Legal
LEGAL
GALATECH INTERNATIONAL (INT)
UK Registered Address:
31 Thornbrook House, Weyside Park, Catteshall Lane, Godalming, GU7 1FP, England.
USA Registered Address:
1009 Vermont Ave, Suit 2 Pittsburgh PA 15234, USA
Contact details:
info@galatechltd.com
Phone: +44-782-817-2821
WhatsApp: +44-749-462-3649
Skype ID: EnochSimeon
Personnel To Contact:
The Admin Team
Regulatory Authorities:
UK - Companies House
UK HMRC - VAT Registration Number (VAT)
UK - Economic Operators Registration and Identification (EORI)
UK - London Metal Exchange (LME)
USA - Pennsylvania Department Of State
USA - Internal Revenue Service (IRS)
USA - Entity Number (EN)
USA - Certification Number (CN)
Registration Details:
UK - Company House: 10496952
UK HMRC - VAT Registration Number (VAT): 352668479
UK - Economic Operators Registration and Identification number: GB352668479000
UK - London Metal Exchange (LME)
USA - Pennsylvania Department of State: DSCB: 15-8821(rev. 2/2017)
USA - Internal Revenue Service EIN: 86-2341779
USA - Entity Number: 7225204
USA - Certification Number: TSC 220119100684-1
Some of Our Clients
Baird & Co Refinery (UK)
Dillon Gage Refinery (USA)
GALATECH INT
OEDC Supply Policy
Introduction
Galatech Int, we believe that corporate responsibility is an integral part of sustainable business management and employees behaviour. In going about our business we embrace the concepts of accountability and transparency.
Galatech Int has always set high standards for the way we conduct business. In turn, we expect suppliers to conduct business responsibly, with integrity and transparency.
Furthermore, we expect suppliers to treat all employees fairly, honestly and with respect, in full compliance with the following requirements. This code aren’t meant to provide an exhaustive list of our expectations of suppliers, just the things that matter most to us including
a. Human rights
b. Occupational Health & Safety
c. Business Ethics
d. Environment/ Land Right
e. Compliance
f. Child Labour
g. Conflict minerals
h. Employment and industrial relations
i. Freedom of association
j. HIV/AIDS
k. Privacy
l. Products and Services
m. Security
n. Treating employees with respect and dignity
o. Wages
p. Working hours
Human Rights and Labour Conditions
We take a zero tolerance approach to modern slavery and human trafficking and expect our suppliers to do the same.
- Suppliers must ensure that all employees have the legal right to work and any migrant workers should be in possession of a valid work permit issued by the relevant authority.
- Suppliers shall not permit the use of forced or involuntary labour of any type (i.e. forced, trafficked, bonded, indentured or involuntary prison labour) and workers shall be free to leave employment without penalty on the provision of reasonable notice.
- The use of physical abuse, verbal or sexual harassment or intimidation of workers shall be prohibited by suppliers.
- Suppliers shall respect the rights of employees to join or refrain from joining worker organisations and will allow workplace access for such organisations to facilitate their representative functions.
- Suppliers shall not discriminate in hiring, compensation, access to training, promotion, termination or retirement on the grounds of race, caste, religion, age, nationality, social or ethnic origin, sexual orientation, gender identity or expression, marital status, family status, pregnancy, union membership, political affiliation, disability or other legally protected class.
- Suppliers shall ensure that their employees are fairly compensated and that, at a minimum, they comply with all applicable wage and hour laws, or industry standards approved on the basis of collective bargaining, whichever is higher. Deductions to wages shall only be made in accordance with applicable law or under collective agreement.
- Suppliers must provide for working hours that comply with national laws and industry standards. Total worked hours shall not exceed the maximum allowable under local legislation.
- All overtime shall be voluntary and compensated in accordance with applicable laws.
- Suppliers shall not seek to avoid obligations to workers under labour or social security laws and regulations arising from the regular employment relationship through the excessive use of fixed-term contracts, labour-only contracting, subcontracting, home-working or apprenticeship schemes.
- We expect our suppliers to meet the disclosure requirements under the Modern Slavery Act 2015 and undertake the necessary due diligence to ensure that there is no modern slavery or human trafficking in their operations and supply chains.
Occupational Health & Safety
- Suppliers to Galatech Int shall ensure all employees work within safe and humane conditions, including providing adequate training and effective protective equipment to safely carry out their duties. Suppliers will also provide access to clean toilet facilities, potable water and sanitary facilities for food storage and meet the basic needs of workers while respecting their dignity.
- We expect our suppliers to provide their employees, their own contractors, the local
community and the users of their products with a safe and healthy workplace and should make sure a senior management representative is responsible for health and safety, and that appropriate policies and procedures are in place.
- Suppliers must adopt a proactive attitude to health and safety. Risks linked to their activity shall be identified, evaluated and either eliminated or mitigated. Our suppliers must take appropriate measures to limit and, where practicable, avoid such risks.
- Suppliers will avoid substances dangerous to their employees’ health and safety.
- These include, but are not limited to, carcinogenic, mutagenic and toxic substance
dangerous to peoples’ health and reproductive (CMR) system.
- Suppliers do business with Galatech Int has to comply with the general Safety, Health and Environment (SHE) rules and SHE rule for Contractors – Suppliers working on Galatech Int sites have to comply with our Access Regulations
- Facilities must be constructed and maintained in accordance with applicable laws and regulations and accommodation, Suppliers will also ensure that there are appropriate exits, procedures and equipment in place to deal with emergency situations.
Business Ethics
- In keeping with our commitment to exercising appropriate standards of professionalism and ethical conduct in all business activities, Galatech Int will not tolerate bribery or corruption in any form, or any breach of its policy
- Suppliers and business partners are not permitted to directly or indirectly promise, offer or provide any improper advantage to any person or entity, including officials of a government or a government-controlled entity.
- Galatech Int employees are not allowed to accept any such advantage and we expect the same approach in business dealings from our business partners, suppliers and third parties.
- Suppliers are expected to maintain accurate records of their activities and performance that clearly demonstrate compliance with all applicable standards, regulations and Galatech Int requirements.
- Suppliers must disclose any personal relationships, economic interest or other ties to their business held by an employee or contractor with Galatech Int.
- Suppliers shall provide Galatech Int with high-quality products and services that meet all applicable quality and safety standards, and demonstrate that they have robust safety and quality-management systems in place. We expect suppliers to immediately report to Galatech Int any concerns about product safety.
- Suppliers shall take appropriate measures to secure and protect all confidential information related to its relationship with Galatech Int and use it only for the purpose authorised under contractual agreement. This obligation shall remain in force regardless of the status of the business relationship.
Environment/Land Rights
- Suppliers to Galatech Int shall carry out operations with care for the environment and at a minimum and will comply with all applicable environmental laws and regulations.
- Galatech Int expects suppliers to support its sustainability commitments through the adoption of good operating practices. In particular, suppliers should seek to optimise their use of natural resources and minimise the generation of waste.
- Suppliers will endeavour to secure their raw materials from fully traceable, sustainable sources and where required, will be members of relevant multi-stakeholder initiatives or reporting platforms that support Galatech Int responsible sourcing ambition.
- Suppliers shall also comply with any additional category and specific requirements
regarding the goods or services provided to Galatech Int. - Suppliers shall respect the rights to land tenure of local communities and indigenous peoples impacted by its operations, including its raw material sourcing, and will adhere to the Principle of Free, Prior and Informed Consent.
- As a minimum, we expect our suppliers to comply with all local and national environmental legislation, regulations and directives to protect and improve the environment, and have developed reviewed and recorded processes in place to make sure they comply.
- We expect suppliers to avoid the use of toxic substances, in the event no alternative is available, we expect our suppliers to follow the environmental legislation and meet the requirements to ensure their safe handling and disposal.
- We expect suppliers to have action plans in place to manage their environmental impact, e.g. energy reduction and waste management programme. Where appropriate, our suppliers must also comply with additional environmental requirements specific to the products and services supplied to Galatech Int. Any specific requirements will be outlined in our contract.
Compliance
- Galatech Int expects suppliers to ensure their operations comply with all applicable laws and regulations at a minimum. Furthermore, we expect that all suppliers adhere to Galatech Int requirements, including the standards as laid out in this and our other Code of Conduct and policy.
- Suppliers shall have the appropriate processes and systems in place to do so, including a means for the confidential reporting of concerns about misconduct or unethical behaviour and an appropriate mechanism for addressing any issues identified. Where issues are identified through internal reporting, whistle-blowers will be protected from any negative repercussions.
- Suppliers shall cooperate with Galatech Int to allow our company, or any authorised third party, to conduct audits to verify compliance with these standards or other required certifications. In the event deficiencies are identified, the supplier will take the steps necessary within an acceptable timeframe to correct any deficiency to Galatech Int satisfaction. Suppliers shall immediately report any concerns about compliance with legal requirements or any aspect of this code, to their designated point of contact or through our confidential reporting facility:
- Where suppliers are found to have contravened the requirements set out in this Code, Galatech Int reserves the right to terminate any associated agreement or business relationship.
- We ensure everything we do is ethical and lawful, and that we work in socially and environmentally sustainable ways
- Our supplier code of conduct is an integral part of the contractual documents between Galatech Int and its suppliers. It’s important to us that our suppliers have the same beliefs and standards that we expect of ourselves. Our code of conduct gives you a good idea of what it means to work with Galatech Int and the expectations that we have. We are asking all of our suppliers to sign up to the code of conduct.
- We expect our suppliers to have the right policies, processes and level of compliance in place to meet our standards, we also expect you to ensure that your suppliers and sub-contractors do the same. On selecting suppliers, we consider these principles and your compliance with the code of conduct.
- Compliance is the minimum standard we expect. At times, we may also monitor your compliance by using an independent third party; we will work together to ensure continual improvements are reviewed and compliance is met.
- We also expect openness and transparency in our relationships with our suppliers, and will work together to improve our sustainability performance, while supporting continuous improvement to meet the principles within this code.
Child labour
- We do not support the use of child labour in any circumstances. So suppliers shall not permit child labour to be used in any operation connected with Galatech Int. Not below the
age for finishing compulsory schooling, or 15 years of age (whichever is the greater) may be employed by a supplier, subject to ILO exceptions.
- Where young people under the age of 18 are employed, suppliers will ensure that their work is not likely to be harmful to their health and/or development, including not working under hazardous conditions and ensuring compliance with all applicable laws.
- Where children under the age of 18 are legally employed, they must not be employed at night or in hazardous conditions. All suppliers must work towards elimination of all child labor and this should be in a manner consistent with the best interests of the children concerned.
Conflict minerals
- We expect our suppliers to make us aware of ‘conflict minerals’ that are sourced from the Democratic Republic of Congo and surrounding countries (and any other countries that become applicable) which are used to finance armed conflict in that region, and that may exist in products or equipment provided by suppliers and all parties within their supply chain to Galatech Int.
Employment and industrial relations
- Suppliers must not discriminate in hiring and employing workers on the basis of race, caste, birth, social or ethnic origin, religion, nationality, age, gender, identity or expression, marital status, sexual orientation, disability, maternity, union membership or political affiliation.
Freedom of Association
- Employees should be free to join trade unions (or other kinds of representation) and where appropriate, to carry out representative functions at work in accordance with relevant legislation. Employees should not be discriminated against, or be treated unfavourably or differently because they carry out representative functions.
HIV/AIDS
- If HIV/AIDS is a significant issue where they are operating, we expect our suppliers to educate workers about the risk and that access to treatment and medication is provided as necessary. It’s important not to tolerate discrimination against any worker who is (or is thought to be) HIV-positive or living with AIDS.
Privacy
- We expect vendors, their contractors, and sub-contractors to adhere to all privacy legislation; the Data Protection Act and the EU General Data Protection Regulation (GDPR) in particular. Galatech Int takes Privacy & Data Protection very seriously and expects its vendors to do likewise.
Products and Services
- We expect our suppliers to meet environmental legislation, health and safety
policies in the development of their products and services. In order to eliminate or mitigate health and safety and or environmental impacts from their products during their total life cycle; while maintaining and/or improving the quality of usage of their products.
- Suppliers’ products and services provided to Galatech Int are expected to comply with the European Directive (2002/95/EC) RoHS 11 and the European Regulation (1907/2006/EC) and relevant legislation.
- We do not support the use of asbestos in any equipment, product and packaging
supplied. Suppliers are encouraged to propose eco-designed, environmentally
friendly and socially responsible products and services.
- We expect that suppliers providing products and services should preferably operate a Quality Management System that is compliant to ISO9001:2015.
Security
- We expect suppliers, their contractors, and sub-contractors to adhere to the security requirements placed on them and ensure that Galatech Int systems and data are kept secure at all times. Suppliers should aspire to be ISO27001:2013 compliant, and, where required, certified to demonstrate their commitment to keeping our information secure.
GALATECH INT
Anti-Bribery & Anti-Corruption Policy
CONTENTS:
1. What our policy covers
2. Policy statement
3. Who is covered by the policy?
4. Definition of bribery
5. What is and what is not acceptable
a. Gifts and hospitality
b. Facilitation payments and kickbacks
c. Political contributions
d. Charitable contributions
6. Employee Responsibilities
7. What happens if I need to raise a concern
a. How to raise a concern
b. What to do if you are victim of bribery or corruption
c. Protection
8. Training and communication
9. Record Keeping
10. Monitoring and reviewing
1. What our policy covers:
1.1 This anti-bribery policy exists to set out the responsibilities of our company and those who work for us in regards to observing and upholding our zero-tolerance position on bribery and corruption.
1.2 It also exists to act as a source of information and guidance for those working for our company, as it helps them recognise and deal with bribery and corruption issues, as well as understands their responsibilities.
2. Policy statement:
2.1 Our company is committed to conducting business in an ethical and honest manner, and is committed to implementing and enforcing systems that ensure bribery is prevented. Our company has zero-tolerance for bribery and corrupt activities. We are committed to acting professionally, fairly, and with integrity in all business dealings and relationships, wherever in the country we operate.
2.2 Our company will constantly uphold all laws relating to anti-bribery and corruption in all the jurisdictions in which we operate. We are bound by the International laws, including any Bribery Act in regards to our conduct both at home and abroad.
2.3 Our company recognises that bribery and corruption are punishable by up to ten years of imprisonment and a fine. If our company is discovered to have taken part in corrupt activities, we may be subjected to an unlimited fine, be excluded from tendering for public contracts, and face serious damage to our reputation. It is with this in mind that we commit to preventing bribery and corruption in our business, and take our legal responsibilities seriously.
3. Who is covered by the policy?
3.1 This anti-bribery policy applies to all employees (whether temporary, fixed-term, or permanent), consultants, contractors, staff, trainees, home workers, casual-workers, agency staff, volunteers, interns, sponsors, or any other person or persons associated with us (including third parties), or their employees, no matter where they are located (within or outside of the UK& USA). The policy also applies to Officers, Board of Directors, and/or Committee members at any level.
3.2 In the context of this policy, third-party refers to any individual or organisation our company meets and works with. It refers to actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies – this includes their advisors, representatives and officials, politicians, and public parties.
3.3 Any arrangements our company makes with a third party is subject to clear contractual terms, including specific provisions that require the third party to comply with at least the minimum legal requirement and transparency.
4. Definition of Bribery:
4.1 Bribery refers to the act of offering, giving, promising, asking, agreeing, receiving, accepting, or soliciting something of value or of an advantage so as to induce or influence an action or decision.
4.2 A bribe refers to any inducement, reward, or object/item of value offered to another individual in order to gain commercial, contractual, regulatory, or personal advantage.
4.3 Bribery is not limited to the act of offering a bribe. If an individual is on the receiving end of a bribe and they accept it, they are also breaking the law.
4.4 Bribery is illegal. Employees must not engage in any form of bribery, whether it be directly, passively (as described above), or through a third party (such as an agent or distributor). They must not bribe a foreign public official anywhere in the world. They must not accept bribes in any degree and if they are uncertain about whether something is a bribe or a gift or act of hospitality, they must seek further advice from the company’s compliance manager.
5. What is and what is not acceptable:
5.1 This section of the policy refers to 4 areas:
• Gifts and hospitality.
• Facilitation payments.
• Political contributions.
• Charitable contributions.
5.2 Gifts and hospitality
Our company accepts normal and appropriate gestures of hospitality and goodwill (whether given to/received from third parties) so long as the giving or receiving of gifts meets the following requirements:
a. It is not made with the intention of influencing the party to whom it is being given, to obtain or reward the retention of a business or a business advantage, or as an explicit or implicit exchange for favours or benefits.
b. It is not made with the suggestion that a return favour is expected.
c. It is in compliance with local law.
d. It is given in the name of the company, not in an individual’s name.
e. It does not include cash or a cash equivalent (e.g. a voucher or gift certificate).
f. It is appropriate for the circumstances (e.g. giving small gifts around Christmas or as a small thank you to a company for helping with a large project upon completion).
g. It is of an appropriate type and value and given at an appropriate time, taking into account the reason for the gift.
h. It is given/ received openly, not secretly.
i. It is not selectively given to a key, influential person, clearly with the intention of directly influencing them.
j. It is not above a certain excessive value, as pre-determined by the company’s compliance manager (usually in excess of £100 or $132).
k. It is not offer to, or accepted from, a government official or representative or politician or political party, without the prior approval of the company’s compliance manager.
5.3 Where it is inappropriate to decline the offer of a gift (i.e. when meeting with an individual of a certain religion/ culture who may take offence), the gift may be accepted so long as it is declared to the compliance manager, who will assess the circumstances.
5.4 Our company recognises that the practice of giving and receiving business gifts varies between countries, regions, cultures, and religions, so definitions of what is acceptable and not acceptable will inevitably differ for each.
5.5 As good practice, gifts given and received should always be disclosed to the compliance manager. Gifts from suppliers should always be disclosed.
5.6 The intention behind a gift being given/ received should always be considered. If there is any uncertainty, the advice of the compliance manager should be sought.
5.7 Facilitation Payments and Kickbacks, our company does not accept and will not make any form of facilitation payments of any nature. We recognise that facilitation payments are a form of bribery that involves expediting or facilitating the performance of a public official for a routine governmental action. We recognise that they tend to be made by low level officials with the intention of securing or speeding up the performance of a certain duty or action.
5.8 Our company does not allow kickbacks to be made or accepted. We recognise that kickbacks are typically made in exchange for a business favour or advantage.
5.9 Our company recognises that, despite our strict policy on facilitation payments and kickbacks, employees may face a situation where avoiding a facilitation payment or kickback may put their/their family’s personal security at risk. Under these circumstances, the following steps must be taken:
a. Keep any amount to the minimum.
b. Ask for a receipt, detailing the amount and reason for the payment.
c. Create a record concerning the payment.
d. Report this incident to your line manager.
5.10 Political Contributions
Our company will not make donations, whether in cash, kind, or by any other means, to support any political parties or candidates. We recognise this may be perceived as an attempt to gain an improper business advantage.
5.11 Charitable Contributions
Our company accepts and indeed encourages the act of donating to charities– whether through services, knowledge, time, or direct financial contributions (cash or otherwise) – and agrees to disclose all charitable contributions it makes.
5.12 Employees must be careful to ensure that charitable contributions are not used to facilitate and conceal acts of bribery.
5.13 We will ensure that all charitable donations made are legal and ethical under local laws and practices, and donations are not offered/ made without the approval of the compliance manager.
6. Employee Responsibilities:
6.1 As an employee of our company, you must ensure that you read, understand, and comply with the information contained within this policy, and with any training or other anti-bribery and corruption information you are given.
6.2 All employees and those under our control are equally responsible for the prevention, detection, and reporting of bribery and other forms of corruption. They are required to void any activities that could lead to, or imply, a breach of this anti-bribery policy.
6.3 If you have reason to believe or suspect that an instance of bribery or corruption has occurred or will occur in the future that breaches this policy, you must notify the compliance manager.
6.4 If any employee breaches this policy, they will face disciplinary action and could face dismissal for gross misconduct. A Director has the right to terminate a contractual relationship with an employee if they breach this anti-bribery policy.
7. What happens if I need to raise a concern?
7.1 This section of the policy covers 3 areas:
a. How to raise a concern.
b. What to do if you are a victim of bribery or corruption.
c. Protection.
7.2 How to raise a concern, if you suspect that there is an instance of bribery or corrupt activities occurring in relation to our company, you are encouraged to raise your concerns at as early a stage as possible. If you’re uncertain about whether a certain action or behaviour can be considered bribery or corruption, you should speak to your line manager, the compliance manager, the Director, or the Head of Governance and Legal.
7.3 Our company will familiarise all employees with its whistleblowing procedures so employees can vocalise their concerns swiftly and confidentially.
7.4 What to do if you are a victim of bribery or corruption, You must tell your compliance manager as soon as possible if you are offered a bribe by anyone, if you are asked to make one, if you suspect that you may be bribed or asked to make a bribe in the near future, or if you have reason to believe that you are a victim of another corrupt activity.
7.5 Protection - If you refuse to accept or offer a bribe or you report a concern relating to potential act(s) of bribery or corruption, we understands that you may feel worried about potential repercussions. Galatech Int will support anyone who raises concerns in good faith under this policy; even if investigation finds that they were mistaken.
7.6 Our company will ensure that no one suffers any detrimental treatment as a result of refusing to accept or offer a bribe or other corrupt activities or because they reported a concern relating to potential act(s) of bribery or corruption.
7.7 Detrimental treatment refers to dismissal, disciplinary action, treats, or unfavourable treatment in relation to the individual concern.
7.8 If you have reason to believe you’ve been subjected to unjust treatment as a result of a concern or refusal to accept a bribe, you should inform your line manager or the compliance manager immediately.
8. Training and communication:
8.1 Our company will provide training on this policy as part of the induction process for all new employees. Employees will also receive regular, relevant training on how to adhere to this policy, and will be asked annually to formally accept that they will comply with this policy.
8.2 Our company’s anti-bribery and corruption policy and zero-tolerance attitude will be clearly communicated to all suppliers, contractors, business partners, and any third parties at the outset of business relations, and as appropriate thereafter.
8.3 Our company will provide relevant anti-bribery and corruption training to employees etc. where we feel their knowledge of how to comply with the Bribery Act needs to be enhanced. As good practice, all businesses should provide their employees with anti-bribery training where there is a potential risk of facing bribery or corruption during work activities.
9. Record keeping:
9.1 Our company will keep detailed and accurate financial records, and will have appropriate internal controls in place to act as evidence for all payments made. We will declare and keep a written record of the amount and reason for hospitality or gifts accepted and given, and understand that gifts and acts of hospitality are subject to managerial review.
10. Monitoring and reviewing:
10.1 Our company compliance manager is responsible for monitoring the effectiveness of this policy and will review the implementation of it on a regular basis. They will assess its suitability, adequacy, and effectiveness.
10.2 Internal control systems and procedures designed to prevent bribery and corruption are subject to regular audits to ensure that they are effective in practice.
10.3 Any need for improvements, will be applied as soon as possible. Employees are encouraged to offer their feedback on this policy if they have any suggestions for how it may be improved. Feedback of this nature should be addressed to the compliance manager.
10.4 This policy does not form part of an employee’s contract of employment and Galactic Int may amend it at any time so to improve its effectiveness at combatting bribery and corruption.
GALATECH INT
Covid-19 Statement
We are committed to the health and safety of our staff, customers and all associates of Galatech INT and to help reduce the spread of Covid-19, so Galatech INT will be conducting all business meetings and communication remotely via video call, email and posting. Please ensure you have access to some sort of device that is compatible with the usual communication technology. For more information please contact our Admin Team.
Galatech INT therefore ask every one of our staff, customers, partners and associates to corporate with the government in stopping the spread of this deadly virus by observing all the rules and taking the necessary precautions such as Wear mask, wash hands and keep your two meters distance.
Furthermore, Galatech INT is asking everyone worldwide to comply with their own government's statement which is meant to defeat this virus.