CODE OF CONDUCT FOR BUSINESSES AND ORGANISATIONS
BACKGROUND AND INTRODUCTION
This Code is an essential part of our decision making process. It helps us make sure that our ethics and values are shared by those we choose to work with, including our suppliers, partners, and sub-grantees, so that collectively we avoid doing things that may cause damage to our company, our planet, or the people that are part of our global community.
We also ask that our suppliers, partners, and sub-grantees (collectively referred to in this document as ‘organisations’) work to ensure their own supply chain adheres to these principles as well. We do however recognise that not all these standards are relevant to every organisation and only expect those that are applicable to be adhered to. Where compliance is not yet achieved, we expect this to be a work in progress backed by genuine commitment.
We hold ourselves to these standards when carrying out our business activities and operations; as a responsible organisation, we aim to be an example to others.
When there is a difference between a local law and our Code of Conduct, the law must always be upheld however we seek to apply the higher standard.
Questions about this document, or reports about any violation or grievance, can be submitted to Syli by contacting us.
Retaliation of any kind against those reporting a good faith concern about improper conduct will not be tolerated.
ENVIRONMENT
Commitment: have an environmental policy that includes actively reducing emissions and other adverse effects from operations on community, environment, and natural resources, whilst safeguarding health and safety.
1. ENVIRONMENTAL PERMITS AND REPORTING
All required environmental permits, approvals, and registrations will be obtained, maintained, and kept current and their operational and reporting requirements will be followed.
2. POLLUTION PREVENTION AND RESOURCE REDUCTION
Emissions and discharges of pollutants and generation of waste are to be minimised or eliminated.
The use of natural resources, including water, fossil fuels, minerals, and virgin forest products, is to be conserved by practices such as modifying activities, changing maintenance and facility processes, materials substitution, re-use, conservation, recycling, or other means.
3. ENERGY CONSUMPTION AND GREENHOUSE GAS EMISSIONS
An organisation-wide greenhouse gas reduction goal ensuring energy consumption and all greenhouse gas emissions are tracked, documented, and reported against the greenhouse gas reduction goal.
4. HAZARDOUS SUBSTANCES
Chemicals, waste, and other materials posing a hazard to humans or the environment are to be identified, labelled, and managed in accordance with applicable laws and standards to ensure their safe handling, movement, storage, use, recycling or reuse and disposal.
5. SOLID WASTE
Implement a systematic approach to identify, manage, reduce, and responsibly dispose of or recycle solid waste (non-hazardous).
6. AIR EMISSIONS
Air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting substances, and combustion byproducts generated from operations are to be identified, monitored, controlled, and treated as required prior to discharge.
Ozone depleting substances are to be effectively managed in accordance with the Montreal Protocol and applicable regulations.
7. MATERIALS RESTRICTIONS
Adhere to all applicable laws and regulations and customer requirements regarding prohibition or restrictions of specific substances in products and manufacturing, including labelling for recycling and disposal.
8. WATER MANAGEMENT
Implement a water management programme that documents, characterises, and monitors water sources, use and discharge; seeks opportunities to conserve water; and controls channels of contamination prior to discharge or disposal.
9. RECYCLING
Identify and implement organisation-wide strategies to increase recycling including during manufacturing, through purchasing, at equipment end of life, and at the post-consumer stage.
10. PREMISES
Actively seek to improve the environmental profile of premises to reduce any negative impact on the environment.
11. TRANSPORT
Reduce the environmental impact of transport activities through strategic planning of purchasing and vehicle use, adoption of clearer alternative fuels, and promotion of environmentally friendly transport alternatives to the workforce.
ETHICS
Commitment: conduct business in accordance with applicable laws and regulations and with a commitment to attaining the highest standards of ethical behaviour.
1. INTEGRITY
Do not take unfair advantage of other organisations, through abuse of privileged or proprietary information, misrepresentation of material facts, or any other unfair or dishonest practices.
Do not engage in collusive bidding, price fixing, price discrimination or other unfair trade practices in violation of antitrust laws.
2. BRIBERY, KICKBACKS AND FRAUD
Maintain the highest standards of integrity including a zero-tolerance policy that strictly prohibits any and all forms of bribery, corruption, extortion and embezzlement.
No funds or assets of the organisation shall be paid, loaned or otherwise disbursed as bribes, “kickbacks”, or other payments designed to influence or compromise proper conduct.
3. CHARITABLE CONTRIBUTIONS
Choice of organisation is not influenced by an organisation giving, or not giving, to any particular charity.
4. OTHER CONFLICTS OF INTEREST
Where a director, employee, agent, or other representative of one party identifies that an individual they have a family or close relationship with is a director, employee, agent, or representative of the other party, this information will be disclosed at the earliest opportunity and any actual or perceived conflict of interest will be addressed.
5. DISCLOSURE OF INFORMATION
All organisation dealings should be transparently performed and accurately reflected in the organisation’s books and records. Information regarding workforce, health and safety, environmental practices, activities, structure, financial situation, and performance is to be disclosed in accordance with applicable regulations and prevailing industry practices.
6. INTELLECTUAL PROPERTY
Intellectual property rights are to be respected; transfer of technology and know-how is to be done in a manner that protects intellectual property rights.
8. PRIVACY
Commit to meeting legal requirements for protecting personal information and meet the reasonable privacy expectations of individuals. This includes, but is not limited to, suppliers, customers, consumers, and workforce.
9. INFORMATION SECURITY
Comply with information security laws and regulations and take all necessary steps to ensure data security.
10. PROTECTION OF IDENTITY AND NON-RETALIATION PROGRAMS
Have in place programmes that ensure the confidentiality, anonymity and protection of suppliers and employee whistleblowers is maintained, unless prohibited by law.
11. RESPONSIBLE MINERALS SOURCING
Adopt a policy and exercise due diligence to ensure minerals in the supply chain originating from conflict-affected and high-risk areas (CAHRAs) do not directly or indirectly finance or benefit armed violence or contribute to human rights abuses.
WORKFORCE RIGHTS AND PRACTICES
Commitment: ensure workforce rights are upheld and protected and that workplace practices are ethical.
Our Code of Conduct for Businesses and Organisations adheres to the key principles of the International Labour Organization’s (ILO) ten fundamental conventions:
Freedom of Association and Protection of the Right to Organise Convention
Right to Organise and Collective Bargaining Convention
Forced Labour Convention
Abolition of Forced Labour Convention
Minimum Age Convention
Worst Forms of Child Labour Convention
Equal Remuneration Convention
Discrimination (Employment and Occupation)
Occupational Safety and Health Convention
Promotional Framework for Occupational Safety and Health Convention
In accordance with the ILO fundamental conventions, commit to uphold human rights of all workers and treat them with dignity and respect. Respect the rights of vulnerable groups particularly relevant to their industry, including, for example, women and migrants.
1. FREELY CHOSEN EMPLOYMENT
Do not use forced, bonded, or indentured labour, involuntary or exploitative prison labour, slavery, or trafficking of persons.
Identification and immigration documents will not be unlawfully withheld, destroyed, concealed, confiscated or denied.
Workers will not be required to pay employers’ or agents’ recruitment fees or other related fees.
2. YOUNG WORKERS
Child: any person under the age of 15, or under the age for completing compulsory education, or under the minimum age for employment in the country, whichever is greatest.
Young Worker: any person under the age of 18 who does not meet the definition of ‘child’.
Do not use child labour and actively verify the age of young workers to ensure they are above the minimum age of employment.
Workers under 18 will not perform work that is likely to jeopardise their health and safety, including night shifts and overtime.
Ensure proper management, support, and training of young workers and protection of their rights in accordance with applicable laws and regulations.
3. WORKING HOURS
A standard work week (one without overtime) must not exceed 48 hours. All overtime must be voluntary meaning workers must be given a choice about whether to undertake overtime.
Working hours will include the minimum breaks and rest periods set by law. Workers will be allowed at least one day off every seven days.
4. WORKING AND LIVING CONDITIONS
Working, and living (if applicable), conditions must meet, at a minimum, standards set by local law and workers must not face any undue health or safety risks from working or living conditions.
5. HUMANE TREATMENT
Donot subject to – or threaten – workers with inhumane treatment, including violence, gender-based violence, sexual harassment, sexual abuse, corporal punishment, mental or physical coercion, bullying, public shaming, or verbal abuse; nor is there to be the threat of such treatment.
Clearly define and communicate disciplinary policies and procedures in support of these requirements to the workforce.
6. WAGES AND BENEFITS
Compensation paid to workers will comply with all applicable wage laws and regulations, including those relating to minimum wages, overtime hours and legally mandated benefits and workers will be compensated for overtime at pay rates greater than regular hourly rates.
Deductions from wages as a disciplinary measure are not permitted.
Workers will be provided with a timely and understandable wage statement that includes sufficient information to verify accurate compensation for work performed and workers will be informed of all deductions from their pay.
All workers will be paid equally for work of equal value, regardless of gender or any other characteristic.
Ensure workers earn enough to meet their basic needs by providing a living wage.
7. NON-DISCRIMINATION
Commit to a workforce free of harassment and discrimination and do not engage in or permit discrimination or harassment based on race, colour, age, gender, sexual orientation, gender identity and expression, ethnicity, national origin, disability, pregnancy, religion, political affiliation, union membership, covered veteran status, protected genetic information, or marital status.
Workers or potential workers will not be subjected to medical tests or physical exams that could be used in a discriminatory way.
8. FREEDOM OF ASSOCIATION
Respect the right of workers to form and join trade unions of their own choosing, to bargain collectively, to engage in peaceful assembly, and to choose to refrain from such activities.
Ensure workers can pursue alternative forms of organising (e.g., worker councils or worker-management dialogues) where there are regulatory constraints on freedom of association.
Workers and/or their representative will be 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.
HEALTH AND SAFETY AND EMERGENCY PREPAREDNESS
Commitment: minimise injury and illness to achieve a safe and healthy work environment and workers will be encouraged to raise any health and safety concerns without being disciplined or subject to any form of retaliation.
1. OCCUPATIONAL SAFETY
Worker exposure to potential safety hazards is to be identified, assessed, and mitigated.
Reasonable steps will be taken to remove or reduce workplace health and safety risks to pregnant women and nursing mothers, and including reasonable accommodations for nursing mothers.
2. EMERGENCY PREPAREDNESS
Potential emergency situations and events are to be identified and assessed, and their impact minimised by implementing emergency plans and response procedures.
Emergency plans should include appropriate fire detection and suppression equipment, a sufficient number of clear and unobstructed exit routes, contact information for emergency responders, and recovery plans that consider the wider impact of the event on the community and the environment.
3. OCCUPATIONAL INJURY AND ILLNESS
Put in place procedures and systems to prevent, manage, track and report occupational injury and illness. This includes provisions to: encourage worker reporting, classify and record injury and illness cases, provide necessary medical treatment, investigate cases and implement corrective actions to eliminate their causes, and facilitate return of workers to work.
4. INDUSTRIAL HYGIENE
Identify, evaluate, and control worker exposure to chemical, biological, and physical agents. Potential hazards are to be eliminated, controlled, or reduced.
When hazards cannot be adequately controlled, workers are to be provided with and use appropriate, well-maintained, personal protective equipment free of charge.
5. PHYSICALLY DEMANDING WORK
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
6. MACHINE SAFETY
Production and other machinery will be evaluated for safety hazards and organisations will provide and properly maintain physical guards, interlocks, and barriers for hazards in machinery used by workers.
7. SANITATION, FOOD, AND HOUSING
Workers are to be provided with ready access to clean toilet facilities, potable water, and sanitary food preparation, storage, and eating facilities.
Worker accommodation will be clean and safe, providing workers with hot water for bathing and showering, adequate lighting, heat and ventilation, individually secured accommodations for storing personal and valuable items, and reasonable personal space along with reasonable entry and exit privileges.
8. HEALTH AND SAFETY TRAINING AND COMMUNICATION
Provide workers with appropriate and accessible workplace health and safety information and training, both at the beginning of work and regularly thereafter, for all identified workplace hazards that workers are exposed to.
Health and safety related information will be clearly posted in the facility or placed in a location identifiable and accessible by workers.
HOW WE WILL IMPLEMENT OUR CODE OF CONDUCT DURING THE PROCUREMENT PROCESS – INCLUDING MEASURING COMPLIANCE AND IMPLEMENTATION.
We have created Code of Conduct questionnaires and a Due Diligence questionnaire to use alongside this document to help us make decisions about which organisations to work with. In some instances we may ask the organisation to complete the questionnaire, or we may undertake this on their behalf using information obtained from public sources and from the organisation directly.
The information we gather through our Due Diligence and Code of Conduct questionnaire will be used alongside other information we need to make an informed decision about who to work with. Our Procurement and Purchasing Policy and Manual provide more detail on this.
Not all elements of this Code of Conduct are relevant to Syl or to the organisations we may work with. We don’t expect all organisations to have achieved full compliance across all areas – we recognise that environmental targets in particular are a work in progress for many at this time.
We do however expect 100% legal compliance in all activities and an active commitment to be working towards compliance across all other areas with ideally at least 50% compliance either already achieved or in progress for all relevant categories.