CONTENT 1 Definition Of COC CONTENT 2 Section A - Labor (6 QUESTIONS) CONTENT 5 Section D – Ethics (5 QUESTIONS) CONTENT 3 Section B – Health & Safety (5 QUESTIONS) CONTENT 4 Section C – Environment (5 QUSETIONS) CONTENT 6 Section E - Management System (5 QUESTIONS) TABLE OF CONTENT
DEFINITION A set of guidelines and principles that outline the expected behavior and ethical standards within an organization. Helps to create a positive work environment, promotes trust and respect among employees, and helps to maintain the organization's reputation. Designed to align employees with the organization's core values and goals, and to ensure that they are all working towards a common purpose while upholding the company's standards of behavior.
-A- LABOR DEFINITION Respect human rights: Commit to treating all workers with dignity and respect, as recognized internationally. Apply to all workers: This principle applies to all types of workers, including temporary, migrant, contract, and others. Refer to recognized standards: Use established standards to guide the preparation of the code and for additional information.
EXPLANATION Workers should have the freedom to move around freely within the workplace and leave the premises after work without any undue restrictions. This is a fundamental right and part of ensuring that workers are not subjected to forced labor or unfair conditions. EXAMPLE In a compliant workplace, workers should be able to take breaks, visit the restroom, or leave the building after their shift without having to get special permissions or face unnecessary delays. If a factory were to lock its doors during work hours, preventing workers from leaving, this would be a violation of their rights. 1. Are there unreasonable restrictions on workers’ freedom of movement or on entering or exiting company-provided facilities?
EXPLANATION Employment agreements should be stable and transparent. Changes to these agreements should be communicated to employees in advance to maintain trust and ensure fairness. Sudden changes without notice can cause uncertainty and may be viewed as exploitative. EXAMPLES If a company decides to reduce the number of working hours, it should notify the employees at least a few weeks in advance, allowing them to adjust their schedules or discuss the changes. Unexpected reductions in hours without notice could leave employees financially vulnerable. 2. Are employment agreements subject to changes upon arrival in the receiving country, unless these changes meet local law and provide equal or better terms?
3. In the absence of local law, is the wage rate for student workers, interns, and apprentices at least the same as other entry-level workers performing equal or similar tasks? EXPLANATION Even if local laws do not mandate a specific wage, it is crucial that workers are paid enough to meet their basic needs, such as food, housing, and healthcare. This helps in maintaining a humane and ethical work environment. EXAMPLE A company might adopt a policy that ensures all employees are paid a living wage, regardless of the local minimum wage standards. For instance, even if the local law requires a minimum wage of $7 per hour, the company might choose to pay $10 per hour to ensure that workers can afford basic living expenses.
4 .Is a workweek more than 60 hours, including overtime, except in emergency or unusual situations? EXPLANATION Working hours are not to exceed the maximum set by local law. Further, a workweek should not be more than 60 hours per week, including overtime, except in emergency or unusual situations. Workers shall be allowed at least one day off every seven days EXAMPLE Imagine a company where the standard workweek is 40 hours. An employee is usually scheduled to work Monday to Friday, 8 hours a day. Due to a sudden large order that needs to be completed urgently, the company requests the employee to work additional hours, making it a total of 60 hours in that week (including overtime). If the situation persists and the employee is asked to work beyond 60 hours regularly, it may be seen as a violation of labor laws, unless it's during an emergency or under extraordinary circumstances. The employer would need to justify this extended work period; otherwise, they could face legal consequences.
5.Are workers provided with a timely and understandable wage statement that includes sufficient information to verify accurate compensation for work performed? EXPLANATION For each pay period, workers shall be provided with a timely and understandable wage statement that includes sufficient information to verify accurate compensation for work performed. EXAMPLE Workers are provided with a wage statement (commonly referred to as a "pay slip") every pay period, which is typically monthly. This pay slip includes detailed information that allows employees to verify that their compensation is accurate for the work they have performed
6. Are workers and/or their representatives able to openly communicate and share ideas and concerns with management regarding working conditions and management practices without fear of discrimination, reprisal, intimidation, or harassment? EXPLANATION An open communication channel between workers and management, where employees can voice their concerns about working conditions without fear of retaliation, such as being demoted, fired, or otherwise penalized. EXAMPLE In a manufacturing plant, workers notice that the ventilation system is not functioning properly, leading to poor air quality. They report this issue to their supervisor through a formal complaint system. The company investigates the concern and fixes the ventilation without punishing the employees who raised the issue.
-B- HEALTH & SAFETY DEFINITION Acknowledge the importance of a safe and healthy work environment for minimizing injuries and improving product quality, production consistency, and worker morale. Understand that ongoing worker input and education are crucial for identifying and solving health and safety issues.
1.Are there educational materials about risks associated with safety hazards provided to workers? EXPLANATION Company provides workers with access to materials that educate them about the risks associated with their job. These materials could include safety manuals, posters, videos, or training sessions that cover topics such as the proper use of equipment, handling hazardous substances, or emergency procedures. EXAMPLE A construction company provides its workers with a handbook detailing the risks of working at heights, the proper use of safety harnesses, and the procedures to follow in case of a fall. Workers are also required to attend a safety training session before starting on-site work.
2.Is there a system to encourage worker reporting of injuries and illnesses? EXPLANATION Company has a system in place that not only allows but encourages workers to report unsafe working conditions. This could include a dedicated hotline, suggestion boxes, or regular safety meetings where workers can report issues anonymously or openly. EXAMPLE In a chemical processing plant, there is an anonymous hotline that workers can call to report leaks or other safety hazards without fear of losing their job. The company investigates all reports and takes corrective action to address the hazards.
3.Are some chemical, biological, or physical hazards not controlled by design, engineering, or administrative means? EXPLANATION All potential hazards related to chemicals, biological agents, or physical risks are being effectively controlled and managed. This includes ensuring that proper safety protocols are in place, workers have the necessary protective equipment, and the work environment is regularly monitored for compliance with safety standards. EXAMPLE In a laboratory setting, all workers handling hazardous chemicals are required to wear gloves, masks, and protective clothing. The lab is equipped with fume hoods to prevent inhalation of dangerous fumes, and regular safety inspections ensure that all equipment is functioning correctly.
EXPLANATION Company has put in place adequate controls to mitigate risks associated with manual handling, such as lifting, carrying, pushing, or pulling heavy objects. Adequate controls might include ergonomic training, the use of mechanical aids, or the implementation of team lifting practices to reduce the risk of injury. EXAMPLE In a warehouse, employees are provided with training on proper lifting techniques to avoid back injuries. The company also supplies mechanical lifts and carts to help move heavy items, ensuring that workers do not strain themselves or risk injury. 4.Are there cases where controls for manual handling or repetitive tasks are not in place?
5.Are workers encouraged to raise safety concerns? EXPLANATION Encouraging workers to raise safety concerns is a critical aspect of maintaining a safe working environment. It involves creating an open and supportive culture where employees feel comfortable reporting potential hazards or unsafe practices without fear of retaliation. This approach not only helps prevent accidents but also promotes a proactive safety culture within the organization. EXAMPLE A company might implement a safety program where employees are trained to identify and report unsafe conditions. The company could also have a system in place, such as a suggestion box or a hotline, where workers can anonymously report safety concerns. Additionally, management might hold regular safety meetings where workers are encouraged to voice any concerns they have noticed in the workplace.
-C- ENVIRONMENT DEFINITION The company acknowledges that environmental responsibility is crucial for top-quality products. It will assess and reduce environmental impacts, protecting communities, nature, and resources during manufacturing, prioritizing public health and safety. References : ISO 14001 & eco management and audit system (EMAS)
1. Are all required environmental permits, approvals, and registrations obtained and kept current? EXPLANATION Environmental permits, approvals, and registrations are legal requirements for certain activities that impact the environment. Ensuring these are obtained and kept current is critical for legal compliance and for minimizing the environmental impact of business operations. EXAMPLE A manufacturing plant that emits air pollutants must obtain an air quality permit from the relevant environmental agency. The company must renew this permit periodically and comply with its conditions to continue operating legally.
EXPLANATION Companies are responsible for reducing or eliminating emissions and pollutants to protect the environment. This includes implementing controls and technologies that minimize harmful emissions into the air, water, and soil. EXAMPLE A factory might install filters or scrubbers on its smokestacks to reduce the emission of harmful gases into the atmosphere. If these technologies are not in place, the company would be non-compliant with environmental standards. 2. Are there any sources of emissions and discharges of pollutants that have not been minimized or eliminated?
EXPLANATION Effective solid waste management involves systematically identifying waste streams, reducing waste generation, and disposing of waste safely and legally. A lack of a systematic approach can lead to environmental contamination and legal penalties. EXAMPLE A company that produces electronic waste should have a formal process for identifying hazardous materials in its waste, reducing the amount of waste generated, and ensuring safe disposal or recycling of the waste. 3. Is there any solid waste management that lacks a systematic approach to identification, reduction, and disposal?
EXPLANATION Air emissions should be carefully characterized to understand their composition and impact. Routine monitoring and control are necessary to ensure emissions stay within legal limits, and treatment is often required to reduce harmful substances before they are released into the environment. EXAMPLE A chemical plant might use continuous emission monitoring systems (CEMS) to track the levels of pollutants like sulfur dioxide or nitrogen oxides in its emissions. These systems help the company stay compliant with air quality regulations. 4. Are air emissions characterized, routinely monitored, controlled, and treated as required before discharge?
EXPLANATION Companies must comply with all relevant laws, regulations, and customer requirements concerning restricted substances. Non-compliance can lead to legal action, fines, or loss of business. EXAMPLE If a company produces products for the European market, it must comply with the REACH regulation, which restricts certain hazardous chemicals. Failure to adhere to these restrictions could result in the product being banned from sale in the EU. 5. Are there any instances where applicable laws, regulations, or customer requirements regarding substance restrictions are not being adhered to?
-D- ETHIC DEFINITION Uphold high ethical standards to meet social responsibilities and succeed in the marketplace
1.Is there a zero tolerance policy for bribery, corruption, extortion, and embezzlement? EXPLANATION A zero-tolerance policy means that the organization strictly prohibits any form of bribery, corruption, extortion, and embezzlement, with no exceptions. This policy is crucial for maintaining ethical standards and ensuring that all business practices are conducted legally and transparently. EXAMPLE A company might have a policy where any employee found accepting bribes is immediately terminated, regardless of their position or the circumstances.
2.Does the organization allow offering or accepting bribes or other means to obtain an improper advantage? EXPLANATION An organization with high ethical standards should not permit the offering or accepting of bribes. Bribes are payments or gifts given to influence the actions of someone in a position of power, leading to unfair advantages. EXAMPLE A supplier offers a company’s procurement officer a luxury vacation in exchange for a contract. If the organization prohibits such actions, this offer would be rejected and reported.
3. Are whistleblowers' identities not protected or is retaliation against them allowed? EXPLANATION Whistleblower protection is essential for encouraging employees to report unethical or illegal activities without fear of retaliation. If a company does not protect whistleblowers, it may discourage employees from coming forward. EXAMPLE A company has an anonymous hotline where employees can report misconduct. The identity of the whistleblower is kept confidential, and any retaliation against them is strictly prohibited.
4.Does the organization have a policy to ensure that tantalum, tin, tungsten, and gold do not finance or benefit armed groups committing human rights abuses in the Democratic Republic of the Congo or adjoining countries? EXPLANATION This question relates to responsible sourcing practices. Companies are expected to ensure that their supply chains do not support armed conflict or human rights abuses, especially concerning minerals from conflict-affected regions. EXAMPLE A technology company requires its suppliers to provide certification that the minerals they use do not come from conflict zones and do not fund armed groups.
5.Is there a commitment to protecting the reasonable privacy expectations of personal information for everyone involved? EXPLANATION Protecting personal information is critical to maintaining trust and compliance with privacy laws. The company should ensure that all personal data is handled with care, confidentiality, and in line with legal requirements. EXAMPLE A company implements strict data protection measures, including encryption and limited access, to ensure that employees' and customers' personal information is secure.
-E- MANAGEMENT SYSTEMS DEFINITION Establish a management system aligned with this code. Ensure compliance with laws, regulations, and customer requirements. Adhere to the code's standards. Identify and manage operational risks related to the code. Promote continual improvement
EXPLANATION It’s important for companies to assign clear responsibility for management systems to ensure accountability and effective implementation. Senior executives should oversee these systems to ensure they are aligned with the company's goals. EXAMPLE A manufacturing company designates its Chief Operating Officer (COO) as the person responsible for overseeing compliance with environmental and safety regulations. 1. Has the company clearly identified senior executives and representatives responsible for implementing the management systems and associated programs?
EXPLANATION Companies should not only establish codes of conduct but also communicate these standards to their suppliers and regularly monitor compliance. This ensures that the entire supply chain adheres to ethical practices. EXAMPLE A retailer requires all its suppliers to sign a Code of Conduct agreement and undergo regular audits to verify compliance. 2. Does the company have a process to communicate Code requirements to suppliers and monitor their compliance with the Code?
EXPLANATION Effective communication of policies and performance is key to transparency and maintaining trust among all stakeholders. This includes providing regular updates and ensuring that all parties understand the company’s standards and performance. EXAMPLE A company holds quarterly meetings with its suppliers and workers to discuss policy changes, performance metrics, and expectations. 3. Does the company have a process for communicating clear and accurate information about its policies, practices, expectations, and performance to workers, suppliers, and customers?
EXPLANATION A corporate social responsibility (CSR) policy reflects a company’s commitment to ethical behavior, environmental stewardship, and social good. This policy should be visibly supported by top management and accessible to all employees. EXAMPLE A company posts its CSR policy, signed by the CEO, in all offices and factories in the local language to ensure that all employees are aware of the company’s commitments. 4. Does the company have a corporate social and environmental responsibility policy statement that is endorsed by executive management and posted in the facility in the local language?
EXPLANATION Companies must stay informed about the legal and regulatory environment in which they operate, as well as the specific requirements of their customers. This ensures compliance and helps in avoiding legal issues or customer dissatisfaction. EXAMPLE A legal team within the company regularly reviews new regulations and updates internal policies accordingly to ensure compliance with all relevant laws. 5.Does the company have a process to identify, monitor, and understand applicable laws, regulations, and customer requirements, including the requirements of this Code?