Introduction
Corporate integrity, ethical business practices, responsible product sourcing, and protecting human health and the environment in its supply chain are important to CLP Circular Services, Inc (“Company”). This Code of Conduct applies to CLP Circular Services, Inc’ manufacturers, distributors, suppliers, and other vendors (each a “Vendor” and collectively “Vendors”). Each Vendor is responsible for compliance with the standards set out in this Vendor Code of Conduct (“Code of Conduct”) throughout its operations and its supply chain.
Certification:
Vendor shall certify to Company that it has implemented and maintains a reliable recordkeeping system to verify and document:
1. Eligibility of its workers to ensure that Vendor shall not support or engage in slavery or human trafficking, including but not limited to child labor, bonded labor, indentured labor, and forced labor, in any part of its supply chain;
2. Eligibility of its workers and adequate safety protections to ensure that Vendor does not, support, engage in, or require any hazardous labor to be performed by any person under the age of 18;
3. Accurate compensation of its workers to meet any required prevailing or minimum wage and benefits established by and in compliance with applicable law;
4. Its policy to not discriminate in hiring, compensation, training, advancement, promotion, termination, retirement, or any other employment practice based on race, color, national origin, gender, gender identity, sexual orientation, military status, religion, age, marital or pregnancy status, disability, or any other protected characteristic;
5. Its policy to not condone, tolerate or subject its workers to corporal punishment, or physical, verbal, sexual, or psychological abuse or harassment;
6. Its policy to provide a safe, healthy, and sanitary working environment and to implement training, protective equipment, maintenance, procedures and safeguards to prevent workplace and industry-specific hazards and work-related accidents and injuries;
7. Its policy not to retaliate against its workers for good faith whistleblowing, freedom of assocation, or reporting of a Code of Conduct violation;
8. Its policy to comply with the Foreign Corrupt Practices Act, Sherman Antitrust Act, anti-bribery, anti-corruption, conflict of interest, code of ethics, environmental laws and treaties, and similar regulatory requirements;
9. Its ownership and maintenance of permits, business licenses, or other documentation that allow Vendor to do business and supply the goods or services supplied to Company;
10. Its cybersecurity and AI policy or procedures to ensure security and privacy of data and avoid discrimination and bias; and
If Vendor is performing work at Company premises, Vendor shall provide or otherwise attest compliance with requirements as applicable to the work:
1. Health, Safety and Environment Plan, Emergency and Incident Response Plan, Business Continuity Plan, Disaster Recovery Plan, Hazardous Material Business Plan, Spill Prevention Control and Countermeasure Plan, Stormwater Pollution Prevention Plan and/or similar plans applicable to the goods or services supplied to Company;
2. Any incident reports, notices of violation, root cause analyses, enforcement actions or similar documents that affect the ability of Vendor to safely and legally provide the goods or services supplied to Company; and/or
3. Vendor’s safety statistics including TRIR and EMR. A TRIR of <2.5 and an EMR of <1 is preferred.
4. Vendor’s certificate(s) of insurance.
Company’s mission includes supporting the circular economy. If Vendor has the following items, please provide to Company copies, summaries or a hyperlink to the following:
1. Published sustainability reporting;
2. Percentages of Vendor’s waste recycled, reused or composted;
3. Vendor facility reuse, recycling or composting programs; and
4. Environmentally preferable purchasing or similar policies or procedures.
Compliance with Laws
Vendor shall comply with all applicable federal, state and local laws and regulations, including laws and regulations relating to this Code of Conduct. Vendor acknowledges that Company may in its discretion, but has no obligation to, conduct Vendor inspections to confirm Vendor’s compliance with this Code of Conduct.
Vendor shall operate its facilities and provide goods (including components and packaging) and services in compliance with all environmental laws, including but not limited to laws and international treaties relating to: emissions, discharges, pollutants and toxics, hazardous substance handling, and waste transport, processing and disposal.
Violations
Vendor shall self-report any violations of the Code of Conduct to Company. Vendor can also submit questions and comments regarding the Code of Conduct to Company at legal@circularservices.com or to the Company’s hotline at 1-833-407-9596 or circularservices.ethicspoint.com. Violation of the Code of Conduct may result in termination of Vendor’s business relationship with Company, including any purchase orders or contracts.