EnerSys, and its global subsidiaries (collectively, “EnerSys”, “Company”, “we” or “us”), takes its role as a world citizen seriously and expects the same from its business partners. EnerSys and its business partners are expected to act in accordance with high standards of integrity and in compliance with all applicable laws and regulations. This Corporate Social Responsibility and Human Rights Policy (the “Policy”) is intended to communicate EnerSys’ position as well as the expectations for our business partners.
We respect the protection of human rights and the conservation of the environment. We oppose anti-competitive behavior and corruption in all forms. This Policy should be read in conjunction with the EnerSys Code of Business Conduct and Ethics and other related policies demonstrating our commitment to the principles detailed herein. Please visit our website at www.enersys.com, under the Investors and Corporate Social Responsibility hyperlinks, to learn more about our engagement as a world citizen.
The Policy is administered and governed by the EnerSys Board of Directors and our Chief Executive Officer.
Human rights are relevant to the economic, social and environmental aspects of responsible corporate activity. EnerSys supports and respects the protection of human rights and recognizes that part of being a good corporate citizen includes respecting the human rights of those who interact with and/or act on behalf of the Company. We insist that all of our partners, suppliers, vendors, and other stakeholders, apply and uphold the same comprehensive standards for human rights as outlined in this Policy.
This Policy is based on the United Nations Guiding Principles on Business and Human Rights, which includes an undertaking to respect the human rights reflected in the International Bill of Human Rights, the Universal Declaration of Human Rights and the Declaration on Fundamental Principles and Rights at Work. We are fully committed and aligned with the global consensus that respect for all minority rights, including indigenous peoples’ and women’s rights, is essential in observance of human rights.
Our Policy is available publicly and communicated internally and externally to our business partners and employees. Our commitment is reflected throughout the Company, including in our Code of Business Conduct and Ethics, Conflict Minerals Report, and Anti-Slavery and Human Trafficking Statement, all of which can be found on our website.
Specific Principles of Our Commitment to Human Rights
Forced Labor and Human Trafficking: We prohibit the use of all forms of forced labor, including, indentured labor, bonded labor, modern forms of slavery and any form of human trafficking.
Child Labor: We prohibit the exploitation of children, their engagement in unacceptably hazardous work, and any physical punishment or abuse, by the Company or its suppliers, in compliance with global, federal and local laws.
Diversity: We seek to attract, retain and engage talented and diverse professionals to ensure a competitive edge in the global marketplace and deliver innovative solutions and services to our customers, all while enhancing stakeholder value. We strive to maintain a workplace that is free from discrimination, harassment, or hostility on the basis of race, sex, gender identity or gender expression, color, national or social origin, ethnicity, religion, age, disability, sexual orientation, political opinion or any other status protected in accordance with federal regulations and local employment rules and regulations.
Workplace Health and Safety: We endeavor to provide a safe and healthy workplace and comply with health and safety rules and laws. We are committed to maintaining a workplace that is free from violence, harassment, intimidation and other unsafe, disruptive or hostile conditions due to internal and external threats. We attempt to minimize exposure to potential safety hazards through continuously improving training and health and safety performance in all of our operations.
Our commitment to corporate social responsibility includes the environmentally prudent management of our facilities around the world. This effort is supported through collaboration with our suppliers to mitigate our indirect environmental impacts and with the assistance of environmental programs, education and training for employees.
Businesses must address environmental challenges, which includes, undertaking initiatives to promote greater environmental responsibility and encouraging the development of new technologies. Our environmental policies and practices aim to protect, conserve, and sustain the world’s natural resources, as well as to protect our customers and the communities in which we live and operate. We acknowledge that respect for human rights includes access to water and we identify the right to water as a fundamental human right.
EnerSys follows strict policies to ensure that the Company remains compliant with international environmental regulations, such as the European Union’s Battery Directive and the United States Environmental Protection Agency’s universal waste regulations. We aim to ensure that our operations and products meet or exceed all regulatory requirements.
Specific Principles of Our Commitment to the Environment
Developing and Improving Products: We understand that there are many responsibilities that come with being the leading manufacturer of industrial batteries and related energy products, and one of those is the development of products that will use resources efficiently. EnerSys works to eliminate waste and ensure that it is safely and responsibly handled and disposed.
Battery Recycling Program: We have a complete Battery Recycling Program to assist our customers in preserving our environment and compliance with recycling and waste disposal regulations. We will do everything we can to make sure batteries are recycled in an environmentally safe manner. It is an obligation we share as an industry.
Conflict Minerals: EnerSys complies with all legislation regarding the use of conflict minerals mined from the Democratic Republic of the Congo and adjoining countries. Businesses should support being conflict mineral-free and source only from suppliers or smelters that are conflict mineral-free. We conduct good faith inquiries regarding the country of origin of the subject minerals used in connection with our products. As part of our inquiry, we continue to monitor smelters for compliance. Our Conflict Minerals Report is filed annually pursuant to Rule 13p-1 under the Securities Exchange Act of 1934, as amended, and is publicly available on our website www.enersys.com, under the Investors link.
Continually Monitoring Our Performance: We engage in ongoing monitoring, controls and elimination, where possible, of all environmental emissions, discharges and waste generated by our operations. We set objectives and targets to ensure an ongoing commitment to continuous improvement in our environmental performance. EnerSys regularly reviews our business activity, engages our stakeholders about our objectives and targets, and assesses our environmental programs and practices as necessary to identify areas in which further improvements can be made.
ANTITRUST, FAIR COMPETITION & ANTI-CORRUPTION
Antitrust and fair competition laws operate to prevent competition from being undermined by anti-competitive practices, such as cartels and abuse of market power. EnerSys vigorously maintains a commitment to comply with all antitrust and fair competition laws, including the Sherman Act, the Clayton Act, and the Federal Trade Commission Act.
It is our goal to compete vigorously and fairly in the marketplace. We are committed to preventing corruption in all its forms and do not tolerate it in our business or in those with whom we do business. EnerSys is dedicated and diligently conforms with all anti-bribery and anti-corruption laws, including the Foreign Corrupt Practices Act of 1977 (FCPA) and the UK Bribery Act 2010.
Specific Principles of Our Commitment to Anti-Corruption and Fair Competition
Global Antitrust Compliance and Fair Competition Policy: Our Global Antitrust Compliance and Fair Competition Policy ensures that EnerSys and all of its employees comply with all laws, rules and regulations relating to antitrust and fair competition. This Global Antitrust Compliance and Fair Competition Policy is communicated to all employees. It prohibits a variety of practices that restrain trade, including but not limited to: price-fixing; tying and reciprocal dealing; exchanges of confidential information with competitors; agreements to limit competition, restrict markets, or not to compete; and acts designed to achieve or maintain monopoly power.
Anti-Corruption: No one acting on EnerSys’ behalf may use bribes, kickbacks, or other unethical and improper conduct, or engage in illegal and corrupt practices. We uphold all laws, such as the FCPA, relevant to countering bribery and corruption and will actively cooperate with regulatory authorities in the investigation and punishment of any act of corruption or bribery by any person employed by or associated with EnerSys. We carefully document uses of funds and assets, in accordance with accounting policies and guidelines, to ensure that bribery and corrupt activity does not occur within our business or among our employees and stakeholders. Our Code of Business Conduct and Ethics prohibits a variety of unethical and corrupt practices, including but not limited to, commercial bribery, kickbacks, bribes, fraud, and misuse of funds or improper influence.
COMMUNITY & STAKEHOLDER ENGAGEMENT
EnerSys understands that we are part of a broader community globally, wherever we do business. Engaging stakeholders, including indigenous peoples, as well as those from more at-risk populations, is a foundational element of our respect for human rights. Where practical, we are committed to dialogue and our goal is to listen, learn and consider the diverse views and local issues that affect the communities in which we operate. This includes a commitment to free, prior and informed consent (FPIC) with regard to indigenous peoples’ inherent and prior rights to their lands and resources, as defined and recognized by the United Nations Department of Economic and Social Affairs.
REPORTING & ACCOUNTABILITY
EnerSys strives to apply these principles, comply with applicable laws, and enforce our policies throughout our operations worldwide. A substantial part of that effort is ensuring that employees are aware of our policies through training and encouraging them to report any potential violations.
Employees who have questions or have concerns about the location where he or she works, should be encouraged to contact their supervisor, a member of the Human Resources department, or a member of the Legal Department.
Employees may also anonymously report their concerns by calling or e-mailing the EnerSys Ethics hotline (applicable country phone numbers and e-mail address are found in Attachment A to the EnerSys Code of Business Conduct and Ethics).