Policies and Compliance Declarations
Sy-Klone International recognizes and supports the elevating accountability for ethical business practices and supply chain transparency in domestic and international laws and regulations. Sy-Klone holds itself, its employees, its resellers and its suppliers to a high standard on these matters because we believe it is the right way to do business, and further, because we want the customers and end users of Sy-Klone products to have confidence in the safety of the source materials and the manner in which these products are made and sold.
Accordingly, we are sharing a summary of some of the key policies and declarations we maintain to ensure that our footprint on these important issues is current and comprehensive:
- Sy-Klone has a Code of Business Ethics covering matters including: government contracting compliance, maintaining records, procurement integrity, business relationships, vendor responsibility, supply chain management, antitrust and competition policies, gratuities, kickbacks and bribes, lobbying activities, conflicts of interest, employment discussions and hiring of government employees, protecting assets and information, foreign parties, export controls, combatting trafficking in persons, equal employment opportunity, the False Claims Act, compliance and reporting, discipline, and non-retaliation. Sy-Klone is committed to exercising due diligence to prevent and detect criminal conduct and promoting an organizational culture that encourages ethical conduct.
- Sy-Klone has a Policy to Prevent Child Labor regarding both its direct employment practices and its position that it does not permit the use of child labor by any suppliers that do business with, or on behalf of, the Company.
- Sy-Klone’s current contracts with its suppliers and resellers include stated expectation that these parties will conduct any and all activities performed in connection with our contracts in a lawful manner, consistent with the highest standards of fair trade, fair competition and business ethics, including specific, relevant topics to the relationship representing pricing practices; export compliance; sanctioned countries, destinations, organizations, or individuals; combatting trafficking in persons; equal employment; government contracting; and other items of ethics.
- Conflict Minerals Declaration: Sy-Klone has asked, and will continue to require of our suppliers, that they identify any Conflict Minerals that they use in the manufacturing or purchasing of material that Sy-Klone sources from them and that they either: (a) do not contain Conflict Minerals or (b) if they do contain Conflict Minerals, that they originate from non-conflict sources, or from scrap or recycled sources. At this time, Sy-Klone can represent that none of our product specifications call for the use or inclusion of any Conflict Minerals and it is our expectation that our products are manufactured to specifications, such that no Conflict Minerals should be present in any of our products. Further, based on active due diligence in the supply chain discipline and information/certification requested/required from our suppliers, Sy-Klone certifies that, to the best of its knowledge, our products do not contain Conflict Minerals covered by the SEC’s disclosure rules.
- Restriction of Hazardous Substances (RoHS) Compliance Declaration: Sy-Klone is aware of the requirements imposed by the Directive on the restriction on the use of certain hazardous substances in electrical and electronic equipment (RoHS 3 - Directive 2015/863EU). To Sy-Klone’s best knowledge and belief, based on active due diligence in the supply chain discipline and information/certification requested/required from our suppliers, none of the articles used in the construction of Sy-Klone’s products contain any known or intentionally-added, restricted substances, as listed in the referenced regulations, in concentrations above limits specified in the regulations.
- Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) Compliance Declaration: Additionally, to Sy-Klone’s best knowledge and belief, based on active due diligence in the supply chain discipline and information/certification requested/required from our suppliers, none of the articles used in the construction of Sy-Klone’s products contain Substances of Very High Concern (SVHC) in a concentration above the allowed threshold of 0.1% w/w (by weight of the substance compared to the weight of the whole article).
- CAS Numbers: Sy-Klone International has consulted with the Chemical Abstract Service (“CAS”), a division of the American Chemical Society, and we have been advised by the CAS Scientific Information Research Specialist that, “CAS Registry Numbers are assigned to specific chemicals (including specific polymers), but not to objects composed of several different chemicals, or to assembled products.” As a result, CAS numbers are not applicable to Sy-Klone’s assembled products.
- Toxic Substances Control Act Compliance (TSCA) Declaration: Sy-Klone International’s products are generally complex objects, comprised of components from multiple suppliers, and the individual components often include multiple articles. Sy-Klone International is aware of the requirements imposed by the Toxic Substances Control Act. To Sy-Klone’s best knowledge and belief, based on active due diligence in the supply chain discipline and information/certification requested/required from our suppliers, none of the restricted materials subject to the Toxic Substances Control Act, are added to, or used in the construction of, Sy-Klone’s products.
We are sharing this information proactively, for a few reasons: (1) first, ‘transparency and trust’ is one of our corporate values and we think it is consistent with this value to be direct on important issues of ethics and supply chain practices; and (2) we understand that many of you are asked for information on these topics in your own supply chain, and as an extension of your supply chain in many cases, we want to make responding to these inquiries easier for you by providing our declarations.