1. Introduction

Elektra is committed to treating all workers with respect and dignity, ensuring healthy and safe working conditions, and conducting environmentally responsible and ethical operations. Elektra expects these same commitments from its suppliers, vendors, staffing partners, contractors, subcontractors, and sub-tier suppliers (“Suppliers”). This Supplier Code of Conduct (“Code”) establishes expectations for how companies with whom we do business should operate. These expectations are derived from and respect internationally recognized standards and frameworks, including the UN Guiding Principles on Business and Human Rights. The Code applies to all Suppliers of goods and services to Elektra, and their subsidiaries (“Elektra”).

Suppliers shall implement and monitor programs designed to achieve conformance with the Code, even when the Code exceeds the requirements of applicable law. Suppliers will also require their own suppliers, vendors, and contractors to comply with the Code in their operations and across their supply chains.

  1. Compliance with underlying obligations. In addition to the responsibilities outlined in the Code, Suppliers must comply with all applicable laws, including, but not limited to, immigration and labor laws, legal regulations, environmental, health and safety laws, trade and sanction regulations, directives, and guidelines. Suppliers must also uphold all obligations in any contract a Supplier may have with us. Suppliers using our properties or facilities must also comply with all of our applicable policies and requirements.
  2. Information requests, disclosure, and documentation. Suppliers will cooperate with any information requests or audits we may initiate to confirm Suppliers’ compliance with the Code and accurately disclose requested information in a timely manner. Information requests or audits may be initiated on: the topics covered in the Code; hiring practices of entities connected to the provision of goods or services to Elektra; and Supplier business activities, structure, financial situation, and performance. Suppliers will create and maintain documents and records in compliance with applicable laws, regulatory requirements, and the Code. Suppliers will also ensure appropriate confidentiality to protect privacy. Falsification of records, refusal to disclose, or misrepresentation of conditions or practices in the supply chain is unacceptable and may result in the termination of the Supplier’s business relationship with Elektra.
  3. Certifications. Suppliers should use credible third-party certifications, including for materials, production processes, and products, where applicable. If Elektra requests additional certifications, such as ISO 50001, 14001, or 45001, Suppliers will make good faith efforts to obtain such certifications in a timely manner.
  4. Accountability. Though we seek to work with Suppliers to improve conditions, we may suspend or terminate our relationship with any Supplier that fails to meet the responsibilities of the Code.

2. Fair labor practices and human rights

Elektra expects its Suppliers to share its commitment to uphold the human rights of workers, treat them with dignity and respect, and provide a workplace free of harassment, discrimination, and retaliation. This applies to all workers, including temporary, migrant, student, contract, and direct employees. Therefore, Suppliers must manage their own workforce in order to achieve the following results:

  1. Freely-chosen employment and combating modern slavery. Suppliers will not use or permit any form of forced, bonded, or indentured labor, or engage in practices that constitute modern slavery. All work, including overtime, must be voluntary, and all workers must be free to terminate their employment at any time without financial reprisal or penalty if reasonable notice is given. Suppliers will not unreasonably restrict workers’ freedom to move into, out of, or within any Supplier-controlled facility or workspace. Suppliers will not hold workers’ identity, immigration, or work permit documents longer than necessary for administrative processing. Suppliers may provide individual, lockable storage facilities in workers’ accommodations, but may not access them while in use. Suppliers will keep up-to-date records of all workers and not require workers to pay recruitment or employment fees. Transportation costs for foreign workers must be paid by the Supplier. Workers must receive a written agreement in a language they understand, prior to departure from their home country.
  2. Young workers and student interns. Suppliers will not use child labor (under 15, or younger if local law applies). Suppliers must implement age verification and remediation if needed. Workers under 18 will not perform work that is likely to jeopardize their health or safety. Student internships are permitted if properly managed. Wages for student workers, interns, and apprentices must be at least the same as other entry-level workers.
  3. Wages and benefits. Suppliers will pay legally mandated wages and benefits, pay overtime at a higher rate, and ensure equal payment for equal work. Deductions from wages will not be used as discipline. Workers must receive clear pay stubs.
  4. Working hours. Workweeks will not exceed 60 hours per week, or less if local law applies. Workers must get at least one day off every seven days and have legally-required breaks.
  5. Fair treatment and non-discrimination. Suppliers will not allow inhumane treatment or discrimination for any reason, including race, color, age, sex, gender, immigration status, orientation, religion, political affiliation, etc.
  6. Freedom of association and collective bargaining. Workers are permitted to form and join labor unions and bargain collectively. If restricted by law, workers may elect alternate forms of representation.
  7. Security forces. Suppliers will not use security forces that engage in practices limiting freedom of association or that result in inhumane treatment or bodily harm not authorized by law.

3. Health and safety

Elektra expects Suppliers to provide healthy and safe working conditions. Suppliers should strive to protect workers from hazards and embed health and safety practices throughout their operations. Suppliers will integrate the following requirements into their business processes:

  1. Compliance with occupational health and safety laws and regulations. Suppliers must comply with all health and safety laws, identify, evaluate, and mitigate hazards, and provide personal protective equipment and training.
  2. Occupational injury and illness. Suppliers must implement procedures to prevent, track, report, and investigate occupational injury and illness, and provide medical treatment and corrective actions.
  3. Emergency preparedness. Suppliers must have emergency plans, conduct drills at least annually, and provide emergency response information.
  4. Machine safeguarding. Machinery must be regularly evaluated for safety and properly maintained.
  5. Sanitation, food, and housing. Workers must have access to clean toilets, potable water, and safe food and housing facilities.
  6. Documentation. Suppliers must keep records of training, risk assessments, health and safety management, and report incidents as required.

4. Environmental protection

Elektra recognizes that environmental responsibility is integral to producing world-class products. Suppliers will strive to create regenerative processes and minimize negative impacts on the community, environment, and natural resources. Suppliers will integrate the following requirements:

  1. Environmental permits and reporting. Suppliers must obtain, maintain, and comply with all required permits, approvals, and reporting requirements.
  2. Pollution prevention and resource reduction. Suppliers must minimize emissions, waste, and noise pollution, and reduce resource consumption.
  3. Hazardous and restricted substances. Suppliers must identify, label, and manage hazardous materials to ensure safe handling, use, storage, and disposal, and comply with all laws.
  4. Water and non-hazardous waste mitigation and management. Suppliers must manage and reduce water use and waste, and treat all wastewater and solid waste appropriately.
  5. Energy consumption and greenhouse gas emissions. Suppliers will improve energy efficiency, minimize energy use, reduce GHG emissions, track and publicly report on energy use and GHG emissions, and strive for 100% clean energy for Elektra products and services by 2030.
  6. Documentation. Suppliers must maintain records of training, permits, and management documentation as required.

5. Ethics

Elektra expects its Suppliers to uphold the highest standards of ethics. Suppliers should strive to establish clear policies and a culture of ethical business practices:

  1. Business integrity. No bribery, corruption, extortion, or embezzlement. No illegal payments or campaign contributions. Maintain compliance with all laws.
  2. Intellectual property. Respect all intellectual property rights and protect customer and supplier information.
  3. Responsible sourcing. Map supply chain and provide chain of custody information as requested. Source minerals and commodities in accordance with recognized due diligence frameworks.
  4. Privacy and information security. Protect privacy of all personal information, comply with laws, and do not interfere with worker privacy rights.

6. Management systems

Suppliers will establish a management system designed to ensure compliance with Elektra’s requirements and applicable laws, conform to the responsibilities of the Code, and identify and mitigate operational risks. The management system will contain:

  1. Executive-level, public commitment and accountability to respect human rights and the environment.
  2. Processes to identify, monitor, and comply with all applicable laws and requirements.
  3. Risk assessment and management processes, including human rights and environmental due diligence.
  4. Ongoing self-assessments, monitoring, and written improvement objectives.
  5. Training for workers and suppliers to implement policies and comply with the Code.
  6. Process to communicate information to workers, suppliers, and customers about the Code.
  7. Process for feedback from workers and stakeholders on management and practices.
  8. Mechanism for anonymous grievances, protection from retaliation, and monitoring of reporting processes.
  9. Process for timely remediation of any non-conformance identified by assessments or reports.

References

  • Responsible Business Alliance’s Code Of Conduct
  • Responsible Business Alliance’s Definition of Fees
  • United Nations Guiding Principles on Business and Human Rights
  • International Bill of Human Rights
  • International Labour Organization’s Declaration on Fundamental Principles and Rights at Work
  • International Labour Organization Conventions on Minimum Age (No. 138), Worst Forms of Child Labour (No. 182), and Forced or Compulsory Labour (No. 29)
  • Web Content Accessibility Guidelines (WCAG) 2.1, Level AA
  • United States Federal Acquisition Regulation (FAR)
  • Organisation for Economic Co-operation and Development (OECD) Guidelines For Multinational Enterprises
  • OECD Due Diligence Guidance For Responsible Business Conduct
  • OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas
  • Voluntary Principles on Security and Human Rights

This Code is aligned with the Responsible Business Alliance’s Code of Conduct. The official version of Elektra’s Supplier Code of Conduct is the English language version, which will prevail in the event of any conflict or inconsistency with translated versions.

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