This Carmanah Technologies Corp. Supplier Code of Conduct (the “Code”), an extension of Carmanah’s Corporate Code of Business Conduct, formalizes the key principles under which suppliers to Carmanah Technologies Corp. (“Suppliers”) are required to operate. In addition, Carmanah requires that its Global Subsidiaries each must maintain their own Code of Conducts which embody the attributes listed below in this document. Carmanah is committed to monitoring compliance of Subsidiary level Supplier Code of Conducts.
The principals in the Code state Carmanah’s expectation for its Suppliers on identified business practices.
In selecting Suppliers, Carmanah seeks to do business with reputable business partners who are committed to ethical standards and business practices compatible with those of Carmanah. Carmanah strongly encourages suppliers to exceed the requirements of this Code and promote best practices and continuous improvement throughout their operations.
Carmanah expects its Suppliers to act responsibly in all respects and to ensure that no abusive, exploitative or illegal conditions exist in their supply chains. Carmanah requires that Suppliers comply with all applicable laws and regulations, as well as the principles set out in the Code. One tenet of this Supplier Code of Conduct is that Carmanah Suppliers must not use any type of involuntary or forced labor; this prohibits, among other things, slave labor or business practices which in any way rely on, or encourage, human trafficking. Where there is no local legal requirement, or if a local legal requirement is not as strict as the requirement included in this Code, Carmanah Suppliers are required to follow the requirement in this Code.
This Code will undergo an annual review and may be amended by Carmanah from time to time to reflect changes in circumstances. Material failures to comply with our Supplier Code of Conduct may result in the termination of our relationship with a Supplier, as may be permitted by applicable law.
Carmanah’s Suppliers are vital business partners, and together, these principles provide us with an opportunity to better the lives of the people we touch.
Supplier Code of Conduct
This Carmanah Technologies Corp. Supplier Code of Conduct (“Code”) formalizes the key principles under which suppliers to Carmanah Technologies Corp. and its global subsidiaries (“Carmanah”) are expected to operate.
In selecting suppliers, Carmanah works hard to choose reputable business partners who are committed to ethical standards and business practices compatible with those of Carmanah.
This Code formalizes Carmanah’s practices and makes clear that, recognizing differences in cultures and legal requirements, we expect that wherever our suppliers are located, producing products for us, producing components that we use in our products, and wherever services are performed for us, that they are produced and/or provided in a manner compatible with the high standards that contribute to the outstanding reputation of Carmanah and our brands.
Carmanah strongly encourages Suppliers to exceed the requirements of this Code and promote best practices and continuous improvement throughout their operations and those of their suppliers, service providers, and extended networks. If there is a conflict between applicable laws and this Code, or there is no local legal requirement, the stricter standard shall apply if it does not violate local law. A Supplier should contact Carmanah to discuss any inconsistency between a Code requirement and applicable local law.
Laws and Regulations
Suppliers must operate in full compliance with all applicable laws and regulations of the countries in which they operate and be in full compliance with this Code. If applicable laws prevent compliance with this Code, Carmanah expects to be informed by Suppliers.
Bribery, extortion and kickbacks are prohibited. Suppliers must comply with all applicable anti-bribery and anticorruption laws, and Carmanah’s Corporate Code of Business Conduct. Carmanah is subject to the U.S. Foreign Corrupt Practices Act (“FCPA”), which prohibits bribery of foreign government officials (including employees of state-owned enterprises).
Suppliers must comply with local laws regarding the minimum age of employees. The minimum age for workers must be the greater of: (a) 15 years of age or 14 years of age where local law allows such an employment age consistent with International Labor Organization guidelines; or (b) the age for completing mandatory (compulsorily) education; or (c) the minimum age established by law in the country of manufacture.
In addition, Suppliers must comply with all legal requirements for the work of authorized young workers, particularly those pertaining to hours of work, wages, safety, working conditions, and the handling of certain materials.
Suppliers must not use any type of involuntary or forced labor, including indentured, bonded, prison, slave or human trafficked labor.
Suppliers must treat all workers with respect and dignity. No work shall be subject to corporal punishment, physical, sexual, psychological or verbal harassment or abuse. In addition, Suppliers will not use monetary fines as a disciplinary practice.
Wage and Benefits
Suppliers must pay workers at least the minimum compensation required by local law and provide all legally mandated benefits. In addition to payment for regular hours of work, workers must be paid for overtime hours at such premium rate as is legally required or, in those countries where such laws do not exist, at least equal to their regular hourly payment rate. In addition, Suppliers must provide accident insurance to their workers for work-related accidents and compensation for work-related accidents resulting in permanent disability.
Hours of Work
Suppliers must ensure that on a regularly scheduled basis, except in extraordinary business circumstances, workers are not required to work more than (a) 60 hours a week, including overtime, or (b) the limits on regular and overtime hours allowed by the law of the country of manufacture. In addition, except in extraordinary business circumstances, all workers are entitled to at least one day off in every seven-day period.
Health and Safety
Suppliers must provide workers a clean, safe and healthy work environment in compliance with all legally mandated standards for workplace health and safety in the countries in which they operate. This includes any residential facilities a Supplier provides to its workers.
Suppliers must ensure employment – including hiring, payment, benefits, advancement, termination and retirement – is based on ability and not on beliefs or any other personal characteristics such as color, race, caste, religion, age, maturity, nationality, social or ethnic origin, status, sexual orientation, gender, gender identity or expression, HIV, marital status, pregnancy, political affiliation, military service (Veterans), union membership, disability or any other status or characteristic that is not related to the individual’s merit or the inherent requirements of the job.
Suppliers will ensure women workers receive equal treatment in all aspects of employment. Pregnancy tests will not be a condition of employment and pregnancy testing – to the extent provided – will be voluntary and the option of the worker. In addition, workers will not be forced to use contraception.
Freedom of Association and Collective Bargaining
Suppliers must recognize and respect any rights of workers to exercise lawful rights of free association, including joining or not joining any association. Suppliers also must respect any legal right of workers to bargain collectively.
Suppliers must comply with all local environmental laws applicable to the workplace, the products produced, the methods of manufacture and the processing and responsible disposal of waste and hazardous waste. Additionally, Suppliers must not use materials that are considered harmful to the environment but should encourage the use of processes and materials that support sustainability of the environment, such as materials high in recycled content. Carmanah encourages Suppliers to monitor and record energy use in their facilities, further encouraging them to reduce energy consumption where possible.
Suppliers must not use subcontractors to manufacture Carmanah products or product components that contain Carmanah’s trademarks or tradenames without prior approval from Carmanah, and only after the subcontractor has agreed to comply with this Code. Suppliers must ensure that their suppliers, service providers, and extended networks have ethical and business practices that are similar to Carmanah’s practices.
Suppliers should communicate, through their existing ethical operating standards/practices or through this Code, so that their workers, supervisors and permitted subcontractors are aware of the expectations and requirements detailed in this Code.
Monitoring and Compliance
In 2018, Carmanah plans to meet with key Suppliers to collaborate on monitoring and compliance programs specific to each Supplier. This may include monitoring such as; announced and unannounced inspections of production facilities, full access to facilities, documents, worker records and workers for confidential interviews in compliance with local laws, to ensure compliance with this Code. In certain circumstances, Carmanah may require Suppliers to allow Carmanah customers to accompany Carmanah’s representatives during an audit.
Suppliers are expected to take necessary corrective actions to promptly remedy any identified noncompliance. Subject to specific contract requirements, Carmanah may terminate its business relationship with any Supplier which is unwilling or unable to comply with this Code.