Supplier Code of Conduct Policy | Wright Service Corp.

Wright Service Corp. and its family of companies are committed to conducting business activities with the highest standards of business ethics and in accordance with all applicable laws and regulations.

This Supplier Code of Conduct (“Code”) applies to all parties providing goods or services (collectively, “Suppliers”) to Wright Service Corp. and its family of companies, affiliates and subcontractors, whether organized, operating or existing under United States law or the law of any other country, state, political union, municipality, administrative district or other governmental authority. This Code establishes the standard of conduct Wright Service Corp. expects from its Suppliers in several areas, including human rights, labor requirements, health and safety, environmental compliance and management practices. Suppliers are responsible for compliance with the standards set out in this Code throughout their operations and supply chain. Wright Service Corp. reserves the right to assess Supplier compliance against the Code. Violations of the Code may result in corrective action, including termination of the business relationship with Wright Service Corp.

Compliance with Laws and Regulations

Supplier shall comply with all applicable laws in any country in which it conducts business and demonstrate actions in all cases that meet or exceed those required by Applicable Law. The term “Applicable Law(s)” means with respect to any Supplier, any domestic, foreign, federal, state, local or municipal statute, law, ordinance, policy, guidance, rule, administrative interpretation, regulation, order, writ, injunction, directive, judgment, decree or other requirement of any governmental entity applicable to such Supplier. Where the Code of Conduct imposes a higher standard for the benefit of workers or the environment than set out by law or regulation, Supplier must meet the higher standard.

Anti-bribery and Anti-corruption

Suppliers must comply with all anti-bribery and anti-corruption laws worldwide and conduct business with integrity. Accordingly, Suppliers must never accept or provide anything of value, either directly or indirectly, in order to obtain an improper advantage or to obtain or retain business. Suppliers must have adequate procedures in place to prevent bribery in all commercial dealings undertaken.

Conflicts of Interest

Suppliers must avoid conflicts of interest as well as the appearance of conflicts of interest. Wright Service Corp. defines a conflict of interest as being involved in a relationship or activity that affects, or has the appearance of affecting, your objectivity in making business decisions in the best interest of the company. For example, a conflict of interest can occur when an employee is in a position to influence a decision that may result in a personal gain for the employee or the employee’s family member as a result of Wright Service Corp.’s business dealings. Suppliers must disclose to Wright Service Corp. any conflicts of interest situations of which the Supplier is aware.

Wages and Benefits

Wages paid to employees shall be at least the minimum wage under applicable law. Paid annual leave and holidays shall be paid as required by applicable law. Benefits provided by Supplier shall include, at a minimum, those mandated by applicable law. Compensation, including overtime premiums and benefits, must meet the standards set by applicable law, collective agreements and industry benchmark standards. For each pay period, Supplier shall provide its employees an understandable wage statement. Wage deductions must not be excessive and must be itemized clearly. Wages are to be paid on schedule at least once per month or such shorter time period as required by applicable law.

Workers Rights

Suppliers shall abide by and support human rights as it relates to the United Nations International Bill of Human Rights and the International Labour Organization in all activities and in the communities they serve. Suppliers must meet or exceed applicable laws as it relates to disability accommodations, religious accommodations, and maintain a zero-tolerance harassment policy.

Working Hours

Suppliers shall comply with applicable laws and industry standards with respect to working hours, not exceeding the maximum hours allowed by applicable law and must allow its employees at least one (1) day off during each seven (7) day period. Should overtime work be necessary or mandatory, employees are to be advised with reasonable notice. Suppliers shall pay its employees overtime pay at a rate which is higher than regular wages and in accordance with applicable law. Suppliers shall permit its employees to take all breaks required by applicable law and, in any event, reasonable breaks, lunch periods and bathroom breaks.

Child Labor

Discrimination, Harassment and Disciplinary Practices

Suppliers shall not discriminate against their employees or prospective employees in hiring practices, compensation, training, advancement or promotion, termination, retirement or any other employment practice on the basis of race, color, national origin, gender, gender identity, religion, age, disability, political affiliation, sexual orientation, social or marital status, maternity or membership in worker’s organizations, such as unions or any other similar factors. Suppliers shall not engage in the use or threat of corporal punishment, the use or threat of any type of abuse or harassment, including mental, physical (including sexual) or verbal, against its employees or the use or threat of any other form of intimidation. Suppliers shall treat all of its employees with respect and dignity. All major disciplinary measures taken against employees shall be documented by Suppliers.

Diversity, Equity and Inclusion

With a people-focused culture, Suppliers shall be committed to being an equal opportunity employer, creating an inclusive work environment where employees are heard, respected and valued, and empowering employees to achieve their personal and professional goals.

Supplier shall comply with the Americans with Disabilities Act (ADA), as amended by the ADA Amendments Act, and all applicable state or local laws. Consistent with those requirements, Supplier shall reasonably accommodate qualified individuals with a disability if such accommodation would allow the individual to perform the essential functions of the job, unless doing so would create an undue hardship. Reasonable accommodations for an employee’s religious beliefs or practices shall also be made.

Protecting Data

Suppliers should protect the confidential information of our consumers and third parties and safeguard their confidential personal information against unauthorized access, use or disclosure. Suppliers should also comply with industry standards regarding data protection including but not limited to data retention, technological security, password security and use of personal devices.

Freedom of Assocation

Suppliers should respect the rights of their employees to choose whether to associate with any lawful organization, including labor organizations. As such, Suppliers should not take any action to prevent or suppress the exercise of these rights, punish workers that exercise these rights, retaliate against workers who raise collective bargaining compliance issues or discriminate against workers based on union membership.

Anti-trust Policy

Suppliers must have clear policies in place to set parameters and standards for those working within it, with it, and on its behalf. There should be an antitrust compliance policy or at least a clear antitrust statement set within a broader ethics policy, code, or statement of ethics, which is published internally and externally in all relevant working (and customer) languages.

The policy should include a statement of Supplier’s commitment to fair competition, set out the general approach to reducing antitrust risk, and give an overview of implementation strategy. It should also:

Expressly prohibit all forms of anticompetitive behavior.
Explain why it is necessary to avoid anticompetitive behavior (setting out the ethical case as well as the legal risks for both the business and individuals).
Commit Supplier to conduct its business and affairs without engaging in any form of anticompetitive behavior.

Health and Safety

Suppliers must provide their employees with a safe and healthy working environment and, where provided, a safe and healthy living environment. Suppliers must provide appropriate worker safety training and equipment testing and maintenance. The Supplier shall comply with applicable law by acquiring and maintaining the required construction, zoning, occupancy and operating permits. Suppliers shall comply with applicable worker safety laws and regulations which includes but is not limited to:

Occupational Safety
Fire Safety
Emergency Preparedness
Chemical Safety

Environmental

Suppliers must comply with all applicable environmental protection and hazardous substances management laws, including laws and international treaties relating to waste disposal, emissions, discharges and hazardous and toxic material handling. This applies to all aspects of the Supplier’s business including but not limited to waste reduction, waste management, the manufacturing processes, air emissions, energy use and land use management.

For the purpose of annual Corporate Social Responsibility Reporting, Suppliers agree to provide environmental metric data upon request to Wright Service Corp.

Whistle Blower

Supplier shall self-report any violations of the Code of Conduct. Supplier can also submit questions and comments regarding the Code of Conduct, to Wright Service Corp.’s liaison set out below:

Wright Service Corp.
Legal Department
5930 Grand Avenue
West Des Moines, Iowa 50266
1-800-882-1216
[email protected]

Supplier shall not retaliate or take disciplinary action against any worker who has, in good faith, reported violations or questionable behavior, or who has sought advice regarding this Code of Conduct.

Monitoring of the Supplier Code of Conduct

Wright Service Corp. reserves the right to review this Supplier Code of Conduct on a regular basis and revise it as necessary. It is the responsibility of the Supplier to ensure that it understands and complies with this Supplier Code of Conduct and to inform Wright Service Corp. (or a member of its management) if and when any situation develops that causes a Supplier to operate in violation of this Supplier Code of Conduct. Supplier shall report any violations of the Supplier Code of Conduct as soon as practicable to Wright Service Corp.

In addition to any other rights Wright Service Corp. may have under any agreement it may have entered into with a Supplier, if Wright Service Corp. determines that the Supplier fails to comply with or breaches any terms of this Supplier Code of Conduct or has otherwise behaved in a manner that is inconsistent with the intent of this Supplier Code of Conduct, Wright Service Corp. reserves the right, in its sole and absolute discretion, to terminate the business relationship with the Supplier or require corrective actions within an acceptable time period and/or work with the Supplier for an acceptable remedial program in order for the business relationship to continue or resume.