CODE OF CONDUCT

NOTICE TO CONTRACTORS, SUPPLIERS AND LICENSEES

PING is committed to being the unquestioned leader in innovation, design, service and quality while providing an enjoyable environment for employees that allows them to fulfill their potential.  PING expects its Contractors, Suppliers and Licensees, and any of their subcontractors and suppliers (collectively “CSL”), to share PING’s commitment to the highest levels of product excellence and social responsibility.

PING expects its CSLs to foster respect for people, promote social responsibility, create a healthy and safe workplace, encourage environmental stewardship and achieve product excellence.

PING will continue to work cooperatively with its CSLs to ensure its standards are fully implemented.  Any CSL that wishes to establish and/or maintain a business relationship with PING shall agree to be bound by PING’s Code of Conduct (“Code”).
 

ETHICS AND VALUES

PING is committed to conducting its business (1) with a high standard of business ethics; (2) in compliance with applicable laws; and (3) with high regard for human rights and fair labor practices. While PING recognizes and respects the cultural differences that exist throughout the world, PING expects its CSLs and agents to share and uphold PING’s values and standards.
 

OVERSIGHT AND CODE OF CONDUCT

To facilitate CSL commitment to these values PING established a CSL Relations Group that has management and oversight responsibility for CSL accountability. This group develops programs and implements procedures aimed at ensuring compliance with PING's Code. Two functions of this group are (1) to educate CSLs regarding these expectations and (2) to coordinate assessment activities at production facilities.

This Code was established to reflect PING's desire to do business with CSLs that comply with the legal requirements applicable to the conduct of their business and who respect accepted international labor standards. The CSL Relations Group, together with PING's agents, ensures that CSLs are informed of and understand the terms of this Code.
 

EDUCATION AND TRAINING

PING believes that the success of its CSL accountability process requires effective education and training of PING’s employees, agents and CSLs. PING is committed to allocating the resources reasonably required to promote an understanding of these requirements.
 

ASSESSMENT AND COMPLIANCE

PING’s representatives and agents may make visits, including unannounced visits, to CSL’s facilities. PING's representatives and agents are required to promptly notify PING of any event of noncompliance with this Code.  In addition, assessments of production facilities may be conducted periodically by either a representative of the CSL Relations Group or by a third party engaged by PING. CSLs will be notified of the results of any assessment and offered guidance with respect to matters requiring correction or that need improvement.  PING reserves the right to suspend future orders or to terminate its relationship with any CSL for compliance failures.
 

COOPERATION AND COMMUNICATION

While PING believes our CSL accountability process promotes responsible working conditions, PING also believes that the continued cooperation and communication among all constituencies interested in this important area offer the best long-term prospects for improved labor conditions.
 

CODE OF CONDUCT

• Compliance with Laws: PING Contractors, Suppliers and Licensees, and any of their subcontractors and suppliers (collectively “CSL”) must comply fully with all legal requirements relevant to the conduct of their businesses, including those governing workers’ rights (which includes adoption and adherence to rules and conditions of employment that respect workers and, at a minimum, safeguard their rights), labor, social security, health, safety and the environment.
• No Child Labor: CSLs will not use child labor. A “child” refers to a person under the minimum age for employment established by local law, or the age at which compulsory school has ended, whichever is greater, but in no case under the age of 16.
• Employment is Voluntary: All labor must be voluntary. Forced, bonded, prison or indentured labor is not allowed. Workers must be allowed to maintain control over their identity documents.
• No Harassment or Coercion: CSLs will treat each worker with dignity and respect, and will not use corporal punishment, threats of violence or other forms of physical, sexual, psychological or verbal harassment, intimidation or abuse.
• Freedom of Association: To the extent permitted by the laws of the manufacturing country, CSLs must respect the right of workers to choose whether to form or join associations of their choice and to collectively bargain.  Workers shall not be subject to intimidation or harassment in the peaceful exercise of their right to join or refrain from joining any organization.
• Nondiscrimination: Workers should be hired on the basis of their ability and qualification to do the job, and not on the basis of personal characteristics or beliefs. CSLs will not unlawfully discriminate with regard to hiring, compensation, advancement, discipline, termination or retirement, on the basis of race, religion, age, nationality, social or ethnic origin, gender, sexual orientation, political opinion or disability.
• Wages and Benefits: CSLs must timely compensate all workers with wages, overtime premiums, and benefits, including holidays, leaves, and statutory severance when employment ends, that meet or exceed applicable law, local industry standards or collective agreements, whichever are higher.  We recognize human rights principles and strongly believe workers should have just and favorable remuneration ensuring for themselves and their families an existence worthy of human dignity, and supplemented, if necessary, by other means of social protection.  CSLs are encouraged to provide wages and benefits that meet basic needs and some discretionary income.  Where these goals are not met, CSLs shall work with PING to take legal and appropriate actions that seek to progressively realize these goals.
• Hours of Work/Overtime: CSLs will maintain reasonable employee work hours in compliance with applicable law and ensure they are not excessive. Workers shall not be required to work more than 48 hours per week with at least 24 consecutive hours of rest in every seven-day period; overtime must be voluntary, and except in exceptional circumstances, not to exceed 12 hours per week on a regular basis.
• Health and Safety: In compliance with applicable law, CSLs will provide workers with a safe and healthy workplace setting to prevent accidents and injury to health arising out of, linked with, or occurring in the course of work or as a result of the operation of CSLs’ facilities.  CSLs also will ensure reasonable access to potable water and sanitary facilities, fire safety, and adequate lighting and proper ventilation.
• Environment: CSLs will comply with all applicable laws regarding protection and preservation of the environment in their country. All input materials and components must be obtained from permissible sources consistent with applicable laws.  CSLs will adopt responsible measures to mitigate negative impacts that the workplace has on the environment.
• Anti-Corruption: CSLs must not tolerate, permit, or engage in bribery, corruption, or unethical practices whether in dealings with public officials or individuals in the private sector.
• Monitoring, Documentation and Compliance: CSLs will permit PING and its agents (including third parties designated by PING) to engage in assessment activities to confirm compliance with this Code, including unannounced onsite inspections of production facilities, immediate reviews of books and records relating to labor matters, and private interviews with workers. CSLs will maintain onsite all documentation that may be needed to demonstrate compliance with this Code and applicable laws and regulations.
• Communication of Standards: CSLs will take appropriate steps to ensure that the provisions of this Code are communicated to workers, and any subcontractor and its workers, including the prominent posting of a copy of this Code in the local language and in a place readily accessible to all such workers at all times.