Supplier Code of Conduct
INTRODUCTION
Corporate integrity, responsible sourcing, and the safety and wellbeing of workers across our global supply chain are of paramount importance to Conductor LLC and our affiliates (“Conductor”, “our”, or “us”). These principles apply to all aspects of our business and encompass all vendors and other suppliers (each a “Supplier” and collectively “Suppliers”) that provide products to us, and/or perform services for us, or on our behalf. These principles are reflected in this code of conduct (“Code of Conduct”), which establishes the minimum standards that must be met by any Supplier that sells goods to or does business with us.
Applicability
This Code of Conduct applies to all Suppliers that are our supply chain partners. Each Supplier is responsible for compliance with the standards set out in this Code of Conduct (“Standards”) throughout its operations and throughout its entire supply chain. Without limiting Supplier’s obligations hereunder, Supplier is responsible for compliance with the Standards by all of its employees, directors, officers, partners, and shareholders, as well as its suppliers, vendors, agents, and subcontractors (“Partner(s)”).
EMPLOYMENT
Voluntary Employment and Child Labor
Suppliers will not use forced labor, whether in the form of slavery, prison labor, indentured labor, bonded labor, or otherwise. Suppliers are required to comply with applicable child labor laws and employ only workers who meet the applicable minimum legal age requirement in their countries of operation.
Compensation and Benefits
Suppliers are required to pay their workers in a timely manner and provide compensation (including overtime pay and benefits) that, at a minimum, satisfy applicable laws. Suppliers are required to provide to their workers the basis on which workers are being paid in a timely manner via pay stub or similar documentation. Deductions from wages as a disciplinary measure are not permitted. In addition, Conductor encourages Suppliers to regularly evaluate whether workers earn enough to meet their basic needs and the needs of their family.
Work Hours
Suppliers are required to comply with all applicable labor laws and regulations governing employee working hours in their countries of operation.
No Discrimination, Abuse, or Harassment
Supplier shall not discriminate in hiring, compensation, training, advancement or promotion, termination, retirement, or any other employment practice based on race, caste, color, national origin, gender, gender identity, sexual orientation, military status, religion, age, marital or pregnancy status, disability, union membership, political affiliation, or any other characteristic other than the worker’s ability to perform the job.
Supplier shall not subject workers to abuse or harassment.
Health and Safety
Suppliers will comply with all applicable workplace health and safety laws. Supplier shall: (i) provide appropriate training and personal protective equipment; and (ii) implement procedures and safeguards to prevent workplace hazards, accidents, and injuries.
Freedom of Association and Collective Bargaining
Supplier shall respect, and shall not interfere with, the right of workers to decide whether to lawfully associate with groups of their choice, including the right to form or join trade unions and to engage in collective bargaining.
ENVIRONMENT & SUSTAINABILITY
Compliance
Supplier shall comply with all environmental laws, including laws and international treaties relating to: (i) waste disposal; (ii) emissions; (iii) discharges; and (iv) hazardous and toxic material handling.
Inputs and Components
Supplier must ensure that the products that it manufactures (including packaging and the inputs and components that it incorporates into its goods) or uses in the performance of services comply with all environmental laws and treaties.
Suppliers may not supply products that contain tin, tantalum, tungsten, or gold that directly or indirectly finance, or benefit armed groups and cause human rights abuses.
Supplier shall endeavor to set targets to achieve carbon neutrality, eliminate plastic waste, and to minimize the use of nonrenewable resources.
DIVERSITY
Suppliers should encourage a culture of inclusion and work to improve the overall diversity of their workforce. Suppliers are encouraged to have a supplier diversity program and support the businesses and communities in the locations in which they operate by engaging with small businesses, minority- and woman-owned businesses and other diverse categories.
BUSINESS ETHICS
Compliance with Laws
Supplier shall comply with all applicable national and local laws and regulations.
Conflict of Interest
Suppliers will avoid any interaction with any of our employees that may conflict, or appear to conflict, with that employee acting in the best interests of Conductor. Supplier must not offer cash, favors, gifts, or entertainment to Conductor’s team members. Any and all conflicts of interest, of which the Supplier is aware, in any business dealings with Conductor, including but not limited to any ownership or beneficial interest in a Supplier’s business by a Conductor employee shall promptly be declared to Conductor to allow for appropriate action.
Anti-Bribery & Anti-Corruption
Suppliers shall conduct their business in compliance with applicable anti-bribery and anti-corruption laws, including, the United States Foreign Corrupt Practices Act and the UK Anti Bribery Act. Suppliers shall not make payments, or promise to pay money or anything of value, directly or indirectly to any government or corporate officials for the purpose of obtaining or retaining business.
Trade Compliance
Suppliers must comply with trade compliance, antiboycott, export control and economic sanctions laws and regulations of the United States, the European Union and other applicable jurisdictions (“Trade Compliance Laws”). This includes, without limitation, end-destination restrictions and prohibitions on dealings with sanctioned individuals and entities.
Intellectual Property Rights
Supplier shall respect and not infringe the intellectual property rights of Conductor and other third parties.
Privacy and Data Protection
Supplier shall have processes and practices in place to secure and protect personal data. Suppliers shall comply with all applicable privacy, data protection, and cybersecurity laws.
Information Security
Supplier shall maintain a security program in accordance with generally accepted industry standards, which is inclusive of technical and organizational measures to prevent misuse, compromise, loss, alteration or unauthorized disclosure, acquisition of, or access to, confidential, proprietary, or protected information.
VIOLATIONS AND INSPECTIONS
Report Violations
Supplier shall self-report any violations of the Code of Conduct. Supplier can also submit questions and comments regarding the Code of Conduct to the following email address: [email protected].
Supplier shall not retaliate or take disciplinary action against any worker who has, in good faith, reported violations or questionable behavior, or who has sought advice regarding this Code of Conduct.
Supplier acknowledges that Conductor may, in its discretion, conduct inspections of Supplier and its Partners to confirm Supplier’s and its Partner’s compliance with this Code of Conduct. Conductor has no obligation to conduct inspections.
Termination
Conductor may immediately terminate its business relationship (including any purchase order(s) and purchase contracts) with Supplier for cause, if Supplier or its Partners fail to meet the Standards.
