Responsible Business A Awareness Training - 1 day.pptx

shiva3305 258 views 110 slides Jul 04, 2024
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About This Presentation

RBA


Slide Content

RBA Awareness Training Prepared by PARABAKARAN BALASUBRAMANIAM

2 Instructor Introduction 2 Professional Summary: With over 15 years of comprehensive experience in Environmental Safety and Health (HSE), Parabakaran Balasubramaniam is a seasoned professional with specialized expertise in delivering impactful training programs. He holds a Master's Degree in Environmental Safety and Health from the University Malaysia Pahang and has dedicated 5 years specifically to the field of HSE training and consultancy. Key Skills and Competencies: Extensive knowledge in environmental safety regulations and compliance standards. Proven track record in designing and delivering engaging and effective HSE training modules. Strong understanding of risk assessment methodologies and hazard control strategies. Skilled in conducting safety audits and implementing corrective measures. Excellent communication and interpersonal skills for effective training delivery

Objective: At the end of this lesson, participants are able to:   Understand the purpose of Social Responsibilities, Pre-ESG, UNGC and RBA requirements Know what to do based on the requirements Become familiar with the requirements of the Supplier Responsibilities in compliance to the requirements Explain how Social Compliance & Accountabilities requirements will fit into your organization Identify the key concepts of Social Compliance requirements

The Issues Today and Overview of CSR In today's global landscape, businesses face a myriad of challenges and societal issues that demand attention and action. From environmental concerns to social inequality, organizations are increasingly expected to go beyond profit-making and embrace a broader sense of responsibility towards society and the planet. This is where Corporate Social Responsibility (CSR) comes into play. Overview of CSR What is CSR? Corporate Social Responsibility (CSR) refers to a company's commitment to operate ethically and contribute positively to the economic, social, and environmental well-being of society beyond its core business activities.

Key Elements of CSR: Environmental Sustainability: Minimizing environmental impact, reducing carbon footprint, and promoting sustainable practices such as renewable energy use and waste reduction. Social Responsibility: Investing in community development, supporting local initiatives, promoting diversity and inclusion within the workforce, and ensuring fair labor practices. Ethical Governance: Upholding ethical business practices, transparency in operations, and adherence to legal and regulatory standards. Stakeholder Engagement: Collaborating with stakeholders (employees, customers, suppliers, communities) to address concerns and incorporate their perspectives into business decisions.

Importance of CSR 1. Enhancing Reputation and Brand Image: CSR initiatives can strengthen a company's reputation and build brand loyalty among consumers who prioritize ethical and sustainable practices. 2. Attracting and Retaining Talent: Employees are increasingly drawn to socially responsible companies that demonstrate a commitment to making a positive impact. CSR programs can also contribute to higher employee engagement and retention. 3. Risk Mitigation: Proactive CSR efforts can help mitigate risks associated with environmental, social, and governance (ESG) issues, reducing potential regulatory, legal, and operational risks.

Importance of CSR 4. Creating Shared Value: CSR initiatives can create shared value by addressing societal needs while simultaneously generating business value, fostering long-term sustainability. 5. Stakeholder Trust and Relationships: Engaging with stakeholders through CSR initiatives can build trust and stronger relationships, leading to better collaboration and support during challenging times. 6. Contributing to Sustainable Development Goals (SDGs): CSR activities aligned with the United Nations' Sustainable Development Goals (SDGs) contribute towards global efforts to achieve a more sustainable and inclusive world. In summary, CSR is not just a philanthropic endeavor but a strategic approach that benefits businesses, society, and the environment alike. Embracing CSR can lead to long-term success and positive impact, positioning organizations as responsible corporate citizens in an increasingly complex and interconnected world.

Triple Bottom Line (TBL) The 3P concept, also known as the Triple Bottom Line (TBL), is a framework used to evaluate an organization's performance and success based on three dimensions: People, Planet, and Profit. This approach goes beyond traditional financial metrics (profit) to include social and environmental considerations. The Three P's of Triple Bottom Line (TBL): People (Social Dimension): This aspect focuses on the social impact and responsibility of the organization towards its stakeholders, including employees, customers, communities, and society at large. Key considerations under the "People" dimension include: Fair labor practices and workplace conditions Employee welfare, diversity, and inclusion Community engagement and development Health and safety initiatives Human rights protection and ethical business practices

Triple Bottom Line (TBL) 2. Planet (Environmental Dimension): The "Planet" dimension emphasizes the environmental impact of the organization's operations and its commitment to sustainability. Key considerations under the "Planet" dimension include: Resource conservation (energy, water, materials) Pollution prevention and waste reduction Adoption of renewable energy sources Climate change mitigation strategies Biodiversity conservation and ecosystem protection 3.Profit (Economic Dimension): While traditional business models focus primarily on financial performance and profitability, the TBL framework incorporates the economic dimension as one of the three pillars. Key considerations under the "Profit" dimension include: Financial stability and profitability Long-term value creation Cost efficiency and resource allocation Ethical and transparent business practices Contribution to economic development and prosperity

Benefits of Triple Bottom Line (TBL) Holistic Performance Evaluation: TBL provides a comprehensive view of organizational performance by considering social, environmental, and economic factors together. Long-Term Sustainability: By balancing the three dimensions, organizations can achieve sustainable growth and resilience in a rapidly changing world. Stakeholder Engagement: TBL encourages stakeholder engagement and collaboration, leading to stronger relationships and trust. Risk Management: Addressing social and environmental issues through TBL can mitigate risks and enhance resilience against external challenges. Enhanced Reputation: Embracing TBL can enhance brand reputation and attract socially conscious customers, investors, and employees. In summary, the Triple Bottom Line (3P) approach is a strategic framework that encourages organizations to evaluate their impact beyond financial outcomes and prioritize sustainable practices that benefit people, the planet, and profitability simultaneously. Adopting TBL principles can lead to long-term value creation and positive societal impact.

Importance of Social Compliance: Ethical Responsibility: Social compliance reflects a company's commitment to ethical conduct and respect for human rights. It ensures fair treatment of workers, including safe working conditions, fair wages, and protection from discrimination and harassment. Worker Well-being and Safety: Social compliance prioritizes the health, safety, and well-being of workers. Compliance with labor laws and safety regulations reduces workplace accidents, injuries, and occupational health risks. Legal Compliance and Risk Management: Adhering to social compliance standards helps companies comply with local labor laws, international regulations, and industry standards. This reduces legal risks, potential fines, and reputational damage associated with non-compliance. Brand Reputation and Consumer Trust: Socially compliant companies build positive brand reputation and earn consumer trust. Consumers increasingly prefer products and services from companies that demonstrate ethical practices and social responsibility. Employee Engagement and Retention: Socially responsible companies attract and retain talent more effectively. Employees are motivated to work for organizations that prioritize their well-being and offer a supportive work environment.

Importance of Social Compliance: Community Relations and Impact: Social compliance extends beyond the workplace to community relations. Companies that engage positively with local communities through social initiatives and responsible practices contribute to community development and support. Supply Chain Transparency: Social compliance requires transparency throughout the supply chain. Companies must ensure suppliers and partners also adhere to ethical standards, promoting fair labor practices and environmental responsibility. Sustainable Business Practices: Social compliance aligns with sustainable business practices by promoting resource efficiency, waste reduction, and environmental stewardship. It encourages responsible sourcing and production methods. Investor and Stakeholder Confidence: Investors and stakeholders increasingly consider social compliance as a key indicator of long-term business sustainability and ethical governance. Socially responsible companies attract responsible investment and support. Global Standards and CSR Commitments: Social compliance contributes to global standards and corporate social responsibility (CSR) commitments. It supports initiatives aimed at addressing global challenges such as poverty, inequality, and climate change.

UN Global Compact initiative Businesses should support and respect the protection of internationally proclaimed human rights; and make sure that they are not complicit in human rights abuses. Businesses should uphold the freedom of association and the effective recognition of the right to collective bargaining; the elimination of all forms of forced and compulsory labour; the effective abolition of child labour; and the elimination of discrimination in respect of employment and occupation. Businesses should support a precautionary approach to environmental challenges; undertake initiatives to promote greater environmental responsibility; and encourage the development and diffusion of environmentally friendly technologies Businesses should work against all forms of corruption, extortion and bribery.

Key objectives of the UNGC A strategic policy initiative for businesses in the areas of human rights, labour, environment and anti-corruption Allowing businesses to collaborate with international actors on current global challenges Mainstream the ten principles in business activities around the world Catalyze actions in support of broader UN goals, including the Millennium Development Goals (MDGs)

The benefits of engagement: Adopting an established and globally recognized policy framework Sharing best and emerging practices to advance practical solutions and strategies to common challenges. Advancing sustainability solutions in partnership with a range of stakeholders, including UN agencies Linking business units and subsidiaries across the value chain with the Global Compact's Local Networks around the world Accessing the United Nations' extensive knowledge of and experience with sustainability and development issues. Utilizing UN Global Compact management tools and resources, and the opportunity to engage in specialized projects

Human Rights Principle One Businesses should support and respect the protection of internationally proclaimed human rights within their sphere of influence; and Principle Two make sure they are not complicit in human rights abuses.

Human rights are: Inherent , in that they belong to everyone Inalienable , in that people cannot consent to giving them up or be deprived of them by governments or other institutions Universal , in that they apply to all people regardless of status Indivisible , in that no human rights can be selectively ignored Interdependent , in that realization of one right contributes to the realization of other rights

Labour Principle Three Businesses should uphold the freedom of association and the effective recognition of the right to collective bargaining; Principle Four the elimination of all forms of forced and compulsory labour; Principle Five the effective abolition of child labour; and Principle Six eliminate discrimination in respect of employment and occupation.

Background to labour issues The four labour principles of the Global Compact are taken from the International Labour Organization's Declaration on Fundamental Principles and Rights at Work. Labour practices include the responsibilities of the organization for work performed on its behalf by others, including subcontracted work. Meaningful and productive work is an essential element in human development; standards of living are improved through full and secure employment.

Environment Principle Seven Business should support a precautionary approach to environmental challenges; Principle Eight undertake initiatives to promote greater environmental responsibility; and Principle Nine encourage the development and diffusion of environmentally friendly technologies.

Background to environmental issues The Rio Summit Agenda 21 explained that population, consumption and technology were the primary driving forces of environmental change and for the first time, at an international level, explicitly linked the need for development and poverty eradication with progress towards sustainable development Key Environmental Challenges loss of biodiversity and long-term damage to ecosystems pollution of the atmosphere and the consequences of climate change damage to aquatic ecosystems land degradation the impacts of chemicals use and disposal waste production depletion of non-renewable resources

Anti-Corruption Principle Ten Businesses should work against corruption in all its forms, including extortion and bribery The adoption of the tenth principle commits UN Global Compact participants not only to avoid bribery, extortion and other forms of corruption, but also to develop policies and concrete programs to address corruption.

The business case for Anti-Corruption Legal risks: Not only are most forms of corruption illegal where it occurs, but also it is increasingly becoming illegal in a company's home country to engage in corrupt practices in another country. Reputational risks: Companies whose policies and practices fail to meet high ethical standards are exposed to serious reputational risks. Financial costs: There is now clear evidence that in many countries corruption adds upwards of 10 per cent to the cost of doing business and that corruption adds as much as 25 per cent to the cost of public procurement. The downward spiral: Once a bribe is paid, repeat demands are possible and the amounts demanded are likely to rise. If a company engages in or tolerates corrupt practice, it will soon be widely known. Blackmail: By engaging in corrupt practices, company managers expose themselves to blackmail and other security risks. Sustainable development: Resources diverted to improper use seriously compromises development and impacts poverty.

RBA VAP 8.0 Introduction & Overview

Overview of RBA 3 Founded in 2004 (EICC) Non-profit coalition of the world’s leading electronics companies Purpose - improve social, economic, and environmental conditions in the global electronic supply chain through use of a standardized code of conduct. Incorporated in 2007 as an association - to ensure greater awareness of the Code, and to expand its adoption across the industry - governed by a Board of Directors that oversees the association’s operations, communications, and programs In October 2017, rebranded from EICC to RBA (Responsible Business Alliance) -to reflect the expanded influence, capabilities, focus areas and membership of this organization

Reference: Verite Fair Labor Training Material. The up-to-date RBA members list can be found at http://www.responsiblebusiness.org/about/members/

LABOR 1. Prohibition of Forced Labor 2. Young workers 3. Working Hours 4 Wages and Benefits 5. Non-Discrimination / Non-Harassment / Humane Treatment 6 Freedom of Association and Collective Bargaining AM . Labor Management System

ZERO Tolerance Items Labor Child Labor Forced Labor Bonded Labor Inhumane treatment Other Falsifying records Bribery Health & Safety Imminent health and safety issues as defined by VAP Imminent environmental risk as defined by VAP Please Note: All Zero Tolerance items require a closure audit (VAP or 3 rd Party AMA) 7

A. Labor Participants are committed to uphold the human rights of workers, and to treat them with dignity and respect as understood by the international community This applies to all workers including temporary, migrant, student, contract, direct employees, and any other type of worker

1. Prohibition of Forced Labor 31 Prohibition of Forced Labor : All forms of forced labor, including bonded, indentured, involuntary or exploitative prison labor, slavery, and human trafficking, are strictly prohibited. Prohibition of Coercive Practices : This includes any actions involving threats, force, coercion, abduction, or fraud to transport, harbor, recruit, transfer, or receive persons for labor or services. Freedom of Movement : Workers must not face unreasonable restrictions on their freedom of movement within the facility or when entering or exiting company- provided facilities, including dormitories or living quarters. Employment Agreements : Workers must receive a written employment agreement in their native language or a language they understand. Foreign migrant workers must receive this agreement before leaving their country of origin. No changes to the employment agreement are allowed upon arrival in the receiving country unless changes comply with local laws and offer equal or better terms.

A1. Prohibition of Forced Labor 32 Voluntary Employment : All work must be voluntary, allowing workers to leave or terminate their employment without penalty, given reasonable notice as specified in their contracts. Documentation : Employers must maintain records of all departing workers. Prohibition on Document Holding : Employers, agents, and sub-agents must not hold, destroy, conceal, or confiscate identity or immigration documents like IDs, passports, or work permits. Compliance with Local Law : Employers can hold documents only if required by l ocal law, but workers must always have access to their documents. Prohibition on Recruitment Fees : Workers must not pay recruitment fees or related charges to employers or their agents. Any such fees paid must be reimbursed to the worker.

2. Young workers 33 Prohibition of Child Labor : No child labor at any stage of manufacturing. "Child" defined as anyone under 15, under the age of compulsory education completion, or under the minimum employment age, whichever is higher. Young Workers : Workers under 18 should not engage in hazardous work or work that jeopardizes health or safety, including night shifts and overtime. Student Workers Management : Maintain accurate student records. Conduct thorough due diligence of educational partners. Protect students' rights per applicable laws and regulations. Verification of Workers' Age : Implement mechanisms to verify the age of workers. Support legitimate workplace learning programs that comply with laws and regulations.

2. Young workers 34 Support and Training for Student Workers : Provide appropriate support and training. Ensure student workers, interns, and apprentices receive at least the same wage rate as other entry-level workers for similar tasks, in the absence of local law. Remediation for Identified Child Labor : Provide assistance and remediation if child labor is identified.

Studies of business practices clearly link worker strain to reduced productivity, increased turnover, and increased injury and illness 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. All overtime must be voluntary. Workers shall be allowed at least one day off every seven days 3. Working Hours

3. Working Hours Management Policy, procedures to determine, communicate, record, manage and control work hours are in place Workers are allowed to have annual leave, public holidays, sick leave, maternity leave and other legally mandated breaks Regular Workweeks shall not exceed 45 hours Working hours: Max 45h/week, 8h-10h/day Overtime: Max 4h/day Total: Max 60h/week, 12h/week (RECOMMENDED, common standards of many buyers) 1 day off in every 7 days

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Compensation paid to workers shall comply with all applicable wage laws , including those relating to minimum wages , overtime hours and legally mandated benefits In compliance with local laws, workers shall be compensated for overtime at pay rates greater than regular hourly rates 4. Wages and Benefits (1)

Deductions from wages as a disciplinary measure shall not be permitted 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. All use of temporary, dispatch and outsourced labor will be within the limits of the local law 4. Wages and Benefits (2)

4. Wages and Benefits (3) Social insurance scheme and other benefits as required by local law is provided to all workers Compensation paid to workers shall comply with all applicable wage laws, including those relating to minimum wages, overtime hours and legally mandated benefits All use of temporary, dispatch and outsourced labor will be within the limits of the local law

4. Wages, Benefits, and Contracts Pay at least the Minimum Wage and provide any benefits required by law and/or contract Communicate pay structure and pay periods to all Workers Shall meet all legal requirements relating to wages and benefits, pay accurate wages in a timely manner, and wage deductions shall not be used as a disciplinary measure

5. Non-Discrimination / Non-Harassment / Humane Treatment Commitment to a Harassment-Free Workplace : Ensure a workplace free of harassment and unlawful discrimination. Prohibition of Harsh or Inhumane Treatment : No violence or gender-based violence. No sexual harassment or sexual abuse. No corporal punishment. No mental or physical coercion. No bullying or public shaming. No verbal abuse of workers. No threats of any such treatment.

5. Non-Discrimination / Non-Harassment / Humane Treatment Non-Discrimination and Anti-Harassment Policy : No discrimination or harassment based on: Race or color Age Gender or gender identity/expression Sexual orientation Ethnicity or national origin Disability Pregnancy Religion Political affiliation Union membership Marital status Fair Employment Practices : Equal treatment in hiring and employment practices, including: Wages Promotions Rewards Access to training

Disciplinary policies and procedures in support of these requirements shall be clearly defined and communicated to workers. Workers shall be provided with reasonable accommodation for religious practices and disability. In addition, workers or potential workers should not be subjected to medical tests, including pregnancy or virginity tests, or physical exams that could be used in a discriminatory way. 5. Non-Discrimination / Non-Harassment / Humane Treatment

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6. Freedom of Association and Collective Bargaining Open communication and direct engagement between workers and management are key to resolving workplace and compensation issues effectively. Workers and/or their representatives should be able to communicate openly with management about working conditions and practices without fear of discrimination, reprisal, intimidation, or harassment. Participants should respect the right of all workers to: Form and join trade unions of their own choosing Bargain collectively Engage in peaceful assembly Refrain from such activities if they choose In cases where freedom of association and collective bargaining are restricted by laws or regulations, workers must be allowed to elect and join alternative lawful forms of worker representation.

AM Labor Management System 48 A.M.1 Risk Assessment : Establish a process to monitor and comply with legal and customer requirements. Identify and address operational gaps against these requirements. Maintain records including compliance calendars, summaries of laws and regulations, and minutes from compliance meetings.

A.M Labor Management System 49 A.M.2 Control Process Labor : Define labor responsibilities for all employee levels. Establish and implement effective labor policies and controls aligned with legal requirements and the RBA Code. Provide training for workers and managers on policies and processes. Maintain records of policies, control results, and corrective action plans.

A.M Labor Management System 50 A.M.3 Communications Labor : Establish two-way communication processes with workers and stakeholders to obtain feedback on labor practices. Ensure workers can report grievances anonymously and without fear of reprisal. Maintain records of communication effectiveness and grievance reports.

A.M Labor Management System 51 A.M.4 Performance Review and Continuous Improvement Labor : Conduct regular performance reviews and continuous improvement activities. Assess conformance with legal, customer, and RBA Code requirements through self-assessment processes. Implement corrective actions for non-conformances and maintain records of assessments, corrective actions, and closure verifications.

B. HEALTH AND SAFETY 1. Occupational Health and Safety 2. Emergency Preparedness 3. Occupational Injury and Illness 4. Industrial Hygiene 5. Physically Demanding Work 6. Machine safeguarding 7. Food, Sanitation and Housing BM Health and Safety Management System

Labor Health & Safety &Environment Other Child Labor Forced Labor Bonded Labor Inh u mane t r e a tme n t Please Note: All Zero T Imminent health and safety issues as defined by VAP Imminent e n v i r onme n t al risk as defined by VAP olerance items require a closure audi F als i f y i ng records Bribery t (VAP or 3 rd Party AMA) 8 ZERO Tolerance Items

B1. Occupational Health and Safety 54 Hazard Identification and Assessment : Identify and assess potential worker exposure to health and safety hazards. Hazards include chemical, electrical, other energy sources, fire, vehicles, fall hazards, etc. Mitigation Using Hierarchy of Controls : Apply the Hierarchy of Controls to mitigate identified hazards. Elimination Substitution Engineering controls Administrative controls Personal protective equipment (PPE)

1. Occupational Health and Safety 55 Personal Protective Equipment (PPE) : Provide appropriate, well-maintained PPE when hazards cannot be adequately controlled. Ensure PPE is used effectively. Educational Materials : Provide workers with educational materials about the risks associated with identified hazards. Gender-Responsive Measures : Implement measures to protect pregnant women and nursing mothers from hazardous working conditions. Provide reasonable accommodations for nursing mothers.

2. Emergency Preparedness Potential emergency situations and events must be identified and assessed. To minimize their impact, implement emergency plans and response procedures, including: Emergency reporting Employee notification and evacuation procedures Worker training and drills Conduct emergency drills at least annually or as required by local law, whichever is stricter. Emergency plans should also include: Fire detection and suppression equipment Clear and unobstructed exits Adequate exit facilities Contact information for emergency responders Recovery plans These plans and procedures aim to minimize harm to life, the environment, and property. 56

3. Occupational Injury and Illness Procedures and systems must prevent, manage, track, and report occupational injuries and illnesses. This includes: Encouraging worker reporting Classifying and recording cases Providing necessary medical treatment Investigating incidents and taking corrective actions Facilitating workers' return to work Workers must be allowed to remove themselves from imminent harm without fear of retaliation and should not return until the situation is resolved. 57

4. Industrial Hygiene Worker exposure to chemical, biological, and physical agents must be identified, evaluated, and controlled following the Hierarchy of Controls. When hazards cannot be adequately controlled, provide workers with suitable and well-maintained personal protective equipment at no cost. Ensure safe and healthy working environments through regular monitoring of workers' health and workplaces. Implement ongoing occupational health monitoring to assess potential harm from workplace exposures. Maintain protective occupational health programs that include educational materials on workplace hazards. 58

5. Physically Demanding Work Worker exposure to the hazards of physically demanding tasks, including manual material handling and heavy or repetitive lifting, prolonged standing, and highly repetitive or forceful assembly tasks shall be identified, evaluated, and controlled. 59

6. Machine safeguarding Production and other machinery shall be evaluated for safety hazards. Physical guards, interlocks, and barriers shall be provided and properly maintained where machinery presents an injury hazard to workers. 60

7. Food, Sanitation and Housing Workers must have access to clean toilet facilities, safe drinking water, and hygienic food preparation, storage, and eating areas. Worker dormitories, whether provided by the facility or labor agent, must be clean and safe. They should include: Emergency exits Hot water for bathing Adequate lighting and ventilation Secure storage for personal items Sufficient personal space Reasonable entry and exit access 61

B.M Health and Safety Management System B.M.1 Risk Assessment – Health and Safety Compliance Establishing Health and Safety Compliance Process : Develop a quarterly process to stay updated on all legal and customer requirements. Identify, track, and assess changes in requirements affecting the facility. Address gaps through updated policies, procedures, and training. Maintaining Records : Use a compliance calendar to track deadlines. Summarize applicable laws, regulations, and customer requirements. Review customer requirements impacting operations. Record changes to RBA Code of Conduct and meeting minutes. 62

B.M Health and Safety Management System B.M.1.2 Due Diligence Process Implementing Due Diligence : Focus on identifying and assessing significant health and safety risks. Include risks specific to demographics like gender and age. Assess risks such as life and property harm, chemical spills, workplace violence, etc. Address risks through a Hierarchy of Controls. Update risk assessment for significant changes. Maintaining Records : Document stakeholder identification and risk assessment reports. Keep records of mitigation plans. 63

B.M Health and Safety Management System B.M.2 Control Processes – Health and Safety Compliance Defining Responsibilities and Authorities : Assign a senior representative for social responsibility programs. Record responsibilities and authorities at each organizational level. Establish an Emergency Response Team (ERT). Establishing Health and Safety Policies : Align policies with laws, RBA Code, and facility standards. Implement effective control processes for policy requirements. Allow workers to remove themselves from unsafe situations without retaliation. Accommodate pregnant women and nursing mothers. 64

B.M Health and Safety Management System B.M.2.3 Training Process Implementing Training Program : Develop a comprehensive training program for workers and managers. Include topics on hazards, PPE, emergency procedures, etc. Provide specialized training for specific roles and responsibilities. Maintaining Records : Keep training records with effectiveness verification. Document educational materials and serious conditions. 65

B.M Health and Safety Management System B.M.3 Communications – Health and Safety Compliance Establishing Two-way Communication : Foster ongoing communication with workers and stakeholders. Use various mechanisms like surveys, focus groups, and meetings. Post health and safety information visibly in the facility. Implementing Grievance Reporting : Set up a process for anonymous grievance reporting. Investigate and address grievances promptly. Maintain records of grievances and investigations. 66

B.M Health and Safety Management System B.M.4 Performance Review and Continuous Improvement Establishing Performance Review Process : Conduct regular reviews of health and safety objectives and systems. Set clear goals and indicators, track progress, and communicate with workers. Evaluate control effectiveness, training, and communication. Implementing Self-assessment Process : Periodically assess compliance with legal, customer, and RBA Code requirements. Review assessment findings with senior management and implement corrective actions. Implementing Corrective Action Process : Develop a corrective action process for non-conformances. Include root cause analysis, specific actions, and follow-up reviews. 67

Summa r y From this course, you have learned: RBA Elements Zero Tolerance Items Occupational Safety Emergency Preparedness Occupational Injury and Illness Industrial Hygiene Physically Demanding Work Machine Safeguarding Food, Sanitation and Housing Health and Safety Communication

C. ENVIRONMENT 1. Environmental Permits and Reporting 2. Hazardous Substances 3. Solid Waste 4. Air Emissions 5. Water Management 6. Energy Consumption and Greenhouse Gas Emissions CM Environmental Management System

Labor Health & Safety &Environment Other Child Labor Forced Labor Bonded Labor Inh u mane t r e a tme n t Please Note: All Zero Toleran Imminent health and safety issues as defined by VAP Imminent e n v i r onme n t al risk as defined by VAP ce items require a closure audit (VAP F als i f y i ng records Bribery or 3 rd Party AMA) ZERO Tolerance Items 70

1. Environmental Permits and Reporting All required environmental permits (e.g. discharge monitoring), approvals, and registrations shall be obtained, maintained, and kept current, and their operational and reporting requirements shall be followed.

2. Hazardous Substances Chemicals, waste, and other materials posing a hazard to humans, or the environment shall be identified, labeled, and managed to ensure their safe handling, movement, storage, use, recycling or reuse, and disposal. Hazardous waste data shall be tracked and documented. 72

C2. Documents to Maintain 73 Maintain records of risk assessments and mitigation plans for hazardous substances. Keep inspection records of hazardous substances and waste inventory. Retain copies of hazardous waste shipping papers and vendor certifications. Document investigation reports and annual reduction targets with progress monitoring.

3. Solid Waste 74 Participants shall implement a systematic approach to identify, manage, reduce, and responsibly dispose of or recycle solid waste (non-hazardous). Waste data shall be tracked and documented.

4. Air Emissions Air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone-depleting substances, and combustion byproducts must be identified, regularly monitored, controlled, and treated before discharge. Ozone-depleting substances must be managed according to the Montreal Protocol and relevant regulations. Regularly monitor the performance of air emission control systems. 75

5. Water Management Participants must implement a water management program that: Documents, characterizes, and monitors water sources, use, and discharge Seeks water conservation opportunities Controls contamination channels All wastewater must be characterized, monitored, controlled, and treated before discharge or disposal. Regularly monitor the performance of wastewater treatment and containment systems to ensure optimal performance and compliance with regulations. 76

6. Energy Consumption and Greenhouse Gas Emissions Participants shall establish and report against an absolute corporate-wide greenhouse gas reduction goal. Energy consumption and all Scopes 1, 2, and significant categories of Scope 3 greenhouse gas emissions shall be tracked, documented, and publicly reported. Participants shall look for methods to improve energy efficiency and to minimize their energy consumption and greenhouse gas emissions. 77

C.M Environmental Management System Environmental Compliance Process (C.M.1.1) : Establish a quarterly process to update and maintain compliance with laws, regulations, and customer requirements. Identify applicable requirements, track changes, assess facility operations, and implement necessary policy updates. 78

C.M Environmental Management System Due Diligence Process (C.M.1.2) : Focus on identifying and assessing significant environmental risks related to the facility's operations. Include risks related to greenhouse gas emissions, ozone-depleting substances, chemical exposures, etc. Broad stakeholder inclusion (workers, suppliers, community) and risk controls hierarchy (elimination, substitution, engineering controls, etc.). 79

C.M Environmental Management System Environmental Responsibilities and Authorities (C.M.2.1) : Assign responsibility for implementing environmental programs and compliance. Define roles for hazardous materials, waste, air emissions, etc., at different organizational levels. Environmental Policies and Controls (C.M.2.2) : Establish policies aligned with laws, RBA Code, and facility standards. Implement effective waste management, control processes, and emergency response plans. 80

C.M Environmental Management System Training Processes (C.M.2.3) : Develop comprehensive training programs covering environmental risks, policies, and procedures. Ensure specialized training for workers handling hazardous materials or waste. Communication Processes (C.M.3) : Establish effective two-way communication with workers and stakeholders to gather feedback on environmental practices. Publicly report environmental performance, engage stakeholders, and provide grievance reporting channels. 81

C.M Environmental Management System Performance Review and Continuous Improvement (C.M.4) : Regularly review environmental management performance. Set objectives, assess risks, track progress, and implement corrective actions. 82

Summa r y From this course, you have learned: RBA Elements Benefits to Your Facilities Environmental Permits and Reporting Pollution Prevention and Resource Reduction Hazardous Substances Solid Waste Air Emissions Materials Restrictions Water management Energy Consumption and Greenhouse Gas Emissions

C.M Environmental Management System Environmental Compliance Process (C.M.1.1) : Establish a quarterly process to update and maintain compliance with laws, regulations, and customer requirements. Identify applicable requirements, track changes, assess facility operations, and implement necessary policy updates. 84

C.M Environmental Management System Due Diligence Process (C.M.1.2) : Focus on identifying and assessing significant environmental risks related to the facility's operations. Include risks related to greenhouse gas emissions, ozone-depleting substances, chemical exposures, etc. Broad stakeholder inclusion (workers, suppliers, community) and risk controls hierarchy (elimination, substitution, engineering controls, etc.). 85

C.M Environmental Management System Environmental Responsibilities and Authorities (C.M.2.1) : Assign responsibility for implementing environmental programs and compliance. Define roles for hazardous materials, waste, air emissions, etc., at different organizational levels. Environmental Policies and Controls (C.M.2.2) : Establish policies aligned with laws, RBA Code, and facility standards. Implement effective waste management, control processes, and emergency response plans. 86

C.M Environmental Management System Training Processes (C.M.2.3) : Develop comprehensive training programs covering environmental risks, policies, and procedures. Ensure specialized training for workers handling hazardous materials or waste. Communication Processes (C.M.3) : Establish effective two-way communication with workers and stakeholders to gather feedback on environmental practices. Publicly report environmental performance, engage stakeholders, and provide grievance reporting channels. 87

C.M Environmental Management System Performance Review and Continuous Improvement (C.M.4) : Regularly review environmental management performance. Set objectives, assess risks, track progress, and implement corrective actions. 88

D. ETHICS 1. Business Integrity and No Improper Advantage 2. Disclosure of Information 3. Intellectual Property 4. Fair Business, Advertising and Competition 5. Protection of Identity and Non-Retaliation 6. Privacy DM Ethics Management System

ZERO Tolerance Items Health & Safety Labor Child Labor Forced Labor Bonded Labor Inhu m ane treatment E t h i c s F al s i f ying records Bribery Imminent health and safety issues as defined by VAP Imminent e n vi r o n m e n t al risk as defined by VAP Please Note: All Zero Tolerance items require a closure audit (VAP or 3 rd Party AMA) 7

1. Business Integrity and No Improper Advantage The highest standards of integrity must be upheld in all business interactions. Participants must have a zero-tolerance policy against bribery, corruption, extortion, and embezzlement. No bribes or improper advantages are allowed, whether directly or through a third party, to gain or retain business or any undue advantage. Implement monitoring, record-keeping, and enforcement procedures to ensure compliance with anti-corruption laws.

D1. Business Integrity and No Improper Advantage Controls & Monitoring Monitoring and Investigation: Regularly monitor business to prevent improper conduct. Investigate alleged violations with privacy protection and no retaliation. Implement appropriate sanctions for confirmed violations. Protect workers from retaliation for refusing unethical actions. Senior management reviews assessment and investigation findings regularly.

2. Disclosure of Information All business dealings must be transparent and accurately recorded in the Participant’s business books and records. Disclose information about labor, health and safety, environmental practices, business activities, structure, financial situation, and performance according to regulations and industry standards. Falsifying records or misrepresenting supply chain conditions or practices is unacceptable. 93

3. Intellectual Property Intellectual property rights shall be respected. Transfer of technology and know-how is to be done in a manner that protects intellectual property rights, and customer and supplier information shall be safeguarded. 94

D3. Intellectual Property 95 Controls & Monitoring Monitoring and Oversight: Review intellectual property ownership and uphold IP rights for themselves and their customers.

D4. Fair Business, Advertising and Competition Standards of fair business, advertising, and competition shall be upheld. 96

5. Protection of Identity and Non-Retaliation Programs that ensure the confidentiality, anonymity, and protection of supplier and employee whistleblowers* shall be maintained, unless prohibited by law. Participants shall have a communicated process for their personnel to be able to raise any concerns without fear of retaliation. 97

D5. Protection of Identity and Non-Retaliation 98 Monitoring and Oversight: Conduct investigations in a way that maintains the confidentiality of the reporting source. Manage records securely to prevent breaches of identity protection. Regularly review communications, records, and access controls to ensure compliance with confidentiality policies.

6. Privacy Participants shall commit to protecting the reasonable privacy expectations of personal information of everyone they do business with, including suppliers, customers, consumers, and employees. Participants shall comply with privacy and information security laws and regulatory requirements when personal information is collected, stored, processed, transmitted, and shared. 99

D.M Ethics Management System Risk Assessment - Ethics (D.M.1) Compliance Process: Establish a quarterly update process to stay compliant with laws and customer requirements. Identify applicable requirements using legal expertise and subscriptions to reports. Track and assess operational compliance against identified requirements. Update policies, procedures, and training to address compliance gaps. Maintain a compliance calendar and summaries of applicable laws and requirements. Due Diligence: Conduct due diligence to identify significant ethics risks related to health, safety, and demographics. Assess risks considering business circumstances and key areas like integrity, fair business, and IP protection. Update risk assessments with significant changes. Maintain stakeholder identification and risk assessment reports. 100

D.M Ethics Management System Control Processes - Ethics (D.M.2) Ethics Responsibilities: Assign senior representatives responsibility for implementing social responsibility programs. Define responsibilities and authority levels in position plans and job descriptions. Ensure readiness for normal and emergency situations. Ethics Policies and Controls: Establish policies aligned with law and RBA standards, covering integrity, fair business, IP protection, and non-collusion. Develop mitigation processes for identified risks and maintain transparent business practices. Conduct investigations and impose sanctions for violations. Implement IT measures to protect information and ensure data privacy. Training Process: Implement a comprehensive training program covering ethics, integrity, and compliance. Provide training to all workers regularly with verification of effectiveness. Maintain training records and educational materials. 101

D.M Ethics Management System Communications - Ethics (D.M.3) Two-Way Communication: Establish ongoing communication with workers and stakeholders to obtain feedback on ethical practices. Use various mechanisms like surveys, meetings, and feedback channels. Ensure clear communication channels and encourage feedback. Grievance Reporting: Develop a comprehensive process for anonymous reporting of grievances without fear of reprisal. Investigate grievances promptly and communicate outcomes while ensuring privacy. Maintain records of grievances and investigations. 102

D.M Ethics Management System Performance Review and Continuous Improvement - Ethics (D.M.4) Performance Review Process: Conduct annual reviews of objectives and systems for continual improvement. Set clear goals and targets, evaluate effectiveness, and review risks and compliance. Maintain records of system reviews, progress reports, and corrective actions. Self-Assessment Process: Periodically assess compliance with legal, customer, and RBA Code requirements. Review all areas of the facility, policies, and practices. Maintain records of self-assessment reports and corrective action plans. Corrective Action Process: Implement a corrective action process with root cause analysis and clear actions. Link corrective actions to performance management objectives. Maintain records of non-conformances, corrective actions, and closure verification. 103

E. Supply Chain Management 1. Company Commitment 2. Materials Restrictions 3. Responsible Sourcing of Minerals 4. Supplier Responsibility

1. Company Commitment Participants shall establish human rights, health and safety, environmental and ethics policy statements affirming Participant’s commitment to due diligence and continual improvement, endorsed by executive management. Policy statements shall be made public and communicated to workers in a language they understand via accessible channels.

2. Materials Restrictions Participants shall adhere to all applicable laws, regulations, and customer requirements regarding the prohibition or restriction of specific substances in products and manufacturing, including labeling for recycling and disposal. 106

3. Responsible Sourcing of Minerals Participants shall adopt a policy and exercise due diligence on the source and chain of custody of the tantalum, tin, tungsten, gold, and cobalt in the products they manufacture to reasonably assure that they are sourced in a way consistent with the Organization for Economic Co-operation and Development (OECD) Guidance for Responsible Supply Chains of Minerals from Conflict- Affected and High-Risk Areas or an equivalent and recognized due diligence framework. 107

4. Supplier Responsibility Participants shall establish a process to communicate Code requirements to suppliers and to monitor supplier compliance the Code. 108

QUESTIONS???

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