Brookwood Companies

Brookwood
Supplier
Code of Conduct

At Brookwood, we strive to create a corporate culture with ethics and conscience. As part of our ethical commitment, we spearhead a number of charitable activities, work to benefit the environment through our own Emerald Initiative™, and have each of our employees annually review and execute Brookwood’s Working Together Guide and Business Conduct Policy. By helping on all sides we benefit the industry, the people around us, and our planet.

In upholding these values, Brookwood is committed to working with reputable business partners who also demonstrate a strong dedication to ethical business standards and practices. To help fulfill this commitment, the Brookwood Supplier Code of Conduct (hereby referred to as the “Code of Conduct”) was created and applies to any company, its factories, manufacturers, vendors or agents (hereby referred to as “Suppliers”) that produce goods and/or provide service for Brookwood Companies, Inc. or any local affiliate thereof.

  1. Laws and Regulations: Notwithstanding anything herein and to the contrary, Suppliers must operate in full compliance with all compulsory laws and regulations of the countries in which they operate.

  2. Child Labor: Suppliers must not employ workers younger than the greater of: (i) 15 years of age, or 14 where the local law allows such exception consistent with International Labor Organization guidelines, or (ii) the age for completing compulsory education, or (iii) the minimum age established by law in the country of manufacture. In addition, Suppliers must comply with all legal requirements for authorized young workers, particularly those pertaining to hours of work, wages, and working conditions.

  3. Forced Labor: Suppliers will not use forced labor, whether prison, bonded, indentured or otherwise and will not engage in or support trafficking in human beings. Forced overtime is also prohibited.

  4. Discipline: All workers must be treated with respect and dignity. No worker shall be subject to corporal punishment, physical, sexual, psychological or verbal harassment or abuse as defined by applicable law. In addition, Suppliers will not use monetary fines as a disciplinary practice.

  5. Hours: Suppliers will not require workers to work in excess of the lesser of: (i) the limits on regular and overtime hours allowed by the law of the country where the worker is located; or (ii) 60 hours a week on a regularly scheduled basis, including overtime, and, except under extraordinary business circumstances, 72 hours a week as an absolute maximum. In addition, Suppliers will ensure all workers are entitled to a least 1 day off every consecutive seven-day period.

  6. Wages/Benefits: Suppliers must ensure that they pay workers at least the legal minimum wage, as well as the legally mandated overtime premium, for all hours worked and that there will be no monetary fines for poor performance. Suppliers must also ensure that all legally mandated benefits are being provided and that there will be no illegal deductions for benefits.

  7. Discrimination: While Brookwood recognizes and respects cultural differences, Suppliers must ensure employment (including hiring, remuneration, benefits, advancement, termination and retirement) is based on ability and not on race, color, religion, sex, age, national origin, disability, pregnancy, marital or partnership status, sexual orientation, gender identity, veteran’s status, or any other personal characteristics protected by law in each locality. Suppliers must comply with all applicable country and local laws governing non-discrimination in employment.

  8. Freedom of Association/Collective Bargaining: Workers should be free to join organizations, such as trade unions, of their own choosing, and to refrain from joining such organizations if that is their wish. Suppliers must not threaten or penalize workers for their efforts to organize or bargain collectively where permitted by the laws of the country where the worker is located, nor may they discriminate against workers as a result of any such organization affiliation.

  9. Health and Safety: Suppliers must provide their workers with a clean, safe and healthy work environment in compliance with all applicable, legally mandated standards for workplace health and safety in the countries in which they operate. This includes residential facilities, if applicable. In addition, Brookwood encourages Suppliers to strive to implement industry best practices, where applicable.

  10. Environmental Management: Suppliers must comply with all local environmental laws applicable to their operations. In addition, Brookwood encourages Suppliers to have environmental policies and environmental management systems containing goals with targets that are focused on the continuous improvement of overall environmental performance.

  11. Monitoring and Compliance: Brookwood reserves the right to undertake affirmative measures such as announced and unannounced on-site inspections of Suppliers premises and production facilities, to monitor compliance with this Code of Conduct. Suppliers must maintain on site all documentation necessary to demonstrate compliance with this Code of Conduct. Suppliers must allow Brookwood’s associates and/or third party monitoring firms full access to premises and production facilities, worker records and workers for confidential interviews in connection with monitoring visits.

  12. Integrity and Anti-Corruption: Suppliers must conduct business with honesty and integrity and demonstrate the highest standards of business ethics. Suppliers must not engage in bribery, corruption, or other unethical or illegal practices whether in dealings with government officials (which includes government employees or officers at any level, employees or officers at government-controlled or owned entities, employees or officers of public international organizations, and political officials or candidates or anyone acting on such a person’s behalf), political parties or others, including individuals in the private sector. This includes, directly or indirectly, paying, giving, offering, promising, or authorizing money or anything of value to anyone to seek to obtain an undue or improper advantage. This also includes any unethical business activities or arrangements between Suppliers and any Brookwood associate or any other company or individual.

  13. Accuracy of Business Records: Suppliers will record and report information accurately and honestly and will not hide, fail to record, or make false entries. All books, records and accounts must accurately reflect transactions, payments and events, and conform to generally accepted accounting principles, good internal controls and all applicable laws and regulations.

  14. Responsible Sourcing: Suppliers will be committed to the sourcing of raw materials, goods and services with the same fundamental support of human rights, labor, health and safety, environment, and ethics – unbounded by specific materials or locations, and develop and/or maintain the capability to identify all materials contained in its products for Brookwood.