SLWM Supplier Code of Conduct
SLWM is committed to conducting its business in an ethical, legal and socially responsible manner. This commitment extends to its partners with whom SLWM chooses to do business (each individually, a “Supplier”, and collectively “Suppliers”). SLWM expects the same high level of honesty and integrity of its Suppliers that it expects of its employees. This Supplier Code of Conduct (“Supplier Code”) represents SLWM’s fundamental expectations of Suppliers with respect to the safety of working conditions in the SLWM supply chain, that workers are treated with respect and dignity, and that manufacturing processes are environmentally and socially responsible. SLWM is also committed to ensuring the security of its information together with the information that it holds on behalf of its customers. To this end we expect Suppliers to be able to prove that they have appropriate security controls in place which are tested on a regular basis.
This Supplier Code applies to all SLWM Suppliers. As brand stewards, we are responsible for protecting and upholding our customers’ reputation. The principles within the Supplier Code speak to the commitments we make to our customers, our commitment to compliance with the law, and our relationships built on trust and corporate responsibility.
By working together, we will ensure that our actions benefit both our companies, our customers and our communities.
Suppliers are responsible for compliance with the standards set forth in this Supplier Code and shall comply with all applicable laws, regulations, directives and other governing standards applicable to their specific industry. It is the responsibility of the Suppliers to inform their employees of this Supplier Code and ensure that everyone adheres to its obligations. Suppliers are expected to be familiar with the practices of all their agents, sub-suppliers, sub-contractors, manufacturers and facility operators to ensure that these third-parties also adhere to and operate within the guidelines of this Supplier Code, or an equally rigorous policy statement. If there is a conflict between existing local laws and this Supplier Code, the provisions of the local law shall take precedence. Where local industry standards are higher than applicable legal requirements, Suppliers shall adhere to the higher standards.
Labor and Human Rights
Suppliers will not use forced or involuntary labor of any type (e.g., bonded, indentured or involuntary prison labor). Suppliers will ensure that hiring practices are in conformance with International Labor Organization (ILO) Conventions for minimum age (Convention 138), child labor (Convention 182) and modern slavery. Suppliers are encouraged to develop lawful workplace apprenticeship programs for the educational benefit of their workers, provided that all participants meet the minimum age requirements.
Child labor is not allowed in any form.
Suppliers are to provide a workplace free from harsh and inhumane treatment, sexual harassment, abuse, mental or physical coercion, verbal abuse, or the threat of any such treatment. It is expected that Suppliers document disciplinary procedures and grievances.
Freedom of Association
SLWM encourages open and inclusive dialogue with their employees and their representatives. Employees should be free to join labor unions, seek representation, join works councils, and engage in collective bargaining.
Freely Chosen Employment
Suppliers will not use forced or involuntary labor of any type (e.g., bonded, indentured or involuntary prison labor).
Modern slavery is a heinous crime that affects communities and individuals across the globe. Suppliers must ensure that their supply chain is transparent about the process through which it manages its employees.
Suppliers are to provide workers with safe and hygienic working conditions. Access to clean toilet facilities, drinking water, and sanitary food storage facilities must be provided.
Wages and Working Hours
Suppliers shall, at a minimum, comply with all applicable wage and hour laws and regulations as well as the Modern Slavery Act of 2015, including those relating to minimum wages, overtime hours, piece rates and other elements of compensation, and provide legally mandated benefits. Workers should not be required to work more than 60 hours per week, including overtime, except in extraordinary business circumstances with their consent. Employees should be allowed at least one day off during a seven-day week.
Wages and benefits must meet national legal standards, as a minimum. Wages should be enough to meet basic needs and provide some discretionary income. Employees should receive all statutory benefits mandated by law, including, but not limited to, pension benefits, annual leave, and holidays.
Regular employment must be provided, working hours must not be excessive and overtime should be voluntary and not excessive. Employees should be provided with advance notice if overtime hours may be necessary.
Health and Safety
Suppliers will provide their employees with a safe and healthy workplace in compliance with all applicable laws, regulations and sound industry practice. Caution should be taken to minimize the risk of accident and injury. Employees should receive regular health and safety training, and accidents should be recorded. Consistent with these obligations, SLWM Suppliers must have and implement effective programs that encompass life safety, incident investigation, chemical safety, ergonomics, and other relevant protective elements.
Respect and Dignity
Employees will be treated with respect and will not be subjected to corporal punishment, threats of violence or other forms of physical coercion or harassment. There should be a policy that prohibits inappropriate conduct and a process for employees to report such conduct for investigation and resolution.
Suppliers must not engage in harassing or physically or verbally abusive discipline, act in a threatening way towards employees or submit employees to demeaning conditions.
Indigenous and Rural Communities
Suppliers must respect indigenous and rural communities’ legal, customary or user rights to
their territories, land and resources.
Suppliers will not discriminate in its hiring and employment practices on grounds of race, religion, age, nationality, social or ethnic origin, sexual orientation, gender, gender identity or expression, marital status, pregnancy, political affiliation, or disability, subject to local law.
Diversity, Inclusion and Gender Equality
Suppliers must not discriminate when recruiting, compensating, training, promoting, or terminating based on race, national or social origin, gender, age, physical characteristics, disability, union membership, religion, family status, pregnancy, sexual orientation, gender identity, gender expression, or any unlawful criterion. An inclusive and supportive workplace should be promoted, equal treatment exercised and diversity encouraged. Where applicable, gender pay gap reporting legislation must be observed. Plans to provide equal opportunities to employees irrespective of their gender must be developed.
Suppliers will comply with all applicable laws and regulations in all locations where they conduct business, especially with respect to strict compliance with all laws and regulations on bribery, corruption and prohibited business practices. SLWM expects Suppliers to conduct their business in accordance with the highest ethical standards.
Suppliers must not practice or tolerate any form of fraud, corruption, extortion, embezzlement, or money laundering. Suppliers must not accept or offer bribes or any unlawful incentives from/to business partners and/or public officials.
Conflicts of Interest
A conflict of interest is where personal interests compete, or appear to compete, with the ability to perform or exercise impartial judgement. Suppliers are to make decisions free of any conflict of interest.
Suppliers should conduct business in compliance with fair competition and applicable anti-trust laws.
Hospitality and Gifts
Suppliers should not accept or offer gifts. Local laws should be followed when offering or accepting gifts, as gifts given inappropriately may violate such laws. Hospitality and gifts must be legal, transparent, and documented and be within policy limits for both the giver and receiver. Hospitality and gifts may not consist of cash or a cash equivalent
Suppliers shall ensure that it has appropriate information security protection measures to manage the risks to the information provided by SLWM and the deliverables produced. As a minimum, information security protection should be included in the following areas: Information Security Management, Contingency Planning, Business Continuity and Disaster Recovery, Operations Security, Personnel Security, Communications Security and Physical Security together with evidence of regular testing.
Suppliers must ensure that all employee, customer, and business partners’ data privacy rights are respected.
Suppliers must have appropriate controls in place to manage the risks to SLWM’s confidential information and information entrusted to SLWM by its clients. In respect of Suppliers who will receive and process personal data, sensitive or highly sensitive data, SLWM will (at its discretion) require the Supplier to have an information security policy that is compliant with or equivalent to ISO 27000 series or SOC 2 Type 2.
Suppliers must safeguard and use confidential information appropriately and in compliance with all applicable legislation and regulation, ensuring that intellectual property rights are respected.
Vulnerability Scans and Penetration Tests
Suppliers will conduct regular penetration tests and vulnerability assessments to ensure continued compliance with this code and acknowledges that SLWM and/or a customer may require access to the Supplier’s systems or premises to audit such compliance.
Disaster Recovery Planning
Suppliers must have a disaster recovery plan which is documented, reviewed and regularly tested.
Suppliers will operate in a manner that protects the environment. Suppliers must comply with all applicable environmental laws, regulations and industry practices. Suppliers will comply with requirements regarding chemical and waste management and disposal, recycling, industrial waste-water treatment and discharge, air emissions controls, environmental permits and environmental reporting. Suppliers must also comply with any additional environmental requirements in SLWM’s product design and specifications, and contractual obligations. Suppliers must seek to reduce their environmental impacts and develop climate change adaptation and mitigation plans.
Suppliers should have a complete and effective Environmental Management System (EMS) including written policies, processes, and requirements for environmental protection and pollution prevention/ source reduction, that is in accordance with laws, regulations, and industry standards.
Natural Resource Conservation
Suppliers should conserve natural resources in their operations and sourcing practices.
Reuse and Recycling
Suppliers should re-use and recycle materials where possible. Products and packaging should be designed to simplify re-use and recycling.
All waste should be managed in compliance with local laws. Proper handling, movement, storge, recycling and re-use of all waste should always be observed.
Suppliers should have programs for the efficient use and conservation of energy
Suppliers should have programs for the efficient use and conservation of water
Suppliers must comply with local laws relating to water emissions and waste
Suppliers should seek to minimize the environmental impacts arising from transportation and logistics
Suppliers should engage in practices that promote biodiversity
Conservation and Protection
Suppliers should obtain materials from certified sources, and/or use sustainable alternatives. Suppliers must never source products from ancient, endangered or illegal sources
Suppliers are expected to implement sustainable sourcing practices within their own organization.
Any sub-contractors, sub-suppliers or third parties working with the Supplier need to be aware of and compliant with this Code of Conduct, to ensure that the SLWM standards are upheld throughout the supply chain.
Last Updated: November 28, 2022