Supplier Code of Conduct
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This Supplier Code of Conduct (“Code of Conduct”) applies to all Suppliers, and each of their respective affiliates, subsidiaries, agents, and representatives (collectively, the “Suppliers”) who provide goods or services to Fasteners For Retail, Inc. d/b/a siffron or any of its subsidiaries or affiliates (collectively, “SIFFRON”). Suppliers must be committed to the highest standards of ethical conduct in their business practices. This Code of Conduct sets forth the basic requirements that all Suppliers must comply with in order to do business with SIFFRON. This Code of Conduct is hereby incorporated by reference into any written supplier agreement executed by a Supplier and SIFFRON. SIFFRON reserves the right to make changes to this Code of Conduct. If SIFFRON believes that any Supplier has violated this Code of Conduct, SIFFRON has the right to terminate its business relationship, and any related agreements, with that Supplier and seek to enforce any rights or remedies available to SIFFRON under applicable law or otherwise. Business Integrity Compliance with Laws and SIFFRON’s Policies: Suppliers must fully comply with all applicable laws and regulations, and with all SIFFRON policies, as provided by SIFFRON from time to time. To the extent that SIFFRON’s policies impose a higher standard than what is required by any applicable law or regulation, SIFFRON’s policies will control. Subcontractor and Third Party Sourcing Compliance: In the event that Suppliers are permitted to use subcontractors in accordance with the terms of any agreement with SIFFRON, or use third parties to source materials in connection with their provision of goods or services to SIFFRON, Suppliers will ensure that any applicable subcontractor or third party complies with this Code of Conduct in connection with providing those goods or services to SIFFRON. Suppliers will not retain any subcontractor or third party that fails to comply with this Code of Conduct. SIFFRON also encourages Suppliers to work closely with local communities to implement projects and strategies that improve the community and those who live there. Conflicts of Interest; Gifts; Bribery and Corruption: Suppliers agree not to engage in any activity which could create either the appearance of, or an actual conflict of interest, between the personal interests of SIFFRON’s representatives, employees, agents or designees (including their immediate family members) and the interests of SIFFRON. Suppliers will not offer gifts or entertainment exceeding nominal value to SIFFRON or any of its representatives, employees, agents or designees. Suppliers must renounce bribery, corruption, fraud and unethical practices in all forms and in all dealings and must comply with all applicable anti-corruption laws and regulations, including the United States Foreign Corrupt Practices Act, in connection with the provision of any goods or services to SIFFRON. Sanctioned Entities: In addition, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) provides a list of all sanctioned entities. siffron is committed to ensuring full compliance with applicable restrictions associated in conducting business transactions with entities listed on the Specially Designated Nationals List which can be found here: https://home.treasury.gov/policy-issues/financial-sanctions/specially-designated-nationals-and-blocked-persons-list-sdn-human-readable-lists. Suppliers agree to comply with all applicable restrictions regarding sanctioned entities. Fair Dealing; Fair Competition: Suppliers must not manipulate, conceal, or misrepresent facts, misuse information, or otherwise act illegally, unfairly, dishonestly, or unethically. Suppliers must adhere to all applicable fair competition laws prohibiting activities that restrain trade or create anti-competitive markets. Labor, Health and Safety Forced Labor: Suppliers shall not use any form of forced, bonded, indentured, trafficked, slave, or prison labor. All work must be voluntary, and employees must be free to leave work or to terminate their employment at will. Suppliers must not require employees to surrender any government-issued identification, passport, or work permit as a condition of employment. Suppliers must take reasonable measures to ensure that all of their employees understand the terms of their employment. More information on the U.S. Government’s prohibition and related import restrictions can be and are to be reviewed at the below websites: https://www.cbp.gov/trade/forced-labor AND https://www.dhs.gov/uflpa. siffron requires its suppliers to diligently visit CBP and DHS’s forced labor webpages to ensure they and their suppliers abide by U.S. Government requirements. Child Labor: Child labor is strictly prohibited. Suppliers shall not use child labor, as defined by the conventions of the ILO and the UN, the International Standard SA8000 (the global social accountability standard for decent working conditions developed and overseen by Social Accountability International) or by applicable national laws and/or regulations, in supplying goods or rendering services for SIFFRON. Suppliers shall hire employees who are at least the legally specified minimum age for employment in accordance with applicable law. Conditions to Employment: Suppliers will comply with applicable laws regulating work hours and benefits. Employees must be paid in a timely fashion that meets or exceeds legal minimum standards. Suppliers must have hiring practices that accurately verify a worker’s legitimate eligibility to work. Suppliers shall clearly define, on a regular basis, their respective wages and other payments to employees and independent contractors. Suppliers will not use wage deductions as a disciplinary measure. All wages and other payments by Suppliers must meet applicable statutory provisions, laws, and/or mandatory local standards. Freedom of Association; Collective Bargaining: Suppliers will comply with all applicable laws that recognize and respect the rights of employees to freedom of association and collective bargaining. Suppliers shall not restrict the right of workers to freely associate with others or establish and join (or refrain from joining) workers’ associations. Suppliers shall neither restrict the right to carry out collective negotiations in accordance with national laws and regulations nor discriminate against workers for exercising such rights. Discrimination and Harassment: Suppliers shall not threaten workers with, or subject them to, harsh or inhumane treatment, including, but not limited to, verbal abuse and harassment, psychological harassment, mental and physical coercion or oppression, or sexual harassment. Suppliers will prohibit discrimination or harassment in all forms, including by prohibiting discrimination or harassment based on sex, race, color, religion, national origin, age, disability, marital status, gender identity, gender expression, or sexual orientation. Diversity and Inclusion: SIFFRON expects all Suppliers to foster a culture and working environment that values and respects employee diversity and inclusivity. Health and Safety: Suppliers must ensure that the workplace is safe, clean, and not harmful to the health of its employees and independent contractors, including by providing appropriate personal protective equipment and all workplace health and safety information and training necessary for its employees and independent contractors to safely perform their work responsibilities. Any working conditions at the workplace or on the Supplier’s premises that violate applicable law and/or regulation are prohibited.
Environmental Standards Responsible Stewardship: Suppliers will look to conserve resources and protect the communities and environment that surround them. SIFFRON encourages its Suppliers to develop and diffuse environmentally friendly technologies and to increase the use of renewable energies. Compliance and Reporting Monitoring and Enforcement: Suppliers must be able to demonstrate compliance with this Code of Conduct upon SIFFRON’s request, and shall take any action to correct any non-compliance. To ensure compliance with this Code of Conduct, SIFFRON reserves the right to audit or inspect Supplier’s books and records, and any facilities used by Suppliers in procuring goods or services for SIFFRON, at any time, directly or through SIFFRON’s designees. Suppliers agree to cooperate with SIFFRON in confirming its compliance with SIFFRON’s policies, including by: (i) promptly responding to inquiries and requests for information; (ii) making facilities readily available for inspection; (iii) participating in any required audits; (iv) working with SIFFRON and any applicable industry bodies or audit programs to resolve issues; (v) designating a representative responsible for legal compliance and compliance with this Code of Conduct; and (vi) maintaining records and documentation sufficient to demonstrate compliance with this Code of Conduct. Reporting and Non-Retaliation: Suppliers will provide an adequate mechanism for their employees to report integrity concerns, safety issues and misconduct without fear of retaliation. Suppliers will not retaliate against any person reporting those concerns. Suppliers will also appropriately investigate reports and take corrective action, if needed. Subject to any restriction posed by applicable law, Suppliers will also promptly inform SIFFRON of any concern related to issues governed by this Code of Conduct or any other agreement between SIFFRON and Suppliers. To report a concern to SIFFRON, Suppliers can always speak directly to their SIFFRON representative. |