Supplier Code of Conduct
Introduction
The Woodstream Supplier Code of Conduct (“Code”) reflects our commitment to ethical, legal, and responsible business practices and specifies the requirements and standards that we expect all Woodstream suppliers (“Suppliers”) to meet. For the purposes of this code, Suppliers include any organization or entity that directly or indirectly provides goods and/or services to Woodstream.
The Code is informed by industry’s best practices and internationally recognized standards, including but not limited to, the United Nations Guiding Principles on Business and Human Rights, United Nations Convention against Corruption, and the principles set forth in the International Labor Organizations Declaration on Fundamental Principles and Rights at Work.
Suppliers are expected to review this Code thoroughly and ensure their operations are in compliance. We also encourage Suppliers to hold their own supply chains to the same standards and expectations set forth in this Code.
Requirements and Best Practices
At Woodstream, we are committed to continuous improvement in our environmental, social and governance (ESG) efforts, and view our suppliers as key partners on this journey. This Code sets forth both mandatory requirements and aspirational best practices that guide our selection, evaluation, and continued engagement with Suppliers.
- Mandatory Requirements and Standards represent the minimum expectations for all suppliers.
- Best Practices are aspirational goals that all suppliers are strongly encouraged to work towards and may become mandatory in the future.
Additional expectations may apply based on the nature of the goods or services provided and will be properly communicated.
Business Conduct and Ethics
Mandatory Requirements and Standards
Legal Compliance
Suppliers must comply with all applicable laws and regulations in the countries in which they operate, as well as all laws and regulations that pertain to Woodstream products.
Anti-Corruption and Anti-Bribery
Suppliers must abide by the U.S Foreign Corrupt Practices Act, the Canada Corruption of Foreign Public Officials Act, and any other applicable anti-corruption and anti-bribery laws. Suppliers are prohibited from all forms of bribery, corruption, extortion, or embezzlement and must not directly or indirectly make any form of payment or promise in exchange for an improper business advantage.
Conflict of Interest, Gifts, Hospitality and Entertainment
Woodstream employees are prohibited from accepting gifts or entertainment from any individual or organization with an existing business relationship if the offering creates, or appears to create, a conflict of interest, violation of any applicable laws, or may influence a business or investment decision. Exemptions include gifts or entertainment of minimal value offered in the spirit of goodwill.
Human Rights and Ethical Labor Practices
Mandatory Requirements and Standards
Forced or Involuntary Labor (Modern Slavery)
Suppliers are prohibited from the use of all forms of forced, bonded, indentured or compulsory labor, including prison labor, military labor, slave labor, or any form of human trafficking. All workers must work under freely chosen employment, voluntary conditions, and freedom to terminate their employment at any time.
Child Labor & Protection of Young Workers
Suppliers must comply with applicable laws regarding the minimum age of employees and comply with all legal requirements for the work of authorized young workers particularly those pertaining to hours of work, wages, working conditions, and the handling of certain materials. Supplier shall ensure that young employees (generally accepted as less than 18 years of age) are protect from work conditions that could affect their health, safety, morals, or social, emotional, physical, or educational development.
Reasonable Work Hours, Conditions and Wages
Suppliers must provide a workplace free of harsh and inhumane conditions, including harassment, abuse, corporal punishment, mental or physical coercion or verbal abuse of workers. Workers should be able to openly communicate with management regarding working conditions without threat of reprisal, retaliation, intimidation, or harassment.
Anti-Discrimination
Suppliers must not discriminate in terms of employment, including hiring, compensation, advancement, discipline, termination or retirement for any of the following reasons: race, gender identity, sexual orientation, color, nationality, age, mental or physical disability, health conditions or disease, pregnancy, religion, or veteran status.
Conflict Minerals
Woodstream is committed to sourcing socially responsible materials. Suppliers must avoid sourcing raw materials that directly or indirectly contribute to armed conflict or human rights abuses, particularly those originating from the Democratic Republic of Congo and the adjoining countries. Conflict minerals for the purpose of this Code include tin, tantalum, tungsten, and gold (3TG).
Suppliers are expected to implement a system to avoid the purchase of Conflict Minerals from the Democratic Republic of Congo or adjoining countries. Suppliers shall obtain from their own suppliers correct and trustworthy information about the country of origin for all Conflict Minerals.
Safe and Healthy Workplace
Mandatory Requirements and Standards
Legal Compliance
Suppliers must comply with all applicable local and national health and safety laws and regulations.
Personal Protective Equipment
Suppliers must make available appropriate personal protective equipment (PPE) to workers and comply with local laws, standards (OSHA where applicable), and World Health Organization recommendations.
Safe Handling and Storage
Suppliers are expected to implement systems and training on proper handling and storage to prevent and mitigate accidental spills or exposure. A list should be maintained of all safety information for hazardous material and be readily available to all workers.
Environment and Sustainability
Mandatory Requirements and Standards
Legal Compliance
Suppliers must comply with all applicable environmental laws and regulations in their operations and should stay informed of all upcoming relevant regulations and proactively plan to meet future requirements.
Waste Management
Suppliers must manage waste responsibly and in accordance with all applicable waste disposal and treatment laws and regulations. All waste should be disposed of in a safe, legal, and environmentally sound manner.
Toxic Packaging & Product
Suppliers must certify that all packaging and packaging components comply with all applicable requirements of the toxics in packaging and product law(s) of the various U.S. states per Exhibit A.
Best Practices
Advance Waste Management
Suppliers are encouraged to promote waste reduction, with the goal to divert waste from landfills through reducing, reusing, or recycling efforts.
Greenhouse Gas Emissions
Suppliers are encouraged to monitor and effectively measure and report their scope 1 (direct) and scope 2 (indirect) emissions as defined by the Greenhouse Gas Protocol.
Monitoring and Compliance
Suppliers are expected to take a proactive approach to maintain compliance with this Code and must report any known issues of non-compliance with any Mandatory Requirements or Standards.
Woodstream reserves the right to monitor suppliers’ compliance through audits, assessments, questionnaires, or other appropriate measures to evaluate conformance with this Code.
Addressing Non-Compliance
If Woodstream becomes aware, or receives a report of non-compliance with this Code, appropriate actions will be taken to investigate, and findings will be discussed with the Supplier. Suppliers are expected to cooperate with the investigation and provide access to the information requested. Woodstream reserves the right to suspend or cease doing business with Suppliers who violate or attempt to compromise this Code.
Exhibit A
Certificate of Compliance
Supplier certifies that all products and packaging components sold to Buyer or its affiliates comply with the requirements of the toxics in packaging and products law(s), including all states.
Supplier certifies that the regulated metals – lead, mercury, cadmium, and hexavalent chromium – were not intentionally added to any package or packaging component during the manufacturing process.
- TSCA Title VI/ CARB Phase II for wood products (PB, MDF, flat plywood)
- Phthalate under CA Prop 65 for plastic material (PVC, PU, PVDC, EVA, Rubber, Silicon, Foam) (shall not contain the following seven phthalates- DEHP/ DBP/ BBP/ DnHP/ DINP/ DIDP / DNOP or should less than 1000 ppm individually)
- Lead content of paints or power coating under 16 CFR 1303 (should not contain or should be less than 90ppm)
- Cadmium content of paints or power coating on metal components under ASTM E1613 (should not contain or should less than 100ppm)
- Toxic in Packaging - Lead, Cadmium, Mercury and Hexavalent chromium (Packaging components shall comply with TPCH in those states with legislation)
- Total concentration of Pb, Cd, Hg, and hexavalent Cr ≤ 100 ppm
- Including 2021 model law update covering phthalates and PFAS where restricted by state law
- UL for electronic products
- FCC for electronic products
- RoHS compliance for electronic product (Directive 2011/65/EU, “RoHS 3”)