![\"Client](\"https:\/\/www.nsm-seating.com\/content\/uploads\/2024\/05\/Client-Privacy-Practices-1.png\" "\\"Client")
\n\n\t1. CORE VALUES<\/strong>\n\n1.1. Values<\/strong>\n1.4.1. Supplier shall comply with all safety rules and signage while on NSM property.
\n1.4.2. Supplier shall follow all infection control guidelines while on NSM property and when interacting with NSM clients. Supplier shall report any exposure to pathogens by its employees when on NSM property within 24 hours to NSM at compliance@nsm-seating.com<\/a>.\n2. COMPLIANCE<\/strong>
\nSupplier shall comply with all terms of this Code of Conduct, including those specifically enumerated below, and shall ensure that any subcontractor of Supplier shall also comply with said terms.\n2.1. Safeguarding Protected Health Information (PHI)<\/strong>
\nCertain situations may necessitate sharing Protected Health Information (“PHI”) of NSM clients. As applicable, Suppliers shall operate in compliance with the Federal Health Insurance Portability and Accountability Act (HIPAA), Personal Information Protection and Electronic Documents Act (PIPEDA), Canadian provincial and territorial privacy laws, and any other applicable local, state, or federal requirements.\n2.2. Fraud, Waste, and Abuse (including Anti-Kickback, Stark and Discount Safe Harbor)<\/strong>
\nIn general, Suppliers should ensure they comply with applicable Fraud, Waste, and Abuse laws, rules, and regulations, including but not limited to, the Federal Anti-Kickback Statue, and the STARK Law – Section 1877 of the Social Security Act (42 U.S.C. \u00a7 1395nn).
\n2.2.1. All Supplier pricing, discounts, programs, promotions must be provided in advance of purchase in accordance with the Discount Safe Harbor of the Federal Anti-Kickback Statute, or other Safe Harbors when applicable.
\n2.2.1.1. Where NSM and Supplier have a commercial agreement inclusive of defined pricing and discounts, Supplier shall not provide transactional discounting at the request of NSM employees or its sales staff.
\n2.2.1.2. All Supplier promotions, temporary discounts, free upgrades, or free accessories must receive prior written approval by NSM Supply Chain in advance of communication or implementation by Supplier.
\n2.2.1.3. Any transactional discount offered to NSM employees or locations, not approved by NSM Supply Chain, will be deemed to have been offered to all NSM employees and locations and will become the new defined price for a period of not less than 180 days.\n2.3. Legal and Regulatory Compliance<\/strong>
\n2.3.1. All products shall be compliant with all applicable local, state, and federal laws governing the delivery address on the PO. Products are to be developed, sourced, and produced in compliance with all local, state, and federal laws, industry requirements, and NSM policies.
\n2.3.1.1. Supplier shall comply with all other applicable international laws and regulations, including those relating to international trade (e.g., sanctions, export controls, and reporting obligations), data protection, and antitrust\/competition laws.
\n2.3.2. Supplier shall be responsible for all regulatory compliance interactions with the Food and Drug Administration (FDA), including, without limitation, adverse event reporting, product complaints, and annual reports as may be legally required.
\n2.3.2.1. Suppliers of wheelchair components shall be compliant with FDA regulations including Quality Management System. Upon request by NSM, supplier shall provide a copy of its quality manual for NSM review.
\n2.3.2.2. Where required, Supplier shall obtain a 510(k) and, upon NSM’s request, shall provide a copy to NSM within 10 days.
\n2.3.2.3. PDAC Coding – Where required, Supplier shall obtain and maintain PDAC verification. NSM recommends that suppliers secure PDAC verification even where not required. In any documentation provided by Supplier to NSM that includes HCPCs coding, Supplier should note any utilization of a HCPCs code where not PDAC verified.
\n\u2022 All changes or loss of PDAC verification must be immediately reported to NSM-SupplyChain@nsm-seating.com<\/a>, compliance@nsm-seating.com<\/a> and mdm@nsm-seating.com<\/a>.
\n2.3.3. Product Hygiene Compliance (Pre-Ship) – Supplier shall have, maintain, and perform a pre-ship hygiene routine to ensure product safety. NSM reserves the right to review pre-ship hygiene procedures and documentation upon request.
\n2.3.4. Recalls – In the event of a recall, Supplier shall notify NSM via NSM-SupplyChain@nsm-seating.com and compliance@nsm-seating.com<\/a>.
\n2.3.5. California Proposition 65 – Supplier bears responsibility for compliance with California Proposition 65, including all California Proposition 65 labeling requirements. NSM will not label products on Suppliers behalf or accept charges or fines associated with California Proposition 65 product compliance or labeling failures.\n2.4. Labor Practices<\/strong>
\n2.4.1. NSM is committed to treating people with dignity and respect and requires that our Suppliers do the same. Supplier shall comply with all applicable laws regarding labor practices.
\n2.4.2. Supplier shall not discriminate against or harass an individual on the basis of race, color, religion, gender, pregnancy, HIV status, health status, sexual orientation, national origin, age, disability, veteran’s status, union membership, marital status, or political affiliation.
\n2.4.3. All of Supplier’s employees shall be provided a total compensation package, including wages, overtime pay, benefits, and paid leave, which meets or exceeds the legal minimum standards or appropriate prevailing industry standards, whichever is higher. Compensation terms established by legally binding collective bargaining agreements shall be implemented and adhered to.
\n2.4.4. Under no circumstances shall a Supplier use forced labor, whether in the form of compulsory or trafficked labor, indentured labor, bonded labor or other such forms. Mental and physical coercion, slavery, and human trafficking are prohibited.
\n2.4.5. Under no circumstances shall a Supplier employ individuals under the age of 15 or under the local legal minimum age for work or mandatory schooling, whichever is higher. When young workers are employed they must not do work that is mentally, physically, socially or morally dangerous or harmful or that interferes with their schooling by depriving them of the opportunity to attend school.
\n2.4.6. Supplier shall enforce upon its suppliers the same standards as defined in this section.
\n2.5. Risk and Liability
\n2.5.1. Supplier warranties for defects in material and workmanship shall be no less than 1 year from delivery to client. NSM shall not be liable to perform warranty repairs at its own cost unless mutually agreed upon, and in no event if the defect rate exceeds 1% of annual transactions of the applicable parts\/product.
\n2.5.2. Insurance Coverage – Supplier shall provide a Certificate of Insurance with National Seating & Mobility, Inc. named as an additional insured and with evidence of a minimum coverage of $1,000,000 per occurrence and $5,000,000 aggregate.
\n2.5.2.1. Supplier shall provide an updated COI annually to mdm@nsm-seating.com<\/a>. Failure to provide an updated COI within 10 days of request will result in suspension of business until remedied.
\n2.6. Responsible and Transparent Sourcing and Manufacturing
\n2.6.1. Supplier shall source Conflict Minerals from sources that are DRC Conflict free. Upon request, Supplier shall provide transparency as to the source of any Conflict Mineral.
\n2.6.2. Supplier shall ensure all of its suppliers follow the same standards as defined above. NSM reserves the right to audit Supplier’s suppliers for compliance with this Code of Conduct. Supplier agrees that upon such request, and with notice of at least 10 days, Supplier shall fully cooperate with NSM to facilitate such audits, which may include, without limitation, site visits or review of documentation.
\n2.6.2.1. In no event shall NSM’s right to audit provide NSM access to commercial information, pricing, volume, etc. between Supplier and its suppliers.
\n2.6.3. Environmental, Social and Corporate Governance (ESG)
\n2.6.3.1. NSM encourages Suppliers to adopt an environmental, social and corporate governance policy and implement sustainable systems. Suppliers should understand, and take account of, the environmental and social impacts of their own operations and their supply chains. Suppliers are also expected to adopt suitable global environmental and social standards where local laws and regulations are absent. The following are best practices for Supplier’s consideration.
\n\u2022 Resource Efficiency: Sustainable businesses minimize the use of natural resources. Suppliers are expected to have commitments to improve resource efficiency, including minimizing use of scarce or non-renewable resources, by using recycled materials where possible and by recycling the materials that they use.
\n\u2022 Energy: Energy efficiency reduces the use of resources and reduces costs. Suppliers should aim to reduce energy consumption in the creation and use of their products and services.
\n\u2022 Water: Suppliers should aim to sustainably manage their use of water in their own operations, supply chains, and their products and services. This includes minimizing the use of water in regions where water is scarce and ensuring that water discharges are free from pollution.
\n\u2022 Waste: Suppliers should have targets and processes to reduce waste from their own operations. This should include reducing waste and ensuring waste is properly disposed of. Suppliers should also be aware of waste issues in their supply chains and work with their own suppliers to minimize impacts.
\n\u2022 Biodiversity: Suppliers should aim to understand and to protect biodiversity in their local environment and communities. They should also seek to understand and reduce impacts from their own supply chains by using sustainable sourcing.
\n\u2022 Product Standards: Suppliers should ensure that their products meet the highest quality standards and do not contain ingredients or components that might pose a threat to human health or the environment. Physical products supplied should be manufactured in a sustainable manner that minimizes environmental impacts.
\n2.6.4. ESG Reporting: NSM may request that Supplier provide reporting on its ESG Policy, its Carbon impacts, and its efforts to drive improvements. Supplier shall make commercially reasonable efforts to support the ESG framework, make improvements in environmental and social impact, and to provide ESG reporting as requested by NSM.\n
3. ORDER MANAGEMENT<\/strong><\/p>\n3.1. Quoting<\/strong> National Seating & Mobility – Supplier Code of Conduct Revision 1.0 20240328<\/p>\n\n\n","protected":false},"excerpt":{"rendered":" 1. CORE VALUES 1.1. Values 1.1.1. National Seating & Mobility, Inc. (“NSM”) has established standards for its business practices that are set forth herein. These standards reflect our commitment to our values of Honor, Excellence, Accountability, Respect, Teamwork and Service. NSM expects its Suppliers to share and embrace these values as well as NSM’s commitment…<\/p>\n","protected":false},"author":20,"featured_media":0,"parent":0,"menu_order":0,"comment_status":"closed","ping_status":"closed","template":"","meta":{"_acf_changed":false,"footnotes":""},"class_list":["post-16588","page","type-page","status-publish","hentry"],"acf":[],"yoast_head":"\n
\n3.1.1. Upon request, Supplier shall provide a quote for the products specified in its standard format on its letterhead with a unique quote number and date. Upon request, Supplier shall provide quote variations including MSRP only or primary cost only. Quotes must be valid for at least 90 days.
\nAdditional contents for all quote information including but not limited to the following:
\n\u2022 Cost
\n\u2022 MSRP
\n\u2022 Item Detail
\n\u2022 Workorder Number
\n\u2022 Quantity
\n\u2022 Quote Date
\n\u2022 HCPCS
\n\u2022 Discount Structure (if applicable)\n\t3.2. Purchase Orders<\/strong>\n\n3.2.1. NSM may request products from Supplier pursuant to and in accordance with separate purchase orders which may be transmitted by Email, EDI or otherwise (the “Purchase Orders”). Such Purchase Orders may specify quantities of products, and shipping instructions. In addition to the Purchase Order terms and conditions, each purchase Order shall be subject to all terms and conditions of this Code of Conduct as if fully set forth therein.
\n3.2.2. Only official NSM Purchase Orders shall be binding. No request for purchase by phone nor undocumented changes to purchases shall be valid.
\n3.2.3. Supplier shall confirm receipt of Purchase Orders by communication of a confirmation number within 2 business days, preferably within the inclusion of an expected shipping date.
\n3.2.4. There are three different types of Purchase Orders issued by NSM. Purchase Orders issued by NSM will match one of the three examples provided below. Suppliers shall only ship against Purchase Orders matching these formats.\n\t\t\t\t![\"1\"](\"https:\/\/www.nsm-seating.com\/content\/uploads\/2024\/05\/1.jpg\" "\\"1\\"")
\n\t\t\t\t![\"2\"](\"https:\/\/www.nsm-seating.com\/content\/uploads\/2024\/05\/2.jpg\" "\\"2\\"")
\n\t\t\t\t![\"3\"](\"https:\/\/www.nsm-seating.com\/content\/uploads\/2024\/05\/3.jpg\" "\\"3\\"")
\n\t\t\t\t![\"\"](\"https:\/\/www.nsm-seating.com\/content\/plugins\/bb-plugin\/img\/pixel.png\"){kind=tracking}
\n\t3.3. Shipment notifications<\/strong>\n\n3.3.1. Shipping and tracking information shall be provided before or on the date of shipment. Shipment notifications shall be communicated through the same channel as Purchase Order confirmations. For more information contact NSM Supply Chain.\n\n3.4. Invoice<\/strong>\n\n3.4.1. All invoices shall be sent to invoices@nsm-seating.com<\/a>. Payment terms are defined in each Purchase Order. In the event of a split or partial shipment of goods, unless agreed upon otherwise in writing, payment terms shall only commence upon shipment in full of the Purchase Order or the last shipment to complete the Purchase Order.
\n3.4.2. Open Balances. NSM endeavors to pay all open balances within the defined payment terms. There may be invoice disputes, missing proof of delivery, off-set of payables, payment term discrepancies or missing invoices that lead to outstanding balances. Supplier acknowledges that it would be a disservice to NSM clients to allow any such payment or credit concern from disrupting the supply of the clients medically necessary equipment. Supplier shall not, without advanced written notice to NSM Supply Chain via NSM-SupplyChain@nsm-seating.com<\/a> and a cure period of 10 days from such notice, discontinue or withhold shipments to NSM.\n