Supplier Workplace Code of Conduct

The BBP’s Supplier Workplace Code of Conduct defines standards for fair, safe and healthy working conditions as well as environmental responsibility throughout our supply chain. This code standards are based on the International Labor Organization (ILO) standards and on internationally accepted good labor practices. 

Requirements in this code apply to the whole supply chain, including sub-suppliers, sub-contractors and farms. BBP requires any supplier that does not meet any of the standards of this code to correct this by improving its practices to ensure ongoing compliance with this code. 

  

  • COMPLIANCE WITH LAWS AND PUBLISHED STANDARDS  

BBP suppliers must comply with (1) all applicable laws, codes or regulations of the countries, states and localities in which they operate. This includes, but is not limited to, (2) our Supplier Workplace Code of Conduct, including working hours, freely chosen employment, compensation, child labor, freedom of association, non-discrimination, and health and safety. 

In addition, BBP suppliers must require their suppliers (including temporary labor agencies) to do the same.  

  • CHILD LABOR  

No person shall be employed under the age of 15 or under the age for completion of compulsory education, whichever is higher. (ILO Convention 138 and 182) 

  • FORCED LABOR 

There shall be no use of forced labor, including prison, indentured, bonded, slave or other forms of forced labor. Acts of human trafficking are also prohibited. Suppliers are required to monitor any third-party entity which assists them in recruiting or hiring employees, to ensure that people seeking employment at their facility are not compelled to work through force, deception, intimidation, coercion or as a punishment for holding or expressing political views. (ILO Conventions 29, 105, 182) 

  • HARASSMENT, ABUSE AND DISCIPLINARY PRACTICES 

 Every employee shall be treated with respect and dignity. No employee shall be subject to any physical, sexual, psychological or verbal harassment or abuse or to monetary fines or embarrassing acts as a disciplinary measure. 
 

  • DISCRIMINATION 

 No person shall be subject to any discrimination in any aspect of the employment, relationship including recruitment, hiring, compensation, benefits, work assignments, access to training, advancement, discipline, termination or retirement, on the basis of race, religious belief, color, gender, pregnancy, childbirth or related medical conditions, age, national origin, ancestry, sexual orientation, gender identification, physical or mental disability, medical condition, illness, genetic characteristics, family care, marital status, caste, socio-economic situation, political opinion, union affiliation, ethnic group, illness any other classification protected under applicable law. 
All employment decisions must be made based on the principle of equal employment opportunity, and shall include effective mechanisms to protect migrant, temporary or seasonal workers against any form of discrimination. (ILO Conventions 100 and 111)  

 

  • FREEDOM OF ASSOCIATION AND COLLECTIVE BARGAINING 

Workers must be free to join organizations of their own choice. Suppliers shall recognize and respect the right of employees to freedom of association and collective bargaining. All suppliers must develop and fully implement effective grievance mechanisms which resolve internal industrial disputes, employee complaints, and ensure effective, respectful and transparent communication between employees, their representatives and management. (ILO Conventions 87, 98 and 135)
 

  • EMPLOYMENT RELATIONSHIP 

Employers shall adopt and adhere to rules and conditions of employment that respect workers and, at a minimum, safeguard their rights under national and international labor and social security laws and regulations.  

 

  • WAGES AND BENEFITS 

Every worker has a right to compensation for a regular work week that is sufficient to meet the worker’s and their family’s basic needs and provide some discretionary income. Employers shall pay wages which equal or exceed minimum wage or the appropriate prevailing wage, whichever is higher, comply with all legal requirements on wages, and provide any fringe benefits required by law and/or contract. Where compensation does not meet workers’ basic needs and provide some discretionary income, BBP should not work with those companies until they realize a level of compensation that does. (ILO Conventions 26 and 131) 
 

  • HOURS OF WORK 

Suppliers shall not require workers to work more than the regular and overtime hours allowed by the law of the country where the workers are employed. Employers shall allow workers at least 24 consecutive hours of rest in every seven-day period. Employers shall not request overtime hours on a regular basis. The sum of regular and overtime hours in a week shall not exceed 60 hours or the maximum allowed by the law of the county of manufacture, whichever is less. (ILO Convention 1) 

 

  • HEALTH AND SAFETY 

 

BBP suppliers shall provide their employees with a safe and healthy working environment in order to prevent accidents and injury to health arising out of, linked with, or occurring in the course of work or as a result of the operation of the supplier. Suppliers shall, among other things, provide:  

  • Occupational health and safety training
     
  • A system for injury and illness reporting
     
  •  Worker exposure to physically demanding tasks, including manual material handling and heavy lifting, prolonged standing and highly repetitive or forceful assembly tasks is to be identified, evaluated and controlled. 
     
  • Medical treatment and/or compensation to injured/ill workers arising as a result of working for supplier.  
  • Worker exposure to chemical, biological and physical agents is to be identified, evaluated, and controlled. When hazards cannot be adequately controlled by engineering and administrative means, workers are to be provided with appropriate personal protective equipment. 
     
  • Machine safeguarding and other protective measures to prevent injuries/illnesses to workers.
     
  • Workers are to be provided clean and safe facilities including clean toilet facilities, access to potable water and sanitary food preparation and storage facilities.  

 

  • ENVIRONMENT 

 

BBP suppliers shall comply with all environmental laws and regulations applicable to their operations worldwide. Such compliance shall include, among other things, the following items:  

  • The facility shall have in place written policies, procedures, training and appointed people to ensure compliance with all legally required environmental regulations.
     
  • The facility shall comply with all applicable laws, regulations and maintain valid permits governing the facilities’ energy consumption and greenhouse gas emissions. 
     
  • The facility shall comply with all applicable laws, regulations and procedures related to water use including maintaining all required permits
     
  • The facility shall comply with all applicable laws, regulations and procedures governing air emissions including: possessing all current records and permits
     
  • Solid waste produced by the facility shall be handled and stored, in a manner which complies with all applicable laws and regulations. Solid waste produced by the facility shall not be disposed of in a manner which violates applicable laws and regulations.
     
  • The facility shall have on-file all valid, up-to-date, and applicable permits, records and other documentation governing hazardous waste including: storage, handling, onsite disposal, offsite disposal, transportation, and waste contractors
     
  • Facilities shall not dispose of hazardous waste in any way that violates applicable laws, regulations and procedures including: onsite disposal, offsite disposal, chemical drum disposal, transportation, or mixing of hazardous and non-hazardous waste.
     
  • The facility maintains applicable permits and has an understanding and awareness of nuisance levels from onsite activities and their associated impacts.
     
  • The facility shows continuous improvement on environmental audit findings and displays a genuine effort to progress to higher levels of environmental management.
     
  • The facility shall have a major incident management system in place which includes having an emergency plan that complies with all applicable laws. Employees must be sufficiently trained on the emergency procedures and functioning equipment readily available at all times.
     
  • The facility is not causing or knowingly permitting contamination of soil and groundwater.
     
  • Suppliers shall not have a negative impact on designated protection areas or species
     

 

  • SUBCONTRACTING 

 

BBP does not permit subcontracting without our prior written approval. All salesman-sample and bulk production orders must be placed within facilities that have been pre-approved by BBP, without exception. Direct suppliers are required to continuously monitor approved subcontractors and sub-suppliers for social and environmental responsibility using standards that meet or exceed our Code. 

 

  • ETHICAL BUSINESS PRACTICES  

 

Suppliers shall conduct their businesses in accordance with the highest standards of ethical behavior and in accordance with applicable laws and regulations. Suppliers are expected to conform to these requirements in each of the following areas:  

  • Fair Trade Practices: Suppliers shall not engage in collusive bidding, price fixing, price discrimination or other unfair trade practices in violation of antitrust laws. 
     
  • Bribery, Kickbacks and Fraud: No funds or assets of the supplier shall be paid, loaned or otherwise disbursed as bribes, « kickbacks », or other payments designed to influence or compromise the conduct of BBP, its employees or representatives. 
     
  • Foreign Corrupt Practices Act:  While laws and customs vary throughout the world, suppliers must comply with foreign legal requirements and European laws that apply to foreign operations.   

 

  • INTELLECTUAL PROPERTY RIGHTS  


    Suppliers shall respect the intellectual property rights of others, including BBP, its affiliates and business partners. Suppliers must take appropriate steps to safeguard and maintain confidential and proprietary information of BBP and shall use such information only for the purposes specified for use by BBP. Suppliers shall observe and respect all BBP patents, trademarks and copyrights and comply with all requirements as to their use as established by BBP. Suppliers shall not transmit confidential or proprietary information of BBP via the internet unless such information is encrypted accordance with minimum standards established by BBP 

     

     

     

    • MONITORING AND COMPLIANCE  

    Suppliers shall conduct audits and inspections to ensure their compliance with this Supplier Code of Conduct and applicable legal requirements. If a supplier identifies areas of noncompliance, the supplier agrees to notify the relevant BBP Purchasing Manager as to its plans to remedy any such non-compliance.  

    BBP or its representatives may engage in monitoring activities to confirm Supplier’s compliance to this Supplier Code of Conduct, including on-site inspections of facilities, use of questionnaires, review of publicly available information, or other measures necessary to assess supplier’s performance. Any BBP supplier or BBP employee that becomes aware of violations of this policy is obligated to notify BBP’s Supply Chain management. Based on the assessment of information made available to BBPBBP reserves the right (in addition to all other legal and contractual rights) to disqualify any potential supplier or terminate any relationship with any current supplier found to be in violation of the supplier Code of Conduct without liability to BBP. 

      

    • APPLICATION/EXCLUSIONS  

    This Supplier Code of Conduct is a general statement of BBP’s expectations with respect to suppliers. This Policy should not be read in lieu of but in addition to any supplier obligations as set forth in any (i) request for proposal or other solicitation, or (ii) agreements by and between BBP and the Supplier. 

    In the event of a conflict between this Policy and any BBP solicitation document or applicable agreement, the terms of the solicitation document or applicable agreement shall control. 
    No exclusions are applicable to this policy.  

    IN WITNESS WHEREOF, the undersigned have caused this Supplier Code of Conduct to be executed by their authorized officers as of the date and year first written above.  

    SUPPLIER  

    By:  

    Name:  

    Title:  

    Date