Policies

GPC Electronics is an Electronics Manufacturing Service provider of end-to-end management for electronic systems manufacturing and design and manufacture of electrical interconnect products.

Our objectives are to provide our customers with competitive solutions, and with Quality Products and Services.

We achieve this by working closely with our customers and other relevant interested parties to meet applicable customer, statutory and regulatory requirements, improve business implementations, and lock-in the benefits with robust, well-defined processes at all levels of the organisation. Through this we aim to gain the long-term confidence and satisfaction of our customers.

In support of these objectives, we maintain and continually improve the effectiveness of our ISO9001, ISO13485, IATF16949 and AS9100 (where implemented) certified quality management system.

The United States Securities and Exchange Commission (SEC) has adopted rules to implement reporting and disclosure requirement related to “conflict minerals”, as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, section 1502, in response to violence and human violations in the mining of certain minerals from the “Conflict Region”, which is situated in the Eastern portion of the Democratic Republic of the Congo (DRC) and all nine countries sharing Congo’s border.


The definition of “conflict minerals” refers to the 3TG, Tin, Tantalum, Tungsten and Gold, regardless of where they are sourced, processed or sold. The United Stated Secretary of State may designate other minerals in the future. GPC Electronics supports the humanitarian initiative of ending violent conflict in the DRC and surrounding countries.


GPC Electronics is committed to the responsible sourcing of the minerals above listed throughout our supply chain and to continue to enforce the SEC rules and regulations surrounding “conflict minerals” where possible.


GPC Electronics will undertake reasonable due-diligence within our supply chain to validate that our manufacturing processes are free of any conflict minerals and will continue to work with our suppliers for conformity.


GPC Electronics’ suppliers must pass this requirement onto their supply chain to determine the source of the above mentioned minerals if they do not source directly from smelters.

Environmental Scope

GPC Electronics is a provider of end-to-end management services for electronics system manufacturing.


In providing value added services to its customers, GPC Electronics recognises the importance that actual and potential impacts upon the environment for its activities.

GPC Electronics endeavours to pursue an environmental management approach that not only encompasses all activities in the area directly within its control in Penrith but also addresses the relevant requirements of all relevant interested parties that GPC Electronics engages in or interacts with.

In doing so, GPC Electronics aims to influence the impact on the environment not only of its business but also of these relevant stakeholders.

Environmental Policy

GPC Electronics is a provider of end-to-end management services for electronic systems manufacturing and, where appropriate, design and manufacture of electrical interconnect products. In providing value added services for its customers, GPC Electronics recognises the importance that actual and potential interactions of its activities have upon the environment.


GPC Electronics is committed to:

• Protecting the local and global environment of the Earth, including prevention of pollution, the responsible use of natural resources and the appropriate control of waste.
• Conducting its activities in a manner that is designed to minimize the impact on the environment and the people who live and work within that environment.
• Fulfilling relevant environmental compliance obligations applicable to its activities.
• Conforming to the requirements of ISO 14001 and the continual improvement of its Environmental Management System to enhance environmental performance by establishing and meeting environmental objectives.

GPC Electronics expect all staff and contractors to maintain high standards of ethical conduct in their dealings with you.

If you have any reason to suspect that our staff or contractors have behaved in a fraudulent or corrupt way, please let us know. We will investigate all complaints.


Please call our Ethics hotline on +61 2 4737 6671 or email a contactofficer@gpc.com.au

RoHS or the Restriction of Hazardous Substances is a directive adopted in February 2003 by the European Union (EU) and takes effect on July 1, 2006. Each EU member state will enact its own RoHS legislation using the directive as a guide.

RoHS 3, 22 July 2019 restricts the use of the following substances:

• Cadmium (Cd)
• Lead (Pb)
• Mercury (Hg)
• Hexavalent Chromium(Cr VI)
• Polybrominated Biphenyls (PBB)
• Polybrominated Diphenyl Ethers (PBDE)
• Bis(2-Ethylhexyl) phthalate (DEHP)
• Benzyl butyl phthalate (BBP)
• Dibutyl phthalate (DBP)
• Diisobutyl phthalate (DIBP)

PBB and PBDE are flame-retardants used in some plastics.


It is linked with the Waste Electrical and Electronic Equipment Directive (WEEE) 2002/96/EC that sets collection, recycling and recovery targets for electronics goods and is an initiative to reduce toxic e-waste.

RoHS is also taking effect in China and California. Japanese manufacturers are moving to make their products RoHS compliant. These, as well as other legislation, effectively make RoHS a worldwide compliance issue.

How does it affect you?

Does it apply to you?

The regulations apply to all Electrical and Electronic Equipment containing hazardous substances that is broadly covered by the following categories:

• Small & large household appliances

• IT & telecommunications
• Consumer equipment
• Lighting equipment

• Electrical & electronic tools

• Toys,leisure and sports equipment

• Automatic dispensers

There are exemptions to the scope.

Loss of sales

You will not be able to export non-RoHS products to the EU.

Penalties

Your European subsidiary, agent or distributor may be subject to severe penalties, including jail terms in some States, if they import non-compliant products to the EU.

Component Obsolescence

RoHS components are rapidly replacing non-RoHS components, so there will be obsolescence issues even if you don’t ship to the EU. Product Redesign Products will need to be redesigned and requalified with new Bills of Material (BoM’s) using RoHS compliant materials.

Compliance

Compliance hasn’t been precisely specified leaving it open to interpretation by the Member States. However it is the Sellers responsibility to ensure compliance and this means proving that your product has less than 0.1% by weight of any of the restricted substances. Gathering, storing and reporting component composition information is tedious but crucial if you have to provide a defence.

Resources

Staff will need to be trained in the implications of RoHS and resources allocated to ensure that your products comply. Records need to be kept for up to 4 years and be available within 28 days upon request.

1. About this policy

GPC Electronics Pty Ltd ABN 56 002 088 164 ( ‘GPC’ ‘we’, ‘us’ or ‘our’) is committed to protecting the privacy of your personal information in accordance with Australian privacy laws.

Our Privacy Policy sets out how we and our related entities collect, use, disclose and manage your personal information.


Our Privacy Policy complies with the Australian Privacy Principles set out in the Privacy Act 1988 (Cth) as amended (‘Privacy Act’).


When you engage us to provide you with any goods or services, apply or complete an application for commercial credit, communicate with us through email, by telephone or in writing, participate in any of our promotional activities, or use any of our other services, including our websites, you agree to the use and disclosure of your personal information in the manner described in this policy. This policy is also relevant and applies to other individuals we deal with in connection with commercial credit we provide, such as guarantors and directors.


We may, from time to time, review and update this Privacy Policy so please check our website periodically to stay informed of any updates.  All personal information collected and held by us will be governed by our most recently updated Privacy Policy. 


2. Types of personal information we collect

The kinds of personal information we may collect from you will depend on what type of interaction you have with us.  Personal information we may collect from you includes, among other things:

• identity particulars - such as your name, address, date of birth, occupation, telephone numbers, e-mail address and hobbies and interests;
• personal information we collect from you when assessing , processing and managing an application by you for commercial credit;
• personal information you provide to us when you participate in a promotion, competition, promotional activity, survey, market research, subscribe to our mailing list;
• your, bank, credit or debit account details when you make a purchase;
• your records of communication with us;
• if you visit our website, your website usage information such as your IP address.

3. The purpose for collecting your personal information

We will generally only collect and use your personal information for the primary purposes of:

• our general business operations;
• effectively providing you with our goods and services;
• where applicable, assessing and processing an application for commercial credit, and for administrative purposes in relation to the ongoing management of your commercial credit arrangement;
• communicating with you;
• responding to your inquires or complaints;
• meeting our legal and regulatory obligations;
• conducting, improving and developing a relationship with you;
• direct marketing (such as providing you with information about our products and promotional notices and offers); and
• improving our website.

Your personal information is only collected by lawful and fair means; and where practicable, only from you or from a person acting or authorised to act on your behalf. Where you have applied for a commercial credit account with us, we may also make enquiries in respect of commercial credit with third parties with your consent.  This could include persons nominated by you as trade references, credit reporting bodies (“CRBs”) and your bankers.
We will take reasonable steps to ensure that you are aware of:

• the likely use of the information;
• the right of access to the information;
• the identity and contact details of the our employee/representative collecting your personal information;
• any law requiring collection of the information; and
• the main consequences of failure to provide your personal information.

4. How we may use and disclose your personal information

We may use your personal information for:

• the primary purposes for which it was collected, such as those described above;
• assessing and processing an application for, or administrative and management of, and commercial credit account with us;
• administering and responding to your enquiry or feedback about our products and/or services;
• conducting, and allowing you to participate in, a promotion, competition, promotional activity, survey, market research or customer behavioural activity;
• promoting and marketing our current and future products and services to you, informing you of upcoming events and special promotions and offers and analysing our products and services so as to improve and develop new products and services (but giving you the opportunity to opt out of such direct marketing)
• improving the operation of our website.

We may disclose personal information we collect from you:

• to our related companies, suppliers, consultants, contractors or agents for the primary proposes for which it was collected or for other purposes directly related to the purpose for which the personal information is collected.  For example, your name and telephone number may be disclosed to our supplier to enable that supplier to respond to your request for information about a particular product;
• for direct marketing by, but giving you the opportunity to opt out of such direct marketing; We will include our contact details in any direct marketing.
• to relevant Federal, State, Territory medical, health and safety authorities (as required);
• where the law requires or authorises us to do so;
• to others that you have been informed of at the time any personal information is collected from you;
• with your consent (express or implied) to others.

Where the Privacy Act permits us to do so, we may also disclose your credit related information (in respect of commercial credit) to CRBs such as Veda or Dunn & Bradstreet, if you apply for commercial credit or if you request an increase in your commercial credit limit with GPC.

Where GPC collects information that we are likely to disclose to a CRB, please note:

• the CRB may include that information in reports provided to GPC to assist it to assess your creditworthiness;
• if you fail to meet payment obligations in relation to commercial credit or commits a serious credit infringement, GPC may be entitled to disclose this to the CRB;
• if you are an individual you may access information from GPC in accordance with this privacy policy and may access this information for the purpose of requesting GPC to correct the information or make a complaint to GPC.

GPC will only disclose personal information to CRBs where GPC is member of a recognised External Dispute Resolution Scheme (‘EDR Scheme’). If GPC discloses your personal information to CRBs, we will provide you with written notice prior to that disclosure, as well as the details of the recognised EDR Scheme.

We do not disclose your personal information for any secondary purposes unless your consent has been given or as required by law, and we will not sell or license any personal information that we collect from you.

5. How your personal information is stored and secured

We take reasonable steps to protect your personal information from loss, misuse or unauthorised access by restricting access to the information in electronic format and by appropriate physical and communications security.

If a substantial data breach has or may have occurred (for example, your personal information was shared with unauthorised persons) we will notify you as soon as is practicable.

We only keep your personal information for as long as it is required for the purpose for which it was collected or as otherwise required by law. We will take appropriate measures to destroy or permanently de-identity your personal information if we no longer need to retain it.  These measures may vary depending on the type of information concerned, the way it was collected and how it was stored.
 

6. Using our Website and Cookies

As with most websites, when you visit our websites or use an application on our website, we may record anonymous information such as IP address, time, date, referring URL, pages accessed and documents downloaded type of browser and operating system.

We also use “cookies”. A cookie is a small file that stays on your computer until, depending on whether it is a sessional or persistent cookie, you turn your computer off or the cookie expires. Cookies may collect and store your personal information. You may adjust your internet browser to disable cookies. If cookies are disabled you may still use our website, but the website may be limited in the use of some of its features.

Our website may also contain links to or from other websites. We are not responsible for the privacy practices of parties responsible for those other websites. This privacy policy applies only to the information we collect on our website. We encourage you to read the privacy policies on other websites you link to from our website.

7. Marketing and Opting-Out

We may use your personal information for:

• promoting and marketing of our current and future products and services;
• informing you of upcoming events and special promotions and offers; and
• analysing our products and services so as to improve and develop new products and services.

We may exchange your personal information between our related entities and so they can also assist in the marketing of our products and services to you.


We will only offer you products or services, where we reasonably believe that they could be of interest or benefit to you.
At the point we collect information from you, you may be asked to “opt in” to consent to us using or disclosing your personal information.  You will generally be given the opportunity to “opt out” from receiving marketing communications from us.  You may “opt out” from receiving these communications by clicking on an unsubscribe link at the end of an email or by contacting us with this request.

8. Cross border disclosure

Your personal information may also be processed by, or disclosed to employees, representatives, or other third parties operating outside of Australia who work for, or are engaged by us in the USA, New Zealand, Hong Kong and China.  For example, we may use a server hosted overseas to store data, which may include your personal information.


 We will take reasonable steps, in the circumstances, before your personal information is disclosed to an overseas recipient, to ensure that the overseas recipient does not breach privacy laws in relation to your personal information (‘the reasonable steps’).


The reasonable steps may not apply if you consent to the disclosure of your personal information to an overseas recipient and we reasonably believe that the overseas receipt is subject to laws that are suitability similar to privacy laws in Australia. 


If you consent to the disclosure of your personal information to an overseas recipient, the overseas recipient may not be accountable under the Privacy Act, and you will not be able to seek redress for breaches under the Privacy Act.


9. Accurate and up-to-date information

We take reasonable steps to ensure your personal information is accurate, up-to-date and not misleading by updating its records whenever true and correct changes to the data come to its attention.

If you believe your information is incorrect, incomplete or not current, you can request that we update this information by contacting our Privacy Officer. To contact our Privacy Officer please see contact details below in paragraph 16.
We will correct information we hold about you if we discover, or you are able to show to a reasonable standard, the information is incorrect. If you seek correction and we disagrees that the information is incorrect, we will provide you with its reasons for taking that view.


We disregard information that seems likely to be inaccurate or out-of-date by reason of the time that has elapsed since it was collected or by reason of any other information in our possession.

10. Access to your personal information

We acknowledges that you have a general right of access to information concerning you, and to have inaccurate information corrected. You are able to access the personal information we hold about you by contacting our Privacy Officer. If access is refused to your personal information for reasons permitted by the Privacy Act, we will give you a notice explaining our decision to the extent practicable and your options.

To contact our Privacy Officer please see contact details below. If you make an access request, we may ask you to verify your identity and put your request in writing for security reasons.  We may charge a reasonable administration fee to cover the costs of meeting your request. We will reply to your request for access within 30 days of notification by you.


11. Dealing with unsolicited information

We take all reasonable steps to ensure that all unsolicited information is destroyed or de-identified immediately.
 

12. Anonymity when dealing with us

Only where it practicable to do so, we may allow you the option not to identify yourself when dealing with us.


13. Collecting sensitive information

GPC does not collect sensitive information, unless it is specifically relevant and necessary for the purpose of our business activities and functions, and your consent is first obtained. All sensitive information that is collected is used in accordance with this privacy policy.


14. Government identifiers

We do not use government identifiers (e.g. tax file numbers or Medicare numbers) to identify individuals.
 

15. Complaints and disputes

If you have reason to believe that we has not complied with our obligations relating to your personal information under this Privacy Policy or under the Privacy Act, please refer any compliant to queries to our Privacy Officer (details below).
We will ensure your compliant is handled by our Privacy Officer in an appropriate and reasonable manner. Were necessary we may consult with our related entities and partners in order to deal with your complaint. A written notice of our decision regarding your complaint will be provided to you. If you are not satisfied with the outcome, then you may contact the Office of the Australian Privacy Commissioner:


Office of the Australian Information Commissioner

Website:www.oaic.gov.au


Phone: 1300 363 992


16. Who should you contact for further information?

Please refer any queries or complaints about our Privacy Policy or privacy issues to our:


Privacy Officer
GPC Electronics Pty Ltd

PO Box 188

Penrith NSW 2750
 
Phone: +612 4737 6671

Email:contactofficer@gpc.com.au

 
Our Privacy Officer will consider your question or complaint and respond to you in a reasonable timeframe.