Compliance and ethics
The commitments we make, and the ones we ask of our own suppliers.
Aerospace buyers no longer qualify a supplier on capability alone. Anti-corruption, export control, conflict minerals, chemical substances and a working channel for raising concerns are on the questionnaire. This page answers those lines before they are asked.
Business conduct
Six commitments, flowed down unchanged
Anti-corruption
No facilitation payment, no gift or hospitality capable of influencing a decision, in either direction. This applies to our people and to anyone acting on our behalf.
Fair competition
No price fixing, no market sharing, no exchange of commercially sensitive information with competitors.
Conflicts of interest
Declared, recorded and removed from the decision. Purchasing decisions are taken on documented criteria.
Labour and human rights
No forced labour, no child labour, freedom of association, working time and pay compliant with Tunisian law, and the same expected of our suppliers.
Health, safety and environment
Safety instructions, personal protective equipment, controlled handling and disposal of machining fluids, swarf and chemicals.
Confidentiality
Customer data is confidential by default and stays inside the contract it came from. See the information security page.
These commitments are passed to our own suppliers through the purchase conditions. A supplier that does not accept them is not approved.
Regulatory
Where we stand on the four declarations you will ask for
| Subject | Position | Status |
|---|---|---|
| REACH | Material and consumables are purchased with their safety data sheets, and any substance of very high concern is identified at purchasing. Declarations are issued per part on request. | On request |
| RoHS | The parts ESM machines are structural aluminium and steel components, not electrical or electronic equipment, so RoHS does not normally apply. Where a customer requires a statement, it is issued per part. | On request |
| Conflict minerals | ESM buys no tin, tantalum, tungsten or gold as raw material. Where these appear in tooling or in a purchased component, the declaration is obtained from the supplier and passed on. | On request |
| Export control | ESM works build-to-print on customer definitions. Where a definition is subject to export control, the customer states it and the restrictions are flowed down to everyone who touches the file, including partners. | In place through the purchase conditions |
| Counterfeit parts | Material and components are bought from the manufacturer or an authorised distributor, with certificates verified on receipt. Suspect items are quarantined and rendered unusable, never returned to the market. | In place — EN 9100 §8.1.4; customer requirements referencing AS6174 are applied through the purchase conditions |
| Product safety | Product safety is briefed to everyone whose work can affect it, and recorded. EN 9100 §8.1.3 and §7.3. | In place |
Raising a concern
A channel that does not go through the person concerned
Anyone — an employee, a supplier, a customer, a candidate — may report a suspected breach of these commitments: corruption, a safety risk concealed, falsified records, harassment, a counterfeit part, a deliberate deviation from a customer requirement.
Reports go to contact@esm.com.tn marked “Alert”.
Retaliation against someone who reports in good faith is itself a breach of these commitments.
Running a supplier compliance assessment?
Send us the questionnaire. We complete it, including the lines where the answer is not yet yes.
