Code of Conduct
KPS GLOBAL, LLC
CODE OF CONDUCT
Overall Standard
This KPS Global Code of Conduct (this “Code”) applies to all vendors and suppliers of KPS Global (“KPSG”).
The highest legal, moral and ethical standards of honesty, integrity and fairness are to be practiced in the conduct of KPSG’s affairs. In order to meet this standard, KPSG requires each of its suppliers and each of their facilities that supply goods to KPSG to operate and act in full compliance with this Code and with all applicable national, state, provincial, regional, local and other laws and regulations (“Applicable Law”). This Code also applies to affiliates and subcontractors of suppliers and to their respective facilities to the extent those facilities supply goods for ultimate sale to KPSG. If a supplier is in compliance with Section 1, Legal Requirements, with respect to employees working at facilities located in the United States, Canada or the European Union, it will be deemed to be in compliance with Sections 3, 4, 5, 6, 7 and 8, respectively, and compliance with those sections will be measured by compliance with Applicable Law of the United States, Canada or the European Union, as applicable, regarding the subject matter of those sections of this Code.
Specific Requirements
- Legal Requirements: KPSG suppliers must comply with all Applicable Law in the countries in which they operate.
- Limitations on Gifts and Gratuities: To maintain high ethical standards and to avoid the appearance of impropriety, KPSG directors, officers and employees will not give or receive payments or gifts in exchange for business opportunities with customers, vendors, suppliers, governmental entities or other KPSG employees. KPSG vendors and suppliers will neither accept nor give payments or gifts to KPSG directors, officers or employees or to third parties in exchange for business opportunities. If a supplier is in compliance with KPSG’s Code of Conduct and Section 1, Legal Requirements, with respect to employees working at facilities located in the United States, Canada or the European Union, it will be deemed to be in compliance with Section 2 with respect to such facilities and employees.
- Human Rights: KPSG will only initiate and renew contractual relationships with suppliers that do not violate basic human rights, as defined in the United Nation Declaration of Human Rights (“UNDHR”), the Core Conventions of the International Labor Organization (“ILO”), and the ILO Declaration on Fundamental Principles and Rights at Work.
- Child Labor: ILO Core Convention No. 138 generally does not permit children under the age of 15, or 14 in less developed countries, with certain exceptions noted therein, to work in any occupation. KPSG expects its suppliers to conduct their respective businesses that produce goods for KPSG in full compliance with this stated principle.
- Freedom of Association: KPSG suppliers must provide their employees with the right to freely associate and organize and to bargain collectively in with accordance applicable and ILO Core Conventions Nos. 87 and 98 where not prohibited under Applicable Law or required by international agreements.
- Forced Labor – Physical Coercion: KPSG will not knowingly work with any supplier that uses forced, bonded, indentured or slave labor nor will KPSG knowingly tolerate the use of physical or mental coercion or corporal punishment.
- Wages and Benefits: KPSG’s intention is to do business only with suppliers that comply with any Applicable Law concerning minimum wage and overtime legal requirements and suppliers will comply with all such requirements. In countries that set a maximum work week, suppliers will comply with such requirements.
- Discrimination: In accordance with ILO Core Conventions Nos. 100 and 111, and in accordance with Article 2 of the UNDHR, suppliers must not discriminate at its supplier facilities on the basis of race, gender, religion, ethnicity, nationality or political beliefs. In addition, suppliers must not discriminate on any other basis prohibited by Applicable Law.
- Health and Safety: KPSG requires that all facilities where goods are produced for KPSG must provide a safe and healthy work environment for all the employees. When housing is provided, it should also be clean and safe.
- Environment: KPSG has a commitment to the communities in which it operates and a responsibility for the environments we impact. KPSG seeks to work with suppliers that share this commitment.
Monitoring and Enforcement
KPSG commits to independent third party monitoring of its suppliers. As a condition of doing business with KPSG, a supplier must allow KPSG and/or its representatives or agents unrestricted access to each of its facilities and to all relevant records at all times, without advance notice, for the purpose of monitoring compliance with this Code. KPSG and/or its representatives or agents will comply with supplier’s reasonable safety rules applicable to presence at supplier’s facilities.
If a supplier violates this Code, either generally or with respect to a particular supplier facility, KPSG may either terminate its business relationship, generally or with the affected facility, or may require the affected facility to implement a corrective action plan. KPSG will continue to develop its monitoring systems to assess and ensure compliance with this Code.
