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Suppliers Code of Conduct

Suppliers Code of Conduct

Introduction

Talan continuously strives to deal with suppliers who are leaders in their industries and are willing to demonstrate a strong commitment to sustainable development by adopting labour and human rights, ethics, health & safety, and environmental principles. Talan is committed to sourcing responsibly and considers all activities in its supply chain that fuel conflicts and lead to human rights abuses as unacceptable.

Consistent with the application of Talan’s sustainability principles, the Suppliers Code of Conduct (“Code”) outlines the company’s expectations regarding sustainability practices of its suppliers. By adopting this Code, Talan aims to minimize legal, financial, and reputation risks and promote sustainable development.

In all their activities, suppliers must conduct business in full compliance with the laws, rules, and regulations of the countries in which they operate and any other applicable jurisdiction. Suppliers are encouraged to go beyond legal compliance, drawing upon internationally recognized standards as indicated in each subsection of this Code, to advance social and environmental responsibilities. When a country’s laws and international standards address the same issues, the highest standards should be applied.

A - Management System

Suppliers shall take all reasonable measures to monitor compliance with this Code and promptly correct any non-compliance. In this regard, suppliers should establish a management system in line with the principles of this Code and international standards such as ISO 14001, ISO 27001, ISO 45001, ISO 50001, and SA8000. The management system should ensure:

  • Compliance with applicable laws, regulations, and customer requirements related to the supplier’s operations and products.
  • Conformance with this Code.
  • Identification and mitigation of operational risks related to this Code and continuous improvement.

The management system may include elements such as company commitment and policy towards corporate social and environmental responsibilities, management accountability, legal and customer requirements, risk assessment and management, improvement objectives, training programs, audits, compliance assessments, documentation, and supplier responsibility.

B - Labour and Human Rights

Suppliers are expected to uphold the human rights1 of workers, and to treat them with dignity and respect in compliance with internationally accepted standards as defined in the International Labour Organization (ILO) conventions and regional or national legislation governing working conditions.

1) Freely Chosen Employment2

Forced, bonded (including debt bondage) or indentured labour, involuntary or exploitative prison labour, slavery or trafficking of persons shall not be used. This includes transporting, harbouring, recruiting, transferring or receiving persons by means of threat, force, coercion, abduction or fraud for labour or services. There shall be no unreasonable restrictions on workers’ freedom of movement in the facility in addition to unreasonable restrictions on entering or exiting company-provided facilities. As part of the hiring process, workers must be provided with a written employment agreement in a language the worker can understand. All work shall be voluntary and workers shall be free to leave work at any time or terminate their employment. Employers and agents shall not hold or otherwise destroy, conceal, confiscate or deny access by employees to their identity or immigration documents, such as government-issued identification, passports or work permits. Workers shall not be required to pay employers’ or agents’ recruitment fees or other related fees for their employment.

2) Young Workers3

Child labour shall not be used in any stage of manufacturing. The term “child” refers to any person under the age of 15, or under the age of completing compulsory education, or under the minimum age for employment in the country, whichever is greatest. The use of legitimate workplace learning programs, which comply with all laws and regulations, is supported. Workers under the age of 18 (Young Workers) shall not perform work that is likely to jeopardize their health or safety, including night shifts and overtime. Suppliers shall protect students’ rights by providing appropriate and reasonable accommodations.

3) Working Hours

Working hours shall not exceed the maximum set by local law. Where there are no applicable laws in the jurisdiction in which they operate, a workweek shall not be more than 60 hours per week, including overtime, except in emergency or unusual situations. Workers shall be allowed at least one day off every seven days.

4) Wages and Benefits

Compensation paid to workers shall comply with all applicable wage laws, including those relating to minimum wages, overtime hours and legally mandated benefits to an adequate standard of living. Where no wage law exists, it is expected that workers be paid at least the minimum local industry standard. Deductions from wages as a disciplinary measure shall not be permitted. For each pay period, workers shall be provided with a timely and understandable wage statement that includes sufficient information to verify accurate compensation for work performed. All use of temporary, dispatch and outsourced labour shall be within the limits of the local law.

5) Humane Treatment

Suppliers shall provide their employees with a workplace free of harsh and inhumane treatment including any sexual harassment, sexual abuse, corporal punishment, mental or physical coercion or verbal abuse of workers; nor is there to be the threat of any such treatment. Disciplinary policies and procedures in support of these requirements shall be clearly defined and communicated to workers.

6) Non-Discrimination4

Suppliers shall be committed to provide a workplace free of harassment and unlawful discrimination. Suppliers shall not engage in discrimination based on race, colour, age, gender, sexual orientation, gender identity and expression, ethnicity or national origin, disability, pregnancy, religion, political affiliation, union membership, covered veteran status, protected genetic information, medical test results or marital status in hiring and employment practices such as wages, promotions, rewards, and access to training. Suppliers are encouraged to provide reasonable accommodation for religious practices. In addition, workers or potential workers should not be subjected to medical tests or physical exams that could be used in a discriminatory way.

7) Freedom of Association and Collective Bargaining5

Suppliers shall respect and uphold the rights of workers to freely join labour unions, seek representation and join workers’ councils in accordance with local laws, and to bargain collectively. Workers and/or their representatives shall be able to openly communicate and share ideas and concerns with management regarding working conditions and management practices without fear of discrimination, reprisals, intimidation or harassment.

C - Ethics

1) Business Integrity

The highest standards of integrity are to be upheld in all business interactions. Suppliers shall have a zero-tolerance policy to prohibit any and all forms of bribery, corruption, extortion, and embezzlement. Suppliers shall not offer or accept bribes or other unlawful incentives to/from their business partners. Suppliers are expected not to offer to Talan employees gifts or any other kind of personal benefit resulting from the relationships with suppliers.

2) No Improper Advantage

Bribes or other means of obtaining undue or improper advantage shall not be promised, offered, authorized, given, or accepted. This prohibition covers promising, offering, authorizing, giving, or accepting anything of value, either directly or indirectly through a third party, to obtain or retain business, direct business to any person, or otherwise gain an improper advantage. Monitoring and enforcement procedures shall be implemented to ensure compliance with anti-corruption laws.

Talan does not permit facilitation payments to be made, even if they may be legal in a particular jurisdiction. Facilitation payments are typically small, unofficial payments made to secure or expedite the performance of a routine government action by a government employee or official, such as providing routine police protection or processing permits. Suppliers are expected to refrain from placing Talan team members in a position where they are, or may be perceived to be, in breach of this Code.

3) Disclosure of Information

All business dealings shall be transparently performed and accurately reflected on suppliers’ business books and records. Information regarding participant labour, health and safety, environmental practices, business activities, structure, financial situation, privacy breaches, and performance is to be disclosed in accordance with applicable regulations and prevailing industry practices. Falsification of records or misrepresentation of conditions or practices in the supply chain is prohibited. Suppliers shall disclose information regarding business activities when requested by Talan.

4) 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. Customer and supplier information are to be safeguarded in accordance with Talan’s standards and requirements. Suppliers shall make only appropriate use of confidential information and ensure that all employees’ and business partners’ privacy and valid intellectual property rights are protected.

5) Fair Business, Anti-Spam, Advertising, and Competition

Suppliers shall comply with all applicable legislation relating to fair business practices, antitrust standards, anti-spam, competition standards, and advertising.

6) Protection of Identity and Non-Retaliation

Programs that ensure confidentiality, anonymity, and protection of supplier and employee whistleblowers are to be maintained. Suppliers should have a communicated process for their personnel to be able to raise any concerns without fear of retaliation.

7) Privacy & Information Security

Where the supplier handles sensitive information belonging to Talan Companies, its customers, or its employees, the supplier must strictly comply with all applicable privacy laws in the jurisdiction in which they operate, as well as the contractual obligations set forth in the agreement. Talan reserves the right to assess and monitor suppliers’ practices regarding information security protection.

The supplier must notify Talan immediately of all actual or suspected privacy breaches, information security incidents, or loss of Talan’s data, and the supplier must assist Talan in managing consequences from such events.

8) Community Engagement

Suppliers are encouraged to engage and invest in the communities in which they live, work, and serve to promote social and economic development.

9) Supplier Diversity

Suppliers are encouraged to promote, identify, and integrate diversity among their suppliers, in addition to workers. Diversity programs to boost the representation of women, Indigenous People, LGBT individuals, visible minorities, veterans, or persons with disabilities are expected to be implemented and continually improved.

D - Health and Safety

Legislation

Suppliers are expected to comply with the international, regional, and national health and safety standards applicable to the suppliers’ business activities, such as ISO 45001 Guidelines on Occupational Safety and Health. Suppliers shall comply with all applicable health and safety legislation and regulations and perform all services diligently in respect of health and safety matters.

1) Occupational Safety

Suppliers shall ensure that their employees and any person present on or near the workplace are protected against potential occupational health and safety hazards resulting from the suppliers' business activities. Potential for exposure to safety hazards is to be identified, assessed, and controlled through proper design, engineering and administrative controls, preventative maintenance, safe work procedures (including lockout-tagout), and ongoing safety training. Where hazards cannot be adequately controlled by these means, workers are to be provided with appropriate, well-maintained personal protective equipment and educational materials about risks associated with these hazards.

2) Emergency Preparedness

Potential emergency situations and events, including but not limited to structural integrity issues, fire risk, flooding risk, power supply continuity risk, and other reasonably expected risks, are to be identified and assessed. Their impact should be minimized by implementing emergency plans and response procedures, including emergency reporting, employee notification and evacuation procedures, worker training and drills, fire detection and suppression equipment, clear and unobstructed egress, adequate exit facilities, and recovery plans. Such plans and procedures shall focus on minimizing harm to life, the environment, and property.

3) Industrial Hygiene

Suppliers shall ensure that all products supplied to Talan or used on its premises comply with applicable workplace hazardous material information standards (e.g., WHMIS in Canada). Worker exposure to chemical, biological, and physical agents is to be identified, evaluated, and controlled according to the hierarchy of controls. Potential hazards are to be eliminated or controlled through proper design, engineering, and administrative controls. When hazards cannot be adequately controlled by such means, workers are to be provided with and use appropriate, well-maintained personal protective equipment. Protective programs shall include educational materials about the risks associated with these hazards. Material Safety Data Sheets must be available in English and French for all controlled products supplied to Talan or used on Talan's premises.

4) Physically Demanding Work

Worker exposure to the hazards of physically demanding tasks, including manual material handling, heavy or repetitive lifting, prolonged standing, and highly repetitive or forceful assembly tasks, is to be identified, evaluated, and controlled by providing appropriate equipment and measures.

5) Machine Safeguarding

Production equipment and other machinery shall be evaluated for safety hazards. Physical guards, interlocks, and barriers are to be provided and properly maintained where machinery presents an injury hazard to workers.

6) Sanitation, Food, and Housing

When applicable, workers are to be provided with ready access to clean toilet facilities, potable water, and sanitary food preparation, storage, and eating facilities. Worker dormitories provided by the suppliers or a labor agent are to be maintained to be clean and safe, and provided with appropriate emergency egress, hot water for bathing and showering, adequate lighting, heat, ventilation, individually secured accommodations for storing personal and valuable items, and reasonable personal space along with reasonable entry and exit privileges.

7) Health and Safety Communication

Suppliers shall provide workers with appropriate workplace health and safety information and training in the language of the worker or in a language the worker can understand for all identified workplace hazards, including mechanical, electrical, chemical, fire, and physical hazards. Health and safety-related information shall be clearly posted in the facility or placed in a location identifiable and accessible by workers. Training should be provided to all workers prior to the beginning of work and regularly thereafter. Suppliers shall systematically evaluate their health and safety performance through appropriate audits and report progress.

E - Environment

Legislation

Suppliers shall comply with all applicable statutes, regulations, guidelines, codes of practice, orders, and agreements entered into with government authorities relating to the protection and conservation of the environment. Suppliers shall obtain, maintain, and report on all environmental permits, approvals, licenses, and registrations as required under environmental legislation.

Policies and Practices

Suppliers shall have knowledge of the environmental impacts associated with their business activities and, where appropriate, implement policies, programs, and employee training to address, in particular but not limited to, the following matters:

1) Pollution Prevention and Resource Reduction

Emissions and discharges of pollutants and generation of waste of all types are to be minimized or eliminated at the source through practices such as adding pollution control equipment, modifying production, maintenance and facility processes, or by other means. The use of natural resources, including water, fossil fuels, minerals, and virgin forest products, is to be minimized through practices such as modifying production, maintenance and facility processes, materials substitution, re-use, conservation, and recycling.

2) Hazardous Substances

Chemicals and other materials posing a hazard to humans or the environment are to be identified, labeled, and managed to ensure their safe handling, movement, storage, use, recycling or reuse, and disposal.

3) Solid Waste

Suppliers are expected to implement a systematic approach to identify, manage, reduce, and responsibly dispose of or recycle solid waste (non-hazardous).

4) Air Emissions

Air emissions of volatile organic chemicals, aerosols, corrosive substances, particulates, ozone-depleting chemicals, and combustion by-products generated from operations are to be characterized, routinely monitored, controlled, and treated as required prior to discharge.

5) Materials Restrictions

Suppliers shall adhere to all applicable laws, regulations, and customer requirements regarding the prohibition or restriction of specific substances in products and manufacturing.

6) Water Management

Suppliers are expected to implement a water management program that documents, characterizes, and monitors water sources, use, and discharge; seeks opportunities to conserve water; and control channels of contamination. When applicable, all wastewater generated by Talan and managed by suppliers is to be characterized, monitored, controlled, and treated prior to discharge or disposal.

7) Energy Consumption and Greenhouse Gas Emissions

Talan encourages suppliers to take measures to reduce Greenhouse Gas (GHG) emissions generated by their operations, products, and services. Suppliers are expected to track and document energy consumption and all relevant scopes 1 and 2 at the facility and/or corporate level. Suppliers are encouraged to improve energy efficiency and minimize their energy consumption and GHG emissions.

F - Responsible Sourcing of Minerals

Suppliers of tangible products that contain “Conflict Minerals” shall be committed to demonstrating that they have in place appropriate due diligence controls over Conflict Minerals in their supply chain to ensure their products are “DRC Conflict Free.”

As used in this Section F, the following terms have specific meanings:

  • Conflict Minerals Rule: The rules and regulations of the U.S. Securities and Exchange Commission promulgated under Section 13(p) of the Securities Exchange Act of 1934, as amended.
  • Conflict Minerals: (A) Columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives (tantalum, tin, tungsten), or (B) any other mineral determined by the U.S. Secretary of State to be financing conflict in the Covered Countries.
  • Covered Countries: The Democratic Republic of the Congo and adjoining countries defined under the Conflict Minerals Rule.
  • DRC Conflict Free: Products that do not contain Conflict Minerals that directly or indirectly finance or benefit armed groups in Covered Countries.

 

In addition to Conflict Minerals, suppliers of products containing cobalt must exercise strict due diligence to ensure the mineral is sourced responsibly. Cobalt should not come from artisanal mines that fail to meet health and safety standards, nor should its purchase transactions benefit groups guilty of human rights violations.

G - Supplier Assessment and Monitoring

Talan reserves the right to assess and monitor the supplier’s practices regarding this Code on an ongoing basis. Suppliers may be requested to complete a self-assessment questionnaire. Talan or a designated third party may conduct onsite audits of selected supplier facilities to review relevant records, policies, and work practices and inspect facilities for compliance with this Code.

In cases of observed non-compliance, suppliers will take all reasonable measures to meet the standards outlined in this Code in a diligent manner.

References

The following standards and codes were used in preparing this Code and may be a useful source of additional information. Talan is committed to continuously reviewing this Code to ensure it is updated as needed to align with current industry practices and requirements.

International Instruments
International Best Practices and Voluntary Standards

Contacts

References

[1] Universal Declaration of Human Rights - General Assembly resolution 217 A (III) of 10 December 1948.
[2] In accordance with ILO conventions 29 and 105 (Forced Labour).
[3] ILO Convention 138 & Recommendation 146 (Minimum Age).
[4] ILO conventions 100 and 111 (Equal Remuneration and Discrimination).
[5] ILO conventions 87 and 98 (Freedom of Association).