Vendors

Supplier Code of Conduct

The Teledirect group of companies is committed to conduct business with integrity, fairness, and responsibility and our suppliers are essential to achieving our aspirations and standards. It is therefore mandatory for our suppliers to abide by this Supplier Code of Conduct. Our employees will similarly conform to this Code to the extent that it applies to their circumstances.

A

Labour

A.1

Freely Chosen Employment

(i)

The supplier will not use forced or trafficked labour.

(ii)

The supplier will not employ persons by threat, force, coercion, abduction or fraud.

(iii)

The supplier will provide its employees with a written employment contract that permits the employee to terminate the contract without cause and for convenience.

(iv)

The supplier will not withhold or destroy its employees' identity or immigration documents, passports or work permits unless required by law. The supplier will not require its employees to pay employers' or agents' recruitment fees or other fees for their employment.

A.2

Young Labour

(i)

The supplier will not use child labour. A “ child ” is a person below 15 years or under the minimum age for employment in the country of employment, whichever age is lower.

(ii)

The supplier will not require employees under the age of 18 years to perform work that is likely to jeopardize their health or safety, including night shifts and overtime.

(iii)

The supplier will protect student employees' legal rights.

(iv)

Subject to applicable law, the supplier will remunerate young employees at the same rate as other employees performing similar tasks.

A.3

Working Hours

(i)

The supplier will not require its employees to work beyond the maximum hours prescribed by local law.

(ii)

The supplier will allow its employees paid rest and holiday periods as prescribed under local law.

A.4

Compensation

(i)

The supplier will comply with local law in compensating its employees.

(ii)

The supplier will not make deductions from its employees' compensation unless permitted under local law or authorised by the employee to do so.

(iii)

The supplier will provide its employees with a written statement each time remuneration is paid, including any overtime payment and legally mandated benefits.

A.5

Humane Treatment

The supplier will treat its employees humanely without any harassment, physical or verbal abuse, corporal punishment, mental or physical coercion, or threats. The supplier will clearly communicate disciplinary policies and procedures in support of these requirements to its employees.

A.6

Non-Discrimination

The supplier will not discriminate by race, colour, age, gender, sexual orientation, gender identity and expression, national origin, disability, pregnancy, religion, political affiliation, union membership or marital status in employment and termination of employment, remuneration, promotion or training.

A.7

Trade Unions

The supplier will respect the right of employees to join trade unions. The supplier will permit employees to approach the management on working conditions and management practices without reprisal or retribution.

A.8

Immigration

The supplier will comply with all immigration and labour laws.

B

Ethics

B.1

Business Integrity

The supplier will conduct business with integrity and will not tolerate any bribery, corruption, extortion or embezzlement. The supplier will have a compliance programme on anti-corruption laws.

B.2

No Improper Advantage

The supplier will not promise, offer, authorize, give or accept bribes or anything of value or by other means to obtain undue or improper advantage, by itself or through a third party, in order to obtain or retain business, direct business to any person, or otherwise gain an improper advantage.

B.3

Disclosure of Information

The supplier will disclose information regarding participant labour, health and safety, environmental practices, business activities, structure, financial situation and performance in accordance with applicable regulations and prevailing industry practices. The supplier will not falsify records or misrepresent conditions or practices in the supply chain.

B.4

Intellectual Property

The supplier will respect intellectual property rights. If there is any transfer of technology and knowhow, the supplier will do this in a manner that protects intellectual property rights; and safeguards customer information.

B.5

Fair Business, Advertising and Competition

The supplier will uphold standards of fair business, advertising and competition. The supplier will make available appropriate means to safeguard customer information.

B.6

Protection of Identity and Non-Retaliation

The supplier will maintain programs that ensure the confidentiality, anonymity and protection of supplier and employee whistleblowers, unless prohibited by law. The supplier will have a communicated process for their employees to be able to raise any concerns without fear of retaliation. (A whistleblower disclosures improper conduct by an employee or officer of a company, or by a public official or official body.)

B.7

Responsible Sourcing of Minerals

The supplier will exercise due diligence on the source and chain of custody of minerals and make their due diligence measures available to customers upon customer request.

B.8

Privacy

The supplier will protect the reasonable privacy expectations of personal information of everyone they do business with, including suppliers, customers, consumers and employees. The supplier will comply with privacy and information security laws and regulatory requirements when personal information is collected, stored, processed, transmitted, and shared.

C

Health and Safety

C.1

Occupational Safety

The supplier will control worker exposure to potential safety hazards (e.g., electrical and other energy sources, fire, vehicles, and fall hazards) are to be controlled through proper design, engineering and administrative controls, preventative maintenance and safe work procedures (including lockout/tagout), and ongoing safety training. Where hazards cannot be adequately controlled by these means, the supplier will provide workers with appropriate, well-maintained, personal protective equipment and educational materials about risks to them associated with these hazards. The supplier will encourage workers to raise safety concerns.

C.2

Emergency Preparedness

The supplier will identify and assess potential emergency situations and events, and minimize their impact by implementing emergency plans and response procedures including: emergency reporting, employee notification and evacuation procedures, worker training and drills, appropriate fire detection and suppression equipment, adequate exit facilities and recovery plans. Such plans and procedures will focus on minimizing harm to life, the environment and property.

C.3

Occupational Injury and Illness

The supplier will put in place procedures and systems to prevent, manage, track and report occupational injury and illness including provisions to encourage worker reporting; classify and record injury and illness cases; provide necessary medical treatment; investigate cases and implement corrective actions to eliminate their causes; and facilitate return of workers to work.

C.4

Industrial Hygiene

The supplier will identify, evaluate, and control worker exposure to chemical, biological and physical agents. The supplier will use engineering or administrative controls to control overexposures. When hazards cannot be adequately controlled by such means, the supplier will protect worker health by appropriate personal protective equipment programs.

C.5

Physically Demanding Works

The supplier will identify, evaluate, and control worker exposure to the hazards of physically demanding tasks, including manual material handling and heavy or repetitive lifting, prolonged standing and highly repetitive or forceful assembly tasks is to be identified, evaluated and controlled.

C.6

Machine Safeguarding

The supplier will evaluate production and other machinery for safety hazards. The supplier will provide physical guards, interlocks and barriers and properly maintain them where the machinery is a potential injury hazard to workers.

C.7

Sanitation, Food, and Housing

The supplier will provide workers with ready access to clean toilet facilities, potable water and sanitary food preparation, storage, and eating facilities. Worker dormitories provided by the supplier or a labour agent will be maintained to be clean and safe, and provided with appropriate emergency egress, hot water for bathing and showering, adequate heat and ventilation, and reasonable personal space along with reasonable entry and exit privileges.

C.8

Health and Safety Communication

The supplier will provide workers with appropriate workplace health and safety training in their primary language. The supplier will post health and safety related information in the facility.

D

Environment

D.1

Environmental Permits and Reporting

The supplier will obtain, maintain and keep current all required environmental permits (e.g. discharge monitoring), approvals and registrations and follow their operational and reporting requirements.

D.2

Pollution Prevention and Resource Reduction

The supplier will reduce or eliminate the use of resources and generation of waste of all types, including water and energy, at the source or by practices such as modifying production, maintenance and facility processes, materials substitution, conservation, recycling and re-using materials.

D.3

Hazardous Substances

The supplier will identify and manage chemicals and other materials posing a hazard if released to the environment to ensure their safe handling, movement, storage, use, recycling or reuse and disposal.

D.4

Wastewater and Solid Waste

The supplier will implement a systematic approach to identify, manage, reduce, and responsibly dispose of or recycle solid waste (non-hazardous). The supplier will characterize, monitor, control and treat as required wastewater generated from operations, industrial processes and sanitation facilities prior to discharge or disposal. In addition, the supplier will implement measures to reduce generation of wastewater. The supplier will conduct routine monitoring of the performance of its wastewater treatment systems.

D.5

Air Emissions

For air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting chemicals and combustion by-products generated from operations, the supplier will have these characterized, routinely monitored, controlled and treated as required prior to discharge. The supplier will conduct routine monitoring of the performance of its air emission control systems.

D.6

Materials Restrictions

The supplier will adhere to all applicable laws, regulations and customer requirements regarding prohibition or restriction of specific substances in products and manufacturing, including labelling for recycling and disposal.

D.7

Storm Water Management

The supplier will implement a systematic approach to prevent contamination of storm water runoff. The supplier will prevent illegal discharges and spills from entering storm drains.

D.8

Energy Consumption and Greenhouse Gas Emissions

The supplier will track energy consumption and greenhouse gas emissions are to be tracked and documented, at the facility and/or corporate level. Participants are to look for cost effective methods to improve energy efficiency and to minimize their energy consumption and greenhouse gas emissions

E

Management System

The supplier will adopt or establish a management system whose scope is related to the content of this Code. The management system will be designed to ensure: (a) compliance with applicable laws, regulations and customer requirements related to the supplier’s operations and products; (b) conformance with this Code; and (c) identification and mitigation of operational risks related to this Code. The management system should also facilitate continual improvement.

The management system will contain the following elements:

(1)

Company Commitment

A corporate social and environmental responsibility policy statements affirming the supplier’s commitment to compliance and continual improvement, endorsed by the executive management and posted in the facility in the local language.

(2)

Management Accountability and Responsibility

Identification of senior executive and company representatives responsible for implementation of management systems and associated programs. Senior management regularly reviews the status of the management system.

(3)

Legal and Customer Requirements

A process to identify, monitor and understand applicable laws, regulations and customer requirements, including the requirements of this Code.

(4)

Risk Assessment and Risk Management

A process to identify the legal compliance, environmental, health and safety and labour practice and ethics risks associated with the supplier's operations. Determination of the relative significance for each risk and implementation of appropriate procedural and physical controls to control the identified risks and ensure regulatory compliance.

(5)

Improvement Objectives

Written performance objectives, targets and implementation plans to improve the supplier's social and environmental performance, including a periodic assessment of the supplier’s performance in achieving those objectives.

(6)

Training

Programs for training managers and workers to implement the supplier's policies, procedures and improvement objectives and to meet applicable legal and regulatory requirements.

(7)

Communication

A process for communicating clear and accurate information about the supplier's policies, practices, expectations and performance to workers, suppliers and customers.

(8)

Worker Feedback and Participation

Ongoing processes to assess employees' understanding of and obtain feedback on practices and conditions covered by this Code and to foster continuous improvement.

(9)

Audits and Assessments

Periodic self-evaluations to ensure conformity to legal and regulatory requirements, the content of the Code and customer contractual requirements related to social and environmental responsibility.

(10)

Corrective Action Process

A process for timely correction of deficiencies identified by internal or external assessments, inspections, investigations and reviews.

(11)

Documentation and Records

Creation and maintenance of documents and records to ensure regulatory compliance and conformity to company requirements along with appropriate confidentiality to protect privacy.

(12)

Supplier Responsibility

A process to communicate Code requirements to suppliers and to monitor supplier compliance to the Code.

If the supplier breaches any part of this Code, Teledirect may terminate its relationship with the supplier.

Last updated: November 2016