharge. SEL routinely monitors the performance of its air emission control systems.

3.6. Materials restrictions

SEL complies with all applicable laws, regulations and customer requirements on prohibiting or restricting specific substances in products and manufacturing, including labelling for recycling and disposal.

3.7. Water management

SEL implements a water management programme that documents, characterises and monitors water sources, use and discharge. It seeks opportunities to conserve water and controls channels of contamination. All wastewater is characterised, monitored, controlled and treated as required before discharge or disposal. SEL routinely monitors the performance of its wastewater treatment and containment systems to ensure optimal performance and legal compliance.

3.8. Energy consumption

Energy consumption is tracked and documented at company level. SEL looks for effective ways to improve energy efficiency and minimise energy consumption.

4. Ethics

To meet its social responsibilities and succeed in the marketplace, SEL upholds the highest ethical standards, including:

4.1. Business integrity

The highest standards of integrity are upheld in all business dealings. SEL has a zero-tolerance policy prohibiting all forms of bribery, corruption, extortion and embezzlement. SEL's core responsibility is to prevent the benefits of its business relationships from conflicting with any direct or indirect personal interest.

4.2. No improper advantage

Bribes or other means of obtaining an improper advantage are not promised, offered, authorised, given or accepted. This prohibition covers promising, offering, authorising, giving or accepting anything of value, 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. Monitoring and enforcement procedures are in place to ensure compliance with anti-corruption laws. All forms of extortion are prohibited.

4.3. Disclosure of information

All business dealings are conducted transparently and accurately reflected in SEL's records. Information about SEL's labour, health and safety, environmental practices, business activities, structure, financial situation and performance is disclosed in line with applicable regulations and prevailing industry practice. Falsifying records or misrepresenting conditions or practices in the supply chain is unacceptable.

4.4. Intellectual property

SEL respects intellectual property rights; technology and know-how are transferred in a way that protects intellectual property rights, and customer and supplier information is safeguarded.

4.5. Fair business, advertising and competition

Standards of fair business, advertising and competition are upheld. Local laws on competition and counterfeit parts are complied with.

4.6. Protection of identity and non-retaliation

Programmes that ensure the confidentiality and protection of whistleblowing employees and suppliers are maintained, unless prohibited by law. SEL has a process through which employees can raise concerns without fear of retaliation.

4.7. Privacy

SEL is committed to protecting the reasonable privacy expectations of everyone it does business with, including customers, consumers and employees, regarding their personal information. SEL complies with privacy and information security laws and regulatory requirements when personal information is collected, stored, processed, transmitted and shared.