SUPPLIER CODE OF CONDUCT
VDG Salumi is committed to the highest standards of social and environmental responsibility and ethical conduct, as well as selecting as local as possible (“ALAP”) suppliers.
VDG Salumi requires its suppliers to operate in accordance with the principles in this VDG Salumi Supplier Code of Conduct (“Code”) and in full compliance with all applicable laws and regulations. The Code requires VDG Salumi suppliers to provide safe working conditions, treat employees with dignity and respect, act fairly and ethically, and use environmentally responsible practices wherever they make products or perform services for VDG Salumi. This Code goes beyond mere compliance with the law by drawing upon internationally recognized standards to advance social and environmental responsibility. When differences arise between standards and legal requirements, the stricter standard must apply, in compliance with applicable law.
This Code applies to VDG Salumi suppliers and their subsidiaries, affiliates, and subcontractors (each a “Supplier”) providing goods or services to VDG Salumi, or for use in or with VDG Salumi products. This Code outlines VDG Salumi expectations for Supplier conduct regarding labour and human rights, health and safety, environmental protection, ethics, and management practices.
VDG Salumi will assess its Suppliers’ compliance with this Code, and any violations of this Code may jeopardize the supplier’s business relationship with VDG Salumi, up to and including termination.
Additionally, VDG Salumi maintains detailed standards (“Standards”) that explicitly define our expectations for compliance with this Code.
Principles
Labour and Human Rights
VDG Salumi believes all employees in our supply chain deserve a fair and ethical workplace. Employees must be treated with the utmost dignity and respect, and VDG Suppliers must uphold the highest standards of human rights.
Anti-Discrimination, Anti-Harassment & Abuse
Similar to our standards in our Culture Book, Supplier must not discriminate against any employees based on age, disability, ethnicity, gender, marital status, national origin, political affiliation, race, religion, sexual orientation, gender identity, union membership, or any other status protected by applicable national or local law, in hiring and other employment practices. Supplier must not require pregnancy or medical tests, except where required by applicable laws or regulations or prudent for workplace safety, and must not improperly discriminate based on test results.
Suppliers must commit to a workplace free of harassment and abuse. Supplier must not threaten employees with, or subject them to harsh or inhumane treatment, including but not limited to verbal abuse and harassment, psychological harassment, mental and physical coercion, and sexual harassment.
Wages & Benefits
Suppliers must pay at least the minimum wage and provide any benefits required by law and/or contract. Preference will be to Supplier who pays employees a Living Wage. Supplier must compensate employees for overtime hours at the legal premium rate, or in time off according to local governing law. Supplier must communicate pay structure and pay periods to all employees. Supplier must meet all legal requirements relating to wages and benefits, pay accurate wages in a timely manner, and wage deductions must not be used as a disciplinary measure. All use of temporary and outsourced labour must be within the limits of the local law.
Prevention of Involuntary Labour & Human Trafficking
Supplier must ensure that all work is voluntary. Supplier must not traffic persons or use any form of slave, forced, bonded, indentured, or prison labour. Involuntary labour includes the transportation, harbouring, recruitment, transfer, receipt, or employment of persons by means of threat, force, coercion, abduction, fraud, or payments to any person having control over another person for the purpose of exploitation.
Supplier must not withhold employees’ original government-issued identification and travel documents. Supplier must ensure that employees’ contracts clearly convey the conditions of employment in a language understood by the employees. Supplier must not impose unreasonable restrictions on movement within the workplace or upon entering or exiting company-provided facilities.
Employees must not be required to pay employers’ or their agents’ recruitment fees or other similar fees to obtain their employment. If such fees are found to have been paid by employees, such fees must be repaid to the employees. Supplier must ensure that the third-party recruitment agencies it uses are compliant with the provisions of this Code and the law.
Prevention of Underage Labour
Supplier must employ only employees who are at least 14 years of age, the applicable minimum legal age for employment, or the applicable age for completion of compulsory education, whichever is highest. Supplier may provide legitimate workplace apprenticeship programs for educational benefits that are consistent with Article 6 of ILO Minimum Age Convention No. 138 or light work consistent with Article 7 of ILO Minimum Age Convention No. 138.
Juvenile Employees' Protections
Supplier may employ juveniles who are older than the applicable legal minimum age but are younger than 18 years of age, provided they do not perform work that might jeopardize their health, safety, or morals, consistent with ILO Minimum Age Convention No. 138. Supplier must not require juvenile employees to work overtime or perform nighttime work.
Student Employees' Protections
Supplier must ensure proper management of student employees through proper maintenance of student records, rigorous due diligence of educational partners, and protection of students’ rights in accordance with applicable law and regulations. Supplier must provide appropriate support and training to all student employees.
Working Hours
A workweek must abide by local governing law, and all overtime must be voluntary.
Freedom of Association
Supplier must freely allow employees’ lawful rights to associate with others, form, and join (or refrain from joining) organizations of their choice, without interference, discrimination, retaliation, or harassment.
Grievance Systems
Suppliers must ensure that employees have a mechanism to report grievances and that facilitates open communication between management and employees.
Health & Safety
Employees’ health, safety, and wellbeing is important to VDG Salumi. Supplier must provide and maintain a safe work environment and integrate sound health and safety management practices into its business. Employees must have the right to refuse unsafe work and to report unhealthy working conditions.
Health & Safety Permits
Supplier must obtain, keep current, and comply with all required health and safety permits.
Occupational Health & Safety Management
Supplier must identify, evaluate, and manage occupational health and safety hazards through a prioritized process of hazard elimination, substitution, engineering controls, administrative controls, and/or personal protective equipment.
Emergency Preparedness & Response
Supplier must identify and assess potential emergency situations. For each situation, Supplier must develop and implement emergency plans and response procedures that will minimize harm to life, environment, and property.
Incident Management
Supplier must have a system for employees to report health and safety incidents and near-misses, as well as a system to investigate, track, and manage such reports. Supplier must implement corrective action plans to mitigate risks, provide necessary medical treatment, and facilitate employees’ return to work.
Working Conditions
Supplier must provide employees with clean and accessible toilet facilities, change rooms, lunch area, clean water, and access to healthy food. Supplier-provided dining, food preparation, and storage facilities must also be sanitary.
Health & Safety Communication
Supplier must provide employees with appropriate workplace health and safety training in their primary language. Health and safety-related information must be clearly posted in the facility. Supplier must, at the minimum, uphold HACCP, and preferably CFIA.
Environment
Supplier must develop, implement, and maintain environmentally responsible business practices. Suppliers utilizing waste diversion, clean energy or any other sustainable certifications will be given priority treatment and acknowledgement.
Environmental Permits & Reporting
Supplier must obtain, keep current, and comply with all required environmental permits. Supplier must comply with the reporting requirements of applicable permits and regulations.
Hazardous Waste Management
Supplier must implement a systematic approach to identify, manage, reduce, and responsibly dispose of, or recycle, hazardous waste.
Non-Hazardous Waste Management
Supplier must implement a systematic approach to identify, manage, reduce, and responsibly dispose of or recycle non- hazardous waste.
Wastewater Management
Supplier must implement a systematic approach to identify, control, and reduce wastewater produced by its operations. Supplier must conduct routine monitoring of the performance of its wastewater treatment systems.
Air Emissions Management
Supplier must identify, manage, reduce, and responsibly control air emissions emanating from its operations that pose a hazard to the environment. Supplier must conduct routine monitoring of the performance of its air emission control systems.
Pollution Prevention & Resource Reduction
Supplier must reduce energy, water, natural resource consumption, and greenhouse gas emissions by implementing conservation and substitution measures. Supplier must minimize hazardous substances consumption by implementing reduction and substitution measures.
Ethics
VDG Salumi is committed to the highest standards of ethical conduct in all of our endeavours. Supplier must always be ethical in every aspect of its business, including relationships, practices, sourcing, and operations.
Business Integrity
Supplier must not engage in dishonest practice, corruption, extortion, embezzlement, or bribery to obtain an unfair or improper advantage.
Disclosure of Information
Supplier must accurately record information regarding its business activities, labour, health and safety, and environmental practices and must disclose such information, without falsification or misrepresentation, to all appropriate parties and as required by law.
Protection of Intellectual Property
Supplier must respect intellectual property rights and safeguard customer information. Supplier must manage technology and know-how in a manner that protects intellectual property rights.
Community Engagement
Supplier is required to foster social and economic development and contribute to the sustainability of the communities in which it operates.
Continuous Improvement
VDG Salumi believes that continuous improvement and commitment are key to enriching the social and environmental wellbeing of our supply chain. Righteous holds its suppliers accountable to this and all of its Standards. Supplier must implement or maintain, as applicable, management systems that identify and mitigate operational risks, and facilitate continuous improvement.
Company Statement
Supplier is required to develop a company statement affirming its commitment to high standards of social and environmental responsibility, ethical conduct, and continuous improvement. Supplier must post this statement in all of its facilities.
Risk Assessment & Management
Supplier must develop and maintain a process to identify labour and human rights, health and safety, environmental, business ethics, and legal compliance risks associated with its operations; determine the relative significance of each risk; and implement appropriate procedures and controls to minimize the identified risks.
Audits & Assessments of Subcontractors
Supplier must perform periodic evaluations of its facilities and operations, and the facilities and operations of its subcontractors and next-tier suppliers that provide goods or services to Righteous to ensure compliance with this Code and the law.
Supplier will permit Righteous and a third party designated by Righteous to periodically evaluate Supplier’s facilities and operations, and those of its subcontractors and next-tier suppliers, to the extent they are providing goods or services to Righteous, for Righteous' benefit, or for use in Righteous products.
Documentation & Records
Suppliers must maintain appropriate documents and records to ensure regulatory compliance.
Training & Communication
Supplier must develop and maintain management and employees training programs to facilitate proper implementation of its policies and procedures and to fulfill Supplier’s continuous improvement objectives. Supplier must have a process or forum for communicating clear and accurate information about its performance, practices, policies, and expectations to its employees, next-tier supplier(s), and customers. Supplier must have an ongoing process to obtain feedback on its practices related to this Code and to foster continuous improvement.
Corrective Action Process
Supplier must have a process for timely correction of any deficiencies or violations identified by an internal or external audit, assessment, inspection, investigation, or review.