Supplier Code of Conduct

Introduction

Export Packers Company Limited and its affiliates (collectively, “Export Packers”) are committed to carrying out our business lawfully, ethically and in a manner that makes a positive impact in communities in which we operate.  To accomplish this, Export Packers looks to conduct business with suppliers that share our commitment to responsible and ethical business practices.

Application

This Supplier Code of Conduct (the “Code”) applies to all suppliers and vendors who provide goods or services, directly or indirectly, to Export Packers (collectively, “Suppliers”).  Suppliers are responsible for the business activities of their own suppliers, vendors, contractors, agents and brokers under this Code (“Supplier Related Parties”).

Principles

The Code is based on the following principles:

  1. Compliance with Applicable Laws and Contract Terms
  2. Business Ethics
  3. Respect for Workers
  4. Quality

Export Packers expects all Suppliers to adopt behaviours and practices that are consistent with the principles set out in this Code and be able to demonstrate the ways in which they apply the principles of this Code.

1. Compliance with Applicable Laws and Contract Terms

Suppliers must comply with all applicable laws and regulations and abide by the terms of contracts made with Export Packers.  This means Suppliers must:

  • Understand and comply with the laws and regulations applicable to them for their business in the regions in which they operate.
  • Maintain all licenses, permits and government approvals necessary to carry on their business.
  • Faithfully and diligently perform all the terms of any contract between Export Packers and Supplier.

2. Business Ethics

Suppliers must operate their businesses ethically and with integrity.  This means Suppliers must:

  • Adopt a zero-tolerance approach to bribery, corruption and money-laundering.
  • Not offer, pay, receive or solicit bribes, kick-backs, or payments of any kind to obtain a favourable outcome, including any facilitation or “grease” payments.
  • Ensure the protection of confidential information they receive from Export Packers and use such information only as part of their business relationship with Export Packers.
  • Identify and disclose any actual or potential conflict of interest that Supplier or its personnel may have before conducting business with Export Packers and do not enter into any transactions that have an actual or potential conflict of interest.
  • Export Packers acknowledges that the occasional exchange of gifts, or participating in entertainment activities, is a customary part of doing business. Export Packers expects that gifts or entertainment should always be for a legitimate business purpose, made in good faith and be reasonable in nature.  No gifts or entertainment of any kind may be given to any public official (or relative or associate of any public official).

3. Respect for Workers

Suppliers must treat people with dignity, respect and in accordance with their unalienable human rights.  This means Suppliers must:

  • Set out terms and conditions for hiring and dismissal that are in compliance with applicable laws and provide these terms and conditions to employees in the language spoken by them.
  • Comply with all applicable local employment laws, including around working hours, overtime and minimum wage. All overtime must be reasonable, voluntary and remunerated. Employees shall be entitled to at least one day of rest per week.
  • Pay their employees on a regular and timely basis.  Suppliers may not withhold wages unless specified in their employment agreement and permitted by applicable law.
  • Not engage in involuntary labour practices – this includes forced, bonded, trafficked, involuntary prison labour or any practice that could reasonably be expected to cause the person to believe their safety or the safety of a person known to them would be threatened if they failed to provide or offer to provide the labour or service. 
  • Permit employees to leave the workplace at the end of their shift, keep their identity documents and work permits in their possession and leave their position after providing reasonable notice and without financial penalty.
  • Not engage in the use of child labour – this means labour or services provided or offered to be provided by persons under the age of 18 years, provided that workers over the age of 14 may, where permitted by applicable law, be employed to perform work where such work is not dangerous to them and does not interfere with their schooling (including excessively long or heavy work).
  • Not subject workers to any form of verbal, physical or sexual abuse or harassment including intimidation in the workplace.
  • Not engage in discriminatory behaviour in the hiring and treatment of workers on the basis of race, citizenship, place of origin, ethnic origin, colour, ancestry, caste, disability, age, religious belief, creed, sex/pregnancy (including breastfeeding), family status, marital status, sexual orientation, gender identity/expression or any other ground prohibited by applicable law.
  • Provide a healthy and safe workplace and take all measures to prevent work-related injuries, illnesses and accidents.
  • Permit workers to associate and bargain collectively in accordance with applicable laws.

These principles cover all workers within Export Packers’ supply chain and expressly include any Supplier Related Parties (including any labour agencies).

.4. Quality

Export Packers expects that the products and services it receives from Suppliers are produced/delivered in accordance with the highest standards applicable to Suppliers’ industry.  This means that Suppliers must:

  • Implement processes and procedures to ensure product safety and quality.
  • Ensure that all products/services sold or delivered meet or exceed all applicable standards for such goods/services, including any requirements for exportation or importation.
  • Deliver products/services that meet the agreed upon specifications for such products/services.

Monitoring Compliance

Suppliers shall monitor the compliance of their operations and their Supplier Related Parties’ operations with the terms of the Code and must immediately disclose any known or suspected violations to Export Packers.

While the requirements in this Code are the responsibility of Supplier, Export Packers may verify Supplier’s compliance with the Code through evaluations, audits and inspections and Supplier agrees to cooperate with and facilitate any verification efforts by Export Packers, including providing any documentation requested and permitting Export Packers’ or its designees to visit and inspect Supplier’s facilities from time to time.