Fox River Associates’
Supplier Code of Conduct
Fox River Associates is committed to responsible business conduct. Respect for human rights and environmental stewardship are fundamental principles of our ethical business practices and standards. We expect our suppliers to share those principles and uphold our standards. Suppliers must conduct their business with a high level of integrity and maintain transparent and accurate records. We require all vendors, suppliers, third-party sellers, manufacturers, contractors, subcontractors, and their agents (collectively, “suppliers”) to abide by the following standards:
Ethical Business Practices
Responsible sourcing, human rights and environmental due
diligence
All our business partners, including suppliers, distributors, consultants, and independent contractors are expected to adopt and comply with the ethical business standards and values set out in this Supplier Code of Conduct, and to actively communicate such standards when dealing with their own (sub-)suppliers.
Supplier must have ethical and responsible sourcing practices in place and source only from companies that satisfy the requirements of this Supplier Code of Conduct .
Supplier must establish and maintain a due diligence framework to ensure that the supplier has policies and processes in place to identify, prevent, mitigate, and account for adverse impacts in their own operations and related to their own (sub-) suppliers in regard to human rights and environmental risks. The due diligence framework should be governed by the supplier’s senior management, and the approach should be based on the UN Guiding Principles on Business and Human Rights and the OECD Due Diligence Guidance for Responsible Business Conduct. Fox River Associates reserves the right to verify compliance with the supplier’s human rights policy and due diligence framework; to ensure it operates in line with the mentioned principles and guidance documents. Also, suppliers should be aware of all sites and companies involved in their production and supply chain, and upon request should be able to provide Fox River Associates with adequate details of the supply chain for the goods supplied to Fox River Associates.
No Bribery
We seek business partners who adhere to the highest ethical standards in their business practices and their interactions with Fox River Associates. Fox River Associates does not allow any exchange of favors, money, gifts, entertainment, or travel with our team members with the intent to influence business decisions. As with the other standards outlined, Fox River Associates team members are held to the same standards and are prohibited from engaging in solicitation of anything of value from business partners.
Unauthorized Subcontracting
We do not tolerate unauthorized subcontracting. All production locations that fall within the scope of Fox River Associates’ Responsible Sourcing and Sustainability Program must be disclosed to and approved by Fox River Associates before production begins.
Fair competition
Supplier and all persons acting on their behalf should comply with national and supranational antitrust and competition laws. They should not enter directly or indirectly into any illegal agreements with their competitors nor exchange sensitive information, e.g., regarding markets, customers, strategies, prices, and the like. All suppliers and all persons acting on their behalf should participate in public tenders and private sector bidding procedures by strictly following the applicable laws and regulations.
Accurate books and records and tax compliance
Keeping accurate books and records as well as declaring truthfully all required taxes and duties is an indispensable part of running a lawful and transparent business in a sustainable way. Fox River Associates expects its suppliers to act with the highest degree of diligence in this respect.
Data protection
Suppliers should comply with all applicable data protection laws in collecting, processing, storing or otherwise handling personal data of any individuals, including, without limitation, their own employees and employees of their customers, suppliers, and business partners.
Trade restrictions and sanctions
Supplier should ensure its business is conducted in compliance with any applicable trade restrictions and sanctions, as well as rules concerning export controls.
Duty to report and grievance mechanism
Suppliers must report to their Fox River Associates representatives any suspicions of a material breach of any of supplier’s obligation under this Supplier Code of Conduct section including any breach by supplier’s sub-suppliers. External parties such as suppliers’ workforce can report what they believe to be a violation of this Supplier Code of Conduct in an email to info@foxriverassociates.com.
Breach of the supplier code of conduct
If a supplier or any of its own (sub-)suppliers fails to comply with the requirements set forth in this Supplier Code of Conduct, the supplier must take appropriate action to remedy the breach and prevent a recurrence of such breach in the future. Fox River Associates reserves the right to terminate the business relationship with any supplier who materially or persistently breaches this Supplier Code of Conduct.
Social, Community and Labor
No Forced Labor or Human Trafficking
We condemn forced labor and human trafficking and will not knowingly work with suppliers who engage in these practices or the use of incarcerated labor. All workers have the right to engage in work willingly, without surrendering identification and without the payment of fees. Workers have the right to freedom of movement, and our suppliers must ensure it is afforded to them. Workers have the right to terminate their employment without penalty upon providing reasonable notice. Suppliers must also procure their raw materials and/or components for products solely from sources that do not utilize forced labor or engage in human trafficking.
No Underage Labor
We do not tolerate the use of underage labor and will not knowingly work with suppliers that utilize underage workers. We define underage worker as any individual younger than the local minimum working age or the age of 15, whichever older, and/or those not abiding by the international standards as defined by the International Labor Organization (ILO) regarding age-appropriate work governing family farming. Suppliers must comply with all age-related working restrictions as set by local law and adhere to international standards as defined by the ILO regarding age-appropriate work.
Conflicts of interest
Supplier should inform Fox River Associates if any Fox River Associates employee has an interest in the supplier’s business that might cause a conflict of interest. Supplier and persons acting on their behalf must avoid conflicts of interest with respect to their private activities, entities in which they, their close relatives or associates have an interest, their business activities with other parties and their part in the business relationship with Fox River Associates. Supplier should inform Fox River Associates about existing conflicts of interest as soon as they become aware of such conflicts.
Health and Safety
Suppliers must provide a safe and healthy working environment that complies with local laws and minimizes occupational hazards. If suppliers provide residential facilities for their workers, they must be safe and sanitary.
No Discrimination
We respect cultural and individual differences and believe discrimination should not be tolerated. Suppliers are expected to maintain a discrimination-free workplace and to employ legally eligible workers based on their abilities, rather than their race, color, sex, pregnancy status, gender identity, marital status, political opinions, religion, age, disability, sexual orientation, social origin, national origin or any other characteristics unrelated to an individual’s ability to perform the work required by the job.
No Harassment
We believe that all workers should be treated with dignity. Suppliers must not engage in, condone, or tolerate physical, verbal, mental, or sexual harassment against or among their workers.
Working Hours and Overtime
Suppliers must not allow working hours that exceed the applicable legal limit, or 60 hours per week, whichever is less. Regularly paid hours must not exceed 48 per week and overtime hours must not exceed 12 hours per week, or the amount specified by local law, whichever is less. Only in exceptional cases may working hours exceed 60 per week. Overtime work must always be voluntary and paid at a premium rate. Workers must have at least one full non-working day in every seven-day period.
Wages
Suppliers must provide wages and benefits that meet or exceed local law requirements and are paid/provided in a timely manner. We encourage suppliers to commit to the betterment of wages and benefits to improve the lives of workers and their families in the communities where they live.
Freedom of Association
We seek suppliers who productively engage workers and value them as critical assets to sustainable business success. This includes respecting the rights of workers to make an informed decision as to whether to associate or not with any group, the right to collective bargaining consistent with all applicable laws.
Licenses and Permitting
Suppliers must acquire and maintain all legally required environmental permits and business operating licenses necessary to produce their products and operate their facilities. We will not tolerate suppliers operating without valid current permits.
Conflict minerals and human rights
Fox River Associates products must not be linked to armed conflicts or human rights abuses. No raw materials or supplies should originate from any conflict area, and components included in release liners supplied to Fox River Associates should be the subject of a documented responsible supply chain. Relevant information should be provided to Fox River Associates in the form of a completed CMRT document. Included components may not contain the minerals defined as conflict minerals (tantalum, tin, tungsten, and gold) or their derivatives unless they are sourced through recognized and responsible certification schemes.
Community relations and impact on local communities
Fox River Associates encourages suppliers to be a positive influence within and act with respect for the communities in which they operate. Fox River Associates values suppliers who provide their employees with a thriving workplace environment and development opportunities. Fox River Associates values relationships with a broad spectrum of suppliers and work towards providing the maximum attainable opportunity for small and diverse businesses in the performance of all vendors. Therefore, Fox River Associates seeks to extend and develop its Supplier Diversity program, and values suppliers who utilize ethnic- or gender-neutral means to allow opportunities for small and diverse businesses to participate in subcontracts, where participation opportunities are present.
Environmental Sustainability
The following apply to all facilities that process or produce raw materials, component parts or finished goods:
Environmental Management and Monitoring Systems
Suppliers must have environmental monitoring systems that accurately measure and track operational and production impacts to air, water and any other environmental system deemed necessary.
Water Stewardship
Suppliers must identify, characterize, and inventory all wastewater streams on an ongoing basis. In addition, suppliers must install and maintain appropriately sized wastewater treatment systems to ensure pollutants are at or below legally required levels. We will not tolerate suppliers with undersized, bypassed, or inoperable wastewater treatment systems.
Waste Reduction and Disposal
Suppliers must handle, store, transport and dispose of hazardous waste legally. We will not tolerate suppliers that engage in illegal waste dumping. We seek suppliers who demonstrate they actively work to reduce waste throughout the production process.
Energy Management
With respect to both production facilities and processes, suppliers must identify all applicable energy sources and energy consumption. We encourage Suppliers to periodically set clear goals to improve energy efficiency and document progress made toward achieving those goals.
Air Emissions
With respect to both production facilities and processes, suppliers must monitor and document all air emissions in accordance with the applicable regulatory requirements. In addition, suppliers must install and maintain appropriate air emissions control devices to ensure air emissions’ pollutants are at or below legally required levels.