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petsustainabilitycoalitionSupplier Code of ConductTemplate*v.1 2017What’s Included?Code of Conduct DefinitionRecommended Process for Developing, Implementing,and Monitoring your Code of ConductCode of Conduct TemplateBusiness IntegrityHuman RightsFair and Equal TreatmentBenefits, Compensation, and HoursHealth and SafetyEnvironmental ManagementCommunication and ReportingSustainable Sourcing Guidelines11-25-13678910111214-16
SUPPLIER CODE OF CONDUCT TEMPLATEpetsustainabilitycoalitionDefinition: What is a Supplier Code of Conduct? (CoC)A supplier CoC is a set of standards that a company and its suppliers agree to ensure that a setlevel of environmental and social practices are met. A CoC helps a company ensure that its suppliersengage in social and environmental practices that are aligned with its brand values which drives twoprimary values:1. To protect a brand from damage in the occurrence of a code of conduct violation.2. To strengthen the supplier relationship therefore encouraging continued innovation,communication, and shared investment.Why is a Supplier Code of Conduct Necessary?Environmental and social standards vary widely across the globe and a company’s ability to getaccurate information about factory compliance with local laws is unreliable.Recommended Process for developing a Supplier Code of Conduct:While the template included in this document is meant to serve the development of your company’scustomized Coc, there are additional steps in the code of conduct process that can ensure that yourcode of conduct is effective.1. Assess your company’s supply chain risks.The template provided does not account for ALL materials and products that are currently orwill be used in the pet industry. Therefore, identifying the major risks related to your company’sspecific supply chain can help ensure that your COC addresses all areas of risk. The followingquestions can help guide this process: What countries do you source your materials/ingredientsfrom? Are there known environmental or human rights issues related to these locations?Does your product require the use of toxic chemicals in its manufacturing process? What arebest practices for handling and disposing of these chemicals and does your supplier have apolicy that ensures these practices are followed? Are there opportunities in the manufacturingprocess of your product to directly contradict your company’s stated environmental and socialobjectives?2. Talk to your suppliers about existing Codes of Conduct and standards.Suppliers receive codes of conduct, audits, and surveys at nausea. Do your part not to cause“survey fatigue” by asking your suppliers if they are already meeting a set of environmental andsocial standards or other common codes of conduct. You can then review the systems they arealready using and determine if they are meeting and reporting on your expectations or if thereare additional areas of performance that you would like to evaluate with them.3. Develop your own Supplier Code of Conduct using the attached template.4. Implement and Monitor your Supplier Code of Conduct.Your code of conduct will provide the most value to you if you are able to measure complianceon a semi-annual basis and develop programs to address any violations, or areas of lowperformance. At a minimum, you can ask all suppliers to sign the code of conduct (frequently aspart of a master purchase agreement or contract renewal) indicating that they are in compliancewith the environmental and social terms included.2
SUPPLIER CODE OF CONDUCT TEMPLATEpetsustainabilitycoalition4. Cont.The primary options for monitoring supplier performance are:i. Supplier Self Assessment: If you believe you can get reliable information from yoursuppliers you may ask them to review your code of conduct and indicate that they are incompliance by using a checklist or other on-line form.ii. Internal Audit: You may choose to send a trained employee to conduct an audit from yourcompany.ii. External Audit: If budget allows, you may choose to hire a 3rd party to conduct supplieraudits.What to do in case of violation. You should work with your team before going through the audit process todetermine how you will handle violations of your code of conduct.Three things to consider:1. What are the consequences to the supplier in violation?Under what circumstances will you stop working with a supplier? Under what time-frame?How long does the supplier have to get into compliance?What role your company is willing to take to help a supplier become compliant?What happens if there is a repeat violation from the same supplier?2. If a violation is found, what level of transparency do you want to have with the public and or yourinternal team about violations discovered?3. What barriers might your suppliers be facing when trying to become compliant?What can you do to address these barriers? (Longer term contracts that ensure consistent financialresources that can be invested in improvements/infrastructure/etc?).Recognize outstanding supplier performance. While many companies are prepared to respond to violationsof their code of conduct, you can also consider how to acknowledge high levels of performance and supplierswho demonstrate continued improvement.For your consideration:1. What kind of acknowledgment would be valuable to your suppliers? (Award, paid visit to yourheadquarters, longer term contracts, etc)PSC’s Code of Conduct Template was built in collaboration with Sterling Consulting. The resources used tocompile the COC were the International Labour Organization, UN Declaration on Human Rights, Fair LaborAssociation, global Impact Investing Rating System, as well notable best practices from companies such asApple, Clif Bar, Mars, McDonald’s, Nestle, Patagonia, Perdue, Sodexo, Starbucks, Unilever, and Walt Disney.3
SUPPLIER CODE OF CONDUCT TEMPLATEpetsustainabilitycoalitionHow to use PSC’s template:Most COC state the most minimum environmental and social standards expected by a company todo business with them. However, PSC encourage its members to develop a code of conduct as aframework that can help guide suppliers toward improved environmental and social performance inalignment with your values. Therefore in addition to minimum requirements, we are also includinga set of performance standards that you can include called “working toward” standards. You maychoose to set a time-line when some of these “working toward” standards become minimumstandards or you can simply include them as additional performance metrics that can inform supplierrecognition programs and/or indicate to your suppliers the types of environmental and socialstandards you would like to see them working toward.As this COC is not written for a specific company and is intended for use by all PSC members, therewill be areas where edits should be made or will need to be tailored including:Document KeyGreen Text: A portion that likely only pertains to manufacturing non consumable hard-goods includingtoys, leashes, collars, etc.Orange Text: A portion that likely only pertains to consumables manufacturing including treats, food,etc.Red Text: A portion that may be difficult for pet suppliers to implement currently but is standards withcurrent food/beverage companies and so may overlap with other expectations.Yellow Highlighting: Text that will need to be updated with the appropriate #, figure, or language.: The space where your company’s name will need to be inserted.4
SUPPLIER CODE OF CONDUCT TEMPLATEpetsustainabilitycoalitionCODE OF CONDUCTAt our mission is to . (Insert Company Mission/Values Statement)In alignment with our mission and as apart of our ongoing sustainability efforts we have developedthe Code of Conduct (“the Code”) to ensure that all of our business partners, suppliers,and manufacturers meet our basic expectations of doing business related to legal requirements,ethical practices, human rights, and environmental management. These standards are based onwell-respected and recognized international standards, including the International Labor Organization,United Nations Universal Declaration of Human Rights, and industry best practices.Compliance with these standards is an expectation of doing business with , as the Codedefines the non-negotiable minimum standards that we ask our suppliers and their sub-tier suppliersor sub-contractors (“the Supplier”), to respect and adhere to.seeks to develop and strengthen partnerships based on a shared commitment oftransparency, collaboration, and mutual respect. We recognize that our suppliers are independentbusinesses and the exclusive employers of their workers. However, the actions of our businesspartners can be attributed to , affecting not only our reputation, but the level of trust wehave worked hard to earn from partners, customers, and pet owners. While appreciatesthat our suppliers operate in a variety of different legal, geographical, and cultural environments weexpect all Suppliers to comply with the Code, and hope that our Suppliers will strive to exceed thesestandards.The standards of this Code are in addition to, and not in lieu of, the provisions of any legal agreementor contract between a supplier and . The following seven categories encompass theCode of Conduct.5
SUPPLIER CODE OF CONDUCT TEMPLATEpetsustainabilitycoalition1. BUSINESS INTEGRITYis committed to the highest standards of business integrity. We do not tolerate anypractice that is inconsistent with the principles of honesty, integrity and fairness, anywhere we dobusiness.REQUIREMENTSWORKING TOWARDa.Compliance with LawSuppliers’ business activities shall complywith all applicable laws and regulations inthe countries and jurisdictions in which theyoperate. This Code applies to activities in thelocations where suppliers’ goods are produced,where any related services are performed, andwhere the goods enter the supply chain.f.Intellectual PropertySupplier respects the intellectual propertyrights of others. Supplier takes appropriatesteps to safeguard and maintain confidentialand proprietary information or trade secrets ofand uses such information only forthe purposes authorized for use by .b.BriberyThere is a prohibition of any and all forms ofbribery, corruption, extortion or embezzlementand there are adequate procedures in placeto prevent bribery in all commercial dealingsundertaken by the supplier.g.Additional StandardsIn addition to this Code, the Supplier is boundto any additional requirements as applicableto the materials or services to be delivered toand in particular the requirements ofthe Responsible Sourcing Guidelines.c.Conflicts of InterestSuppliers will disclose to anysituation that may appear to be a conflict ofinterest, and disclose if a worker from one oftheir family members, or a friend may have aninterest of any kind in Supplier’s business orany kind of economic ties with Supplier.d.Freedom of AssociationSuppliers shall respect the rights of workers toassociate or not to associate with any group,as permitted by and in accordance with allapplicable laws and regulations.e.RecordsThe Supplier shall maintain transparent andup to date books and records to demonstratecompliance with this code and applicablegovernmental and industry regulations.6
SUPPLIER CODE OF CONDUCT TEMPLATEpetsustainabilitycoalition2. HUMAN RIGHTSexpects our suppliers to conduct their activities in a manner that respects human rights .REQUIREMENTSWORKING TOWARDa.Voluntary LaborSupplier employs all workers on a voluntarybasis free from any threat of violence, threatsof criminal penalty, and restrictions on freedomof movement. Supplier shall not use anyprison, slave, bonded, forced, indentured, ordebt induced labor, or engage in any otherforms of compulsory labor, or any other formsof slavery or human trafficking.d.Worker DocumentationSupplier does not require workers to depositoriginal identification documents, traveldocuments or any other personal legaldocuments upon commencing employment withSupplier.b.Minimum AgeUnder no circumstances will supplier employworkers under the age of 15 or under theminimum age for work or mandatory schoolingas specified by the local law, whichever ishigher. When young workers are employedthey must not do work that is mentally,physically, socially or morally dangerous orharmful or interferes with their schooling bydepriving them of the opportunity to attendschool. In the case of hazardous work, theminimum age is 18.c.Employment PracticesThe supplier shall only employ workerswho are legally authorized to work in theirfacilities and are responsible for validatingworkers’ eligibility to work through appropriatedocumentation. All work shall be voluntary, andworkers shall be free to leave work or terminatetheir employment upon reasonable notice.e.Migrant LaborSupplier recognizes the unique legal, social, andcultural situations that migrantworkers face and will ensure that such workersare treated with dignity, respect, and inaccordance with the same standards as apply toother workers.f.PrivacyThe Supplier shall respect the privacy rightsof its workers whenever it gathers privateinformation or implements worker monitoringpractices.g.Recruitment & SecuritySupplier shall ensure that if third-partyrecruitment agencies are used they arecompliant with the provisions of this Code andthe law. Suppliers recruiting foreign contractworkers either directly or through third partyagencies shall be responsible for payment of allrecruitment-related fees and expenses. Whenthe Supplier retains direct or contracted workersto provide security to safeguard its personneland property, the Supplier will make sure thatsecurity personnel apply the standards in thiscode.7
SUPPLIER CODE OF CONDUCT TEMPLATEpetsustainabilitycoalition3. FAIR AND EQUAL TREATMENTbelieves all workers deserve an equal chance to succeed based on their hard work,talent, and commitment, and should always be treated with fairness and respect.REQUIREMENTSWORKING TOWARDa.Discrimination & HarassmentAll workers are treated with respect anddignity. No worker is subject to any physical,sexual, psychological, verbal harassment,abuse or other form of intimidation. There isno discrimination in employment, includinghiring, compensation, advancement, discipline,termination or retirement. Discrimination basedon caste, national origin, ethnicity, religion,age, disability, gender, marital status, sexualorientation, union membership, politicalaffiliation, health, disability or pregnancy isprevented. In particular, attention is paidto the rights of workers most vulnerable todiscrimination.c.Diversityexpects its Suppliers to demonstratea diverse workforce composition activelyembracing workforce age, gender, race, nationalor ethnic origin, religion, language, politicalbeliefs, sexual orientation, physical ability andpromoting supply chain inclusion throughout theirown supply chains.b.Grievance MechanismThe Supplier shall provide all workers withtransparent, fair, accessible and confidentialprocedures that result in swift, unbiased andfair resolution of difficulties which may ariseas part of their working relationship. Workerswill be protected from retaliation for submittingsuch complaints.d.TransportationSupplier shall work collaboratively with workersto ensure their adequate access to necessaryservices. Any transportation provided by theSupplier or agent on Supplier’s behalf must besafe and in compliance with legal requirements.Should the Supplier relocate the worker from theoriginal point of hiring, the Supplier shall providereturn passage to the origination location at nocharge to the worker.e.Discrimination & Harassment (expanded)Supplier does not conduct medical tests onworkers that can be used to discriminate (e.g.pregnancy testing). The results of any tests thatare required by local legislation shall not beused in a discriminatory way. The supplier shallnot use any form of home working arrangementfor the production of any branded oraffiliate product.f.CommunitySupplier will ensure due diligence is undertakento uphold individual, community or indigenouspeople’s established rights to property and land.8
SUPPLIER CODE OF CONDUCT TEMPLATEpetsustainabilitycoalition4. BENEFITS, COMPENSATION, AND HOURSexpects Suppliers to provide workers with fair and equal compensation for hours worked,and that all work is conducted on a voluntary basis.REQUIREMENTSWORKING TOWARDa.Wages BenefitsSupplier pays workers on time, inaccordance with legal requirements, and inall circumstances, wages must be paid on atleast a monthly basis and in the name of theindividual performing the work. Workers areprovided with a total compensation packagethat includes wages, overtime pay, benefits andpaid leave which meets or exceeds the legalminimum standards or appropriate prevailingindustry standards, whichever is higher. Inaddition to their compensation for regularhours of work, workers shall be compensatedfor overtime hours at such premium rate as islegally required in the country of manufactureor, in those countries where such laws do notexist, at a rate at least equal to their regularhourly compensation rate. Compensationterms established by legally binding collectivebargaining agreements are implemented andadhered to without bias.c.Employment ContractSuppliers, where reasonably possible, mustprovide all workers (permanent, temporary,seasonal, domestic and migrant) with a writtencontract in the appropriate language thatincludes a description of job duties, benefits,disciplinary procedures, and notice periods.Where the provision of a written contract is notreasonably possible or practical, suppliers shallprovide workers with a verbal description of theterms of their employment.b.Working Time & Rest DaysThe Supplier must ensure that its workerswork in compliance with all applicable lawsand mandatory industry standards pertainingto regular working hours, and overtime hours,including breaks, rest periods, holidays, andmaternity and paternity leaves. In absenceof law, the Supplier shall not require aregular work week over 60 hours, workersshall be allowed at least one day off after sixconsecutive days of work, and any overtimeworked shall be voluntary and compensated atpremium rate.d.Wage StatementSupplier will provide workers access toan itemized wage statement for each payperiod clearly indicating the components oftheir compensation (hours, pieces, or unitsproduced), including exact amounts for wages,benefits, incentives bonuses, and deductions.Deductions of pay other than those legallymandated, may not be made without the expressand written consent of the worker, and underno circumstances may be made as a form ofdiscrimination or punishment.e.Living WageThe Supplier shall ensure workers are provideda living wage, sufficient to meet basic needs forworkers, and their entitled official dependents,and to provide some discretionary income.9
SUPPLIER CODE OF CONDUCT TEMPLATEpetsustainabilitycoalition5. HEALTH AND SAFETYexpects the Suppliers operations, facilities, and procedures to protect and promoteworker health and safety.REQUIREMENTSWORKING TOWARDa.Workplace EnvironmentThe Supplier shall provide its workers with asafe and healthy working environment. At aminimum, potable drinking water, adequatelighting, temperature, ventilation, sanitationfacilities, and personal protective equipmentmust be provided together with equipped workstations at no cost. In addition, facilities mustbe constructed and maintained in accordancewith the standards set by applicable laws andregulations.d.Emergency PreparednessThe Supplier shall be prepared for emergencysituations. This includes worker notification andevacuation procedures, emergency training anddrills, appropriate first-aid supplies, appropriatefire detection and suppression equipment,and adequate exit facilities. The Supplier shallregularly train workers on e
headquarters, longer term contracts, etc) PSC’s Code of Conduct Template was built in collaboration with Sterling Consulting. he resources used to compile the COC were the International Labour
