1.6. Confidential Information
Standard: Implement and adhere to adequate controls which ensure the privacy and protection of
information and intellectual property belonging to McKey, McKey’s suppliers, and third parties.
Expectation: Carefully protect information regarding McKey and its business, ensuring it is never
disclosed to anyone who is not authorized. Safeguard McKey information by keeping it secure, limiting
access, and avoiding discussing or revealing such information in public places. Respect the intellectual
property rights of others and take appropriate steps to safeguard the information of third parties. These
requirements extend even after the conclusion of a business relationship with McKey. If there are any
questions about whether information possessed is confidential, seek guidance from McKey before
disclosing.
1.7. Standards of Business Conduct
Standard: While the Standards of Business Conduct (“SBC”) for McKey’s employees does not apply
directly to suppliers, suppliers should ensure that the employees enjoy these same ethical standards.
Expectation: Notify McKey if you become aware (or suspect) that a McKey’s employee, or anyone
acting on McKey’s behalf, is involved in a violation of a law, regulation, or policy. We take violations of
the SBC seriously, and ask that any potentially unethical or illegal behavior by a McKey’s employee,
supplier, or auditing firm is immediately brought to our attention.
2.0 Management Systems
Standard: The policies and procedures (“management systems”) established regarding compliance with
laws, standards, and our expectations are essential to adherence with the Code. Suppliers should
establish a planning process to define the purpose, methods, frequencies, and responsibilities for
verification of activities. The management system that is established should address all of the key
elements within McKey’s SWA requirements, noted under the following 4 key categories:
• Business Integrity
• Human Rights
• Workplace Environment
• Environmental Management
Expectation: Effective management systems are essential for the efficient running of any business, and
involve all compliance areas. A management system begins with a planning process to define the
system's purpose, the methods that will be used to meet this purpose, how often internal verifications will
occur, and who is responsible for each component. These requirements should also be clearly identified
in job descriptions. Suppliers should monitor and update their systems regularly to continually improve
and remain up-to-date with changes in requirements.