SUPPLIER CONDUCT POLICY
This Supplier Conduct Policy establishes the minimum standards to which suppliers shall adhere, unless where otherwise specifically stated as a recommended practice. Suppliers shall conform to any applicable legal requirements that are greater than the standards set forth herein this Supplier Conduct Policy, and should strive to develop practices for their employees that will increase their protection in the facility and overall work environment.
THADDEA's structural foundation is based on integrity, dependability and the message of inspiration through Enhanced Tech Apparel and Products (ETAP). When dealing with suppliers, we expect at a minimum the implementation of these practices in the work place and compliance with the ethical standards we set.
ACCOUNTABILITIES OF FACILITY OPERATIONS
Manager of Facility: shall construct the programs, implement the policies and procedures of the facility as outlined herein the Supplier Conduct Policy.
Administrators & Supervisors of Facility: shall train the employees to be knowledgeable and to abide by the requirements of the programs, policies and procedures outlined herein the Supplier Conduct Policy.
Employees of Facility: shall abide by the requirements of the programs, policies and procedures outlined herein the Supplier Conduct Policy.
Facility Control Representative: shall institute, maintain and govern the programs, policies and procedures outlined herein the Supplier Conduct Policy.
OBLIGATIONS OF FACILITY
Review of Risks
The supplier's facility shall have a documented review of risk conducted that includes; evaluation of potential facility, hazards, safety or environment risks and identifying methods that can help to decrease these risks.
Employees shall be trained when first starting their specific occupation of work, on initial and new assignments, when procedures change and on an annual basis.
The supplier's facility shall maintain training and incident records for at least 2 years and maintain a current review of risk.
ETHICAL AND LEGAL BUSINESS PRACTICES
The supplier is required to be ethical with their business practices and fully conform with all applicable local, state, federal, national and international laws and rules including, but not limited to, those relating to child labor, wages, work hours, labor, health, safety and environment and immigration. Any supplier that adopts the Supplier Conduct Policy must comply with all pertinent manufacturing laws, local and government business laws within that country and support the Supplier Conduct Policy in accordance with the Ethical and Legal Business Practices and must apply the higher standard in cases of difference of conflicts.
The supplier shall not use any form of forced labor (indentured labor, prison labor or bonded labor) as a business practice.
Any employee hired by the supplier must be at least 16 years of age or over the age for completion of the mandatory education; whichever age is higher will serve as the authorized working age. If an employee is under the age of 18 then they cannot be employed to work in hazardous conditions, which is the responsibility of the supplier to recognize such conditions.
THADDEA and/or its associates may establish a higher minimum age requirement with certain industries or countries, and if established then communicated to the suppliers that it will effect
Those suppliers will be required to receive a proof of age before hiring the individual. The supplier must verify the individuals age by receiving from the individual an identification card (ID), birth certificate, voting identification card, driver's license or some other form of ID. Copies of these documents are to be stored in a physical file folder or on a computer for the entire period of the individual's employment.
The supplier is required to conduct themselves respectively and with dignity toward their employees. The supplier shall not tolerate any form of physical, verbal or psychological harassment or abuse toward an employee. The supplier must have some form of a written harassment and abuse policy and be able to provide upon request to THADDEA or authorized inspectors all documentation pertaining to any allegation of harassment or abuse.
The supplier is prohibited from using prison labor or providing subcontract work to prisons. This includes attaining any goods, services or materials that may be used to manufacture THADDEA apparel and/or products.
The supplier shall not engage in employment discrimination, including hiring, benefits, advancement, pay, discipline, termination or retirement, on the basis of sex, race, religious faith, age, disability, sexual orientation, ethnicity, marital status, political opinion, or social origin. It is the responsibility of the supplier to train its staff to recognize these types of discriminations and to make sure they are implementing and enforcing the nondiscrimination law of the country. The supplier must have some form of a written nondiscrimination policy.
The supplier must provide employees the right to move freely throughout their assigned work areas during their hours of work, and allow them to have access to drinking water and the use of toilet facilities. The supplier must also allow employees the right to leave the workplace during meal breaks or after the work day hours have ended.
Suppliers that provide dormitory living for employees must provide environmentally livable, healthy, clean and safe living quarters and explain security practices and curfew policies to those employees in which they apply. The guidelines for where curfews exist must be sensible and structured so both national employees and foreign working employees are provided adequate time to rest and the opportunity to partake in activities during hours that are deemed non-working.
TREAMENT OF WOMEN
The supplier must comply with any country law that relates to pregnancy, childbirth, nursing, and including but not limited to the protection of pregnant women from hazardous work and the working hours of a pregnant women, which may be proposed by a licensed physician of the country.
The supplier shall not require women employees to perform a pregnancy test as a condition of hire or during their employment period. However, the supplier can provide a pregnancy test but only at the employees request, which then must be documented by the supplier and thereafter for any additional requests. In addition, no employee will be pressured or forced by the supplier to use contraception.
Women employees shall be permitted to maternity leave by the supplier, which guidelines pertaining to maternity leave are in compliance with the country law.
FREEDOM OF ASSOCIATION AND COLLECTIVE BARGAIN
The supplier must act in accordance with the laws of the manufacturing country, and acknowledge the right of employees to engage in freedom of association and collective bargaining and to do such without obstruction, retribution, harassment or blacklisting.
The supplier must pay each employee at least the minimum wage required by law or the prevailing industry wage, whichever is higher, provide each employee a clear written report for each pay period, provide legally mandated benefits, which include holidays and leaves, and legal compensation to the employee when their employment period ends. The supplier must have a written leave policy implemented that provides the leave for legally required holidays, annual leave, sick leave, maternity leave, emergency leave for family and any other leaves that are permitted by country law. This leave policy must be able to be effectively articulated to the employees by the supplier.
The supplier must provide their employees with all legally mandated benefits of the country.
WORK HOURS /OVERTIME
The supplier shall not require or compel their employees to work more than a total of 60 hours a week or less if laws of the manufacturing country permit and shall comply at all times with the legally mandated work hours, breaks, days of rest and use overtime only when each employee is fully compensated according with the country law. In addition, the supplier must inform each employee at the time of their hiring if mandatory overtime is a condition of their employment. In countries where the laws do not limit the work hours, employees are only required to work a regular workweek plus 12 hours of overtime and be given at least 24 consecutive hours off in every seven day period. Overtime hours must be compensated at the legal rate required country law. Countries that do not compensate for overtime must provide at least the employees regular hourly pay. The productions of THADDEA apparel and/or products are to be manufactured within the supplier's facility(s) or the regular work place and not within the home or living quarters of an employee.
EMPLOYEE HIRING ORGANIZATIONS
The supplier must use organizations that are legal, in good standing and where applicable registered in accordance with the laws of the country.
The supplier is to employee only legal workers of the receiving country and may not hire Illegal foreign workers.
The supplier's facility must meet local code standard requirements and provide safe working conditions that include, safe exit routes from fires and emergencies, adequate lighting, safe passage when using stairs, protective guards and barriers to shield from bodily harm, industry certified safety equipment for face, eyes, head and extremities, protective clothing and equipment required to operate machinery, properly working and protective machinery guards, safe loading and unloading doc areas and protective procedures in place to decrease or eliminate the risk of a fall or from being hit by falling objects.
FACILITIES CARING FOR CHILDREN
The supplier must provide an environment that is healthy, clean and safe for children when working with or caring for them within or outside the working facility. The facility must have child care procedures in place that provide contact information for the parent/guardian of the child, release authorization by the parent/guardian, health records of the child, a safe building that meets local code standard requirements, clean drinking water, clean toilet facilities, clean sleeping areas with proper sleep mattresses and protection from areas that contain medicines, chemicals, hot surfaces, electric outlets or other potential dangers.
HEALTH, SAFETY AND ENVIRONMENT
The supplier must provide a work environment that is healthy, clean and safe for their employees and in accordance with country law. Suppliers must conform to all pertinent workplace safety regulations, environmental laws, take the appropriate measures to help prevent accidents and injuries within the facilities, and implement procedures that help to minimize the risk of sanitation and decrease or eliminate mental and physical health risks. In addition, the supplier must provide clean drinking water, provide an adequate number of clean separate toilets for each gender and clean washbasins with hand soap in all areas where work is performed.
If the supplier is providing residential living accommodations to employees then the accommodations must be environmentally livable, healthy and safe.
The supplier must implement policies and procedures that help to decrease or eliminate the risk of employees' exposure to any ionizing and non-ionizing radiation sources (such as Ionizing Radiation, Radio Frequency (RF) Radiation and Electric and Magnetic Field (EMF) Radiation), to asbestos containing material (ACM), to ergonomic hazards and to chemical and biological materials or liquids. Further, the supplier must implement policies and procedures to help decrease or eliminate the risk of employees' respiratory system from over-exposures of chemicals and maintain the decreased levels of exposure for the employees' health. The minimum, the supplier must decrease exposures that would be in accordance with established local and international regulations. The supplier must comply with the requirements as set forth in this section or with the local laws and regulations governing the prevention of hazardous conditions, which either one is more strict.
Suppliers must comply with whichever regulation or standard is more restrictive, either their nation's law or health requirements, the Threshold Limit Values (TLV's), American Conference of Governmental Industrial Hygienists (ACGIH) or US Occupational Safety and Health Administration (OSHA). The supplier must select the standards for the employees in the work environment that will protect them to the highest level and that will especially protect them from the exposure to blood borne pathogens.
In accordance with this section, the supplier is prohibited from using the finishing technique of Abrasive Blasting on THADDEA, INC. apparel and products, because the technique consists of unsafe substances and potential biological and chemical agents. Also, the supplier must provide working conditions that are electrically safe (no exposed wires, all cable wires in good condition, all electrical outlets installed correctly with Ground Fault Circuit Interruption near wet locations and secure labeled electrical panels and boxes) and that do not cause heat induced illnesses, such as, heat exhaustion, heat cramps or heat stroke. Procedures must be implemented to decrease or eliminate electrical risks, heat stress risks and injuries.
MAINTENANCE AND REPAIR SAFETY
The supplier must identify any hazards or equipment failure that could be related with maintenance and repair activities. Further, each facility workshop(s) must be clean and in good working condition, equipment and tools must be safe and work properly, protective equipment must be provided and used and access must be provided to equipment manuals.
The supplier must decrease high noise levels and protect employees from high noise levels that can cause the loss of hearing. Any facility with noise levels identified to be over 85 dB is deemed a high noise area and therefore the supplier must decrease or eliminate the risk of employees losing their hearing. Any employee affected from high noise levels must be tested by a certified medical professional at no cost to the employee.
MOBLIE POWERED VEHICLES AND TRAFFIC
The supplier must implement policies and procedures that help to decrease or eliminate the risk of operations involving power motorized vehicles and pedestrians. Each facility must implement vehicle safety requirements, regular maintenance inspections, safety operating guidelines and report on any accidents or issues concerning potential accidents. The supplier must comply with the requirements as set forth in this section or with the local laws and regulations governing the operation or power motorized vehicles within a facility, which either one is more strict. Further, each facility must implement policies that will help power motorized vehicle operators to manage employees safety and pedestrian traffic, which cover the following for power motorized vehicles while on site: speed limits; driving guidelines; protective equipment for operators; vehicle reversing noise indicator; vehicle must function correctly; and all vehicle operators must be certified or licensed before operating any power motorized vehicle.
The supplier must implement policies and procedures that help to decrease or eliminate the risk of work-related exposure and use of LASER (Light Amplification by Stimulated Emission of Radiation) devices. Each facility must have emergency procedures in place and procedures that: restrict unauthorized personnel from areas containing LASERs; post signage in LASER areas; provide proper protective equipment; use only LASER devices that consist of guarding and interlocks to protect from the exposure of the beam; and LASER devices must be configured and tested to the manufactures recommendations. Further, any LASER device found with defects must be fixed prior to operating.
FACILITY MATERIALS, EMISSIONS AND ENVIRONMENT HAZARDS
The supplier must implement policies and procedures that restrict the use of nanomaterials, decrease or eliminate the risk of air emissions, hazardous materials (transportation and use), hazardous waste, solid wastes and wastewater. Further, the supplier must implement programs that: protect the potential exposure and health of employees and suppliers; minimize the risk to the environment; and store all hazardous elements in suitable containers. The supplier must have in place procedures to effectively clean the incident relating to the action or use of materials or conditions in this section. Any incident involving these materials or conditions must be documented. The supplier must comply with the requirements as set forth in this section or with the local laws and regulations governing the action or use of these materials or conditions within a facility, which either one is more strict.
Each supplier must have within the facility an implemented written emergency plan that provides the names of contacts involved with handling an emergency, plans for evacuation, resources and people designated to help assist handicapped individuals, help with medical and rescue duties and an alarm or warning system that can distinctively notify employees of emergencies.
Each supplier must have within the facility an implemented plan to decrease or eliminate the risk of hazards that could cause a fire within or outside the facility, procedures for individual and facility fire safety.
INJURIES OR ILLNESSES IN THE FACILITY
In the occurrence of an injury or illness the incident must be reported to the facilities management the day the incident transpired and documented in the records of the facility. Further, each facility must be able to provide first aid treatment to an injured or sick individual whether or not professional care is required and have a first kit, disposable gloves, burn treatment materials, sterile adhesive bandages, eyewash and body flush equipment in case of a chemical exposure to the eyes face or body.
STRUCTURE OF BUILDING
The supplier must implement policies and procedures that decrease or eliminate safety risks related with the design of the building, structure, usage and maintenance of the building. Any identified or potential hazards related with the design of the building, structure or other causes that could deteriorate the structural foundation of the building must be reported. Each facility must implement policies for building structure safety, which for new building construction includes approval by the local building authority or certified professional building designer or architect when constructing the building and constructing mezzanine structures to support all loads and stationary loads so the weight of the loads do not exceed the allowable stress or stated strength of the materials being used for construction.
STORING SYSTEM TANKS
The supplier must implement policies and procedures for the facility that decrease or eliminate the risks of health, safety and environmental impacts related with storing tank systems located above and below ground, which contain petroleum or hazardous materials. Above ground storing system tanks are considered immobile containers located completely above ground level, and must: be labeled with the contents and potential hazards; contain protective barriers in case of accident; be checked frequently to make sure the tank works properly and has no damage or malfunctions; and is designed to contain the material(s) being stored. Storing tank systems that are defined as underground have a portion of the structure (not including piping beneath ground level) located below ground level, and must: contain a leak detection system; be designed to contain the material(s) being stored; have protection from subsurface corrosion; and contain an overfill protection system.
POLYCHLORINATED BIPHENYLS (PCB)
The supplier must implement policies and procedures to decrease the risk to employees and the environment when the facility has materials and equipment containing polychlorinated biphenyls (PCBs). Any materials or equipment containing 50 ppm of polychlorinated biphenyls (PCB's) and those containing unknown amounts of polychlorinated biphenyls (PCBs), which should be assumed as containing more than 50 ppm, must implement procedures that: display a Warning/Danger label stating which materials or equipment contain polychlorinated biphenyls (PCB')s; give access only to authorized personnel in areas containing polychlorinated biphenyls (PCB); provide annual inspections for those materials and equipment containing polychlorinated biphenyls (PCB); have in place containment procedures in case of a spill; a sanitization process for all polychlorinated biphenyls (PCB) materials that have not been disposed of or intended for reuse; and any materials or equipment containing polychlorinated biphenyls (PCB) that are planned to be sent for disposal must be sent to an authorized disposal facility that accepts polychlorinated biphenyls (PCB) waste.
FACILITY CONTROL SYSTEM
The supplier must implement a Facility Control System (FCS) for health, safety and environment management to decrease or eliminate risks related to operations within the facility. Each facility shall: develop a written FCS policy which must be signed by the facilities senior location manager or general manager; develop a written FCS plan which incorporates health, safety and environment objectives that are developed based upon taking into account risks considered to be high, lawful, functional, hi-tech options, company obligations, financial, shareholders views and other obligations; implement procedures to manage all documents associated with FCS; implement an inspection procedure that allows for a full evaluation of the FCS during a period reliant on the overall risk of the facility; implement procedures that can determine and resolve noncompliance issues associated with the FCS; implement procedures that must be performed for the annual FCS management review; and communicate with their employees verbally, via email or through websites about FCS.
The inspection of supplier facilities are conducted by third-party monitoring companies, THADDEA and/or THADDEA affiliates. These inspections evaluate the supplier's compliance with THADDEA's Supplier Conduct Policy and the contractual obligations stated by country law.
STIPULATIONS OF COMMITMENT
they meet their obligations as employers to their employees. In addition, all third parties must agree to conform with laws applicable to the products they make and agree to respect THADDEA's Supplier Conduct Policy.
With the supplier agreeing to the terms stated herein the Supplier Conduct Policy, it is the responsibility of the supplier to execute and incorporate this policy and applicable laws into the practices of its business, and to ensure any sub-contractor manufacturing of THADDEA apparel and/or products is in compliance with this policy.
To validate compliance with the Supplier Conduct Policy and country law, the supplier shall provide requested information and cooperate with inspections conducted by THADDEA or third-party auditors affiliated with or independent of THADDEA, with or without prior notice. Any non-compliance issues identified from an inspection shall be addressed and rectified by the supplier in a timely period. Failure to address and rectify the issues may result in a decrease of placed orders or termination of the business arrangement.
THADDEA holds the right to take proper action against the supplier for failing to meet the country law requirements or contractual responsibilities or to take sufficient action to deal with reported matters.