BCI Brands LLC Supplier Code of Conduct

Introduction to BCI Brands LLC (“BCI”) Supplier Code of Conduct

 

BCI Brands’ Supplier Code of Conduct (“Code”) is part of BCI’s broader commitment to partnering with organizations that are committed to fair and safe labor practices. The Code applies to all parties, including but not limited to agents, vendors, factories, contractors, and licensees that supply merchandise, materials, or services to BCI (collectively referred to herein as “Suppliers”).

This Code provides the minimum standards that must be met by Suppliers. BCI expects Suppliers to build and maintain policies and procedures to ensure continued compliance with these minimum standards. Additionally, compliance with this Code means that Suppliers are responsible for ensuring that entities they do business with as part of their supply chain also meet these minimum requirements.

BCI will review and may terminate any Supplier relationship if BCI believes a Supplier is not in compliance with this Code.

 

1. Forced Labor

 

Suppliers must ensure that they do not utilize forced labor. This includes prison labor, indentured labor, bonded labor, slave labor, state-sponsored forced labor, labor obtained through human trafficking or slavery, or any labor defined as forced labor by applicable local, provincial, or national law. Suppliers will ensure that all workers have full freedom of movement and are working on a voluntary basis.

Upon hiring, Suppliers will inform all workers of the basic terms of employment. Suppliers will also ensure that workers have access to their identifying documents and have the right to terminate their employment contract without penalty. Suppliers will not withhold financial benefits or other valuable items to bind workers to employment.

If workers are required to pay fees to the Supplier or a third party as a condition for being hired, these fees must be reimbursed to the employee without withholding wages or deducting these fees from the employee’s wages.

 

2. Child Labor

 

As part of the hiring process, Suppliers must have procedures in place to conduct age verification. Suppliers shall not employ any persons under the age of 15 or under the minimum age established by applicable local, provincial, and national law (whichever is higher).


3. Discrimination, Harassment and Abuse

 

Suppliers shall not subject employees to discrimination in any aspect of employment, including recruitment, hiring, advancement, discipline, termination, or retirement on the basis of sex, religion, race, color, national origin, age, social or ethnic origin, caste, union membership, marital status, pregnancy, parental status, disability (physical, mental, or sensory), political opinion, beliefs, sexual orientation, and gender identity expression.

Suppliers must ensure that all workers are treated with respect and dignity. Workers must not be subject to verbal, physical, psychological, or sexual abuse or physical coercion, threats, or corporal punishment. Suppliers must not use fines to discipline employees.

Suppliers must have mechanisms in place to allow all employees to freely voice concerns without fear of Supplier retaliation.

 

4. Health and Safety

 

Suppliers shall provide a healthy and safe working environment for all employees, establishing policies and procedures to ensure employees are not subject to hazardous and unsafe or unhealthy workplace situations. Suppliers must also have policies and procedures in place to provide protection from accidents, injuries, and exposure to hazardous materials. To ensure such an environment exists, Suppliers must follow all applicable local, provincial, and national health and safety laws and regulations. Suppliers shall provide a healthy and safe working environment for all employees, establishing policies and procedures to ensure employees are not subject to hazardous and unsafe or unhealthy workplace situations. Suppliers must also have policies and procedures in place to provide protection from accidents, injuries, and exposure to hazardous materials. To ensure such an environment exists, Suppliers must follow all applicable local, provincial, and national health and safety laws and regulations, including those relating to building safety, fire safety, electrical safety, chemical safety, sanitation, emergency preparedness, first aid, and personal protective equipment. If a Supplier provides housing for workers, they must also ensure that all housing is safe and healthy.

 

5. Freedom of Association

 

Suppliers shall recognize and respect employees’ right to freedom of association, organization, and collective bargaining. Suppliers shall ensure that employees are not subject to discrimination or discipline for associating, organizing, or collectively bargaining. When employees are either associating, organizing, or collectively bargaining, Suppliers must not threaten, spy, or interrogate them as retaliation for exercising their rights to freedom of association.

Where the right to freedom of association is restricted by law, Suppliers shall allow employees to exercise their right to freedom of association within the parameters of the law without fear of discrimination, harassment, or discipline.

 

6. Fair Wages and Benefits

 

Suppliers shall pay employees at least the minimum wage required by law, prevailing industry wage, or the wage negotiated in a collective bargaining agreement, whichever is highest. Suppliers shall also pay workers on time for all work (both regular and overtime) completed and provide benefits required by law and by contract on a timely basis. Suppliers must maintain proper wage documentation and statements in accordance with all applicable local, provincial, and national laws.

 

7. Working Hours and Overtime

 

Suppliers shall not establish a regular workweek that exceeds 48 hours or the applicable legal limit for a regular workweek, whichever is lower. All work over the lesser of 48 hours or the applicable legal limit for a regular workweek will be considered overtime, and the Supplier shall compensate the employee with overtime wages at a premium rate. All overtime shall be voluntary. Suppliers shall have policies and procedures in place to maintain accurate time records for all employees.

Total working hours shall not exceed 60 hours per week or the applicable legal limit, whichever is lower. Employees will not be subject to discrimination, abuse, harassment, or dismissal for refusing to work overtime hours.

Suppliers will allow employees at least one full day off (24 contiguous hours) per 7 days of work.

 

8. Compliance with Laws and Regulations

 

All Suppliers must comply with the local laws and regulations of the countries, provinces, and local jurisdictions where they operate.

 

9. Environmental Compliance

 

Suppliers must maintain compliance with all applicable local, provincial, and national environmental laws and operate with the appropriate and relevant environmental permits and licenses required in the countries, provinces, and local jurisdictions where they operate.

 

10. Subcontracting and Upstream Supply

 

A “Subcontractor” is defined as any entity contracted or hired by a Supplier to perform labor or services related in any way to the products supplied to BCI by a Supplier, as well as any upstream supplier of labor or services to such an entity. An “Upstream Material Supplier” is defined as any entity involved in supplying materials (including raw materials) to a Supplier that are incorporated in the products supplied to BCI, as well as any upstream supplier of materials (including raw materials) to such an entity.

All Subcontractors and Upstream Material Suppliers used by Suppliers must comply with all aspects of this Code. It is the responsibility of a Supplier to ensure compliance with all aspects of this Code by Subcontractors and Upstream Material Suppliers. All Subcontractors must be disclosed to BCI prior to production and approved by BCI in writing before production begins.