Code of Conduct for Suppliers
The terms of this Code extend to the company as a corporate body and its workers, regardless of their status or relationship with the supplier. This Code of Conduct therefore also applies to workers who are engaged informally, on short-term contracts, or on a part-time basis.
It is the responsibility of each supplier to ensure that its sub-suppliers do not violate the standards of this Code of Conduct.
In addition to meeting the terms of this Code, the supplier shall comply with all national laws and regulations, as well as other applicable industry standards (e.g. collective bargaining agreements or other Codes of Conduct).
Where there are differences between the terms of this Code and national laws or other applicable standards, the supplier shall always adhere to the higher or more stringent requirements.
Communication & Raising Awareness
It is the supplier’s responsibility to ensure that the standards included in this Code of Conduct are communicated to all employees as an integrated part of the suppliers own regulations and management policies. All relevant employees, including managers and supervisors, should be informed through appropriate means of communication and training if deemed necessary.
1.1. Freedom of Association and Collective Bargaining
Modulift UK Ltd expects its suppliers to recognize and respect the rights of employees to freely associate, organize and bargain collectively in accordance with the laws of the countries in which they are employed, as well as core ILO conventions Freedom of Association and Protection of the Right to Organize Convention, (C 87, 1948) and Right to Organize and Collective Bargaining Convention, (C.98- 1949).
Modulift UK Ltd recognizes the importance of open communication and direct engagement between workers and management and suppliers are to respect the rights of workers to associate freely and communicate openly with management regarding working conditions without fear of harassment, intimidation, penalty, interference or reprisal.
1.2. Forced Labour
Modulift UK Ltd expects its suppliers to prohibit any use of forced, bonded or indentured labour or involuntary prison labour, and embrace employment practices consistent with ILO conventions pertaining to forced labour: Forced Labour Convention, (c.29-1930) and Abolition of Forced Labour Convention, (C.105-1957).
All work, including overtime work, will be voluntary and workers should be free to leave upon reasonable notice. Employees handing in government-issued identification; passports or work permits may be normal business practice and acceptable under certain circumstances. However, suppliers shall not force employees to hand over government-issued identification.
1.3. Child Labour
Modulift UK Ltd expects its suppliers, at a minimum, not to engage in any practice inconsistent with the rights set forth in the Convention on the Rights of the Child, the ILO Minimum Age Convention (C.138-1973) or the Prohibition and Immediate Elimination of the Worst Forms of Child Labour Convention (C. 182-1999).
Children and young persons under the age of 18 shall not be engaged in labour that is hazardous to their health or safety, including night work.
Children under the age of 15 (14 or 16 in certain countries) shall not be engaged in labour that is detrimental to their education.
New recruitment of child labour in infringing of the above mentioned conventions is unacceptable. If child labour, as described above, is already in existence, sustained efforts shall be made to redress the situation as quickly as possible. However, the children concerned shall be given the possibility of earning a livelihood, as well as acquiring an education until they are no longer of compulsory school age.
All suppliers should also adhere to legitimate workplace apprenticeship programs and comply with all laws and regulations governing child labour and apprenticeship programs.
Modulift UK Ltd does not tolerate any form of discrimination in hiring and employment practices on the grounds of race, colour, religion, gender, sexual orientation, age, physical ability, health condition, political opinion, nationality, social or ethnic origin, union membership or marital status.
Consistent with the principles espoused in ILO Conventions on Discrimination (Employment and Occupation) Convention, C. 111-1958) and Equal Remuneration (Equal Remuneration Convention, C. 100-1951), the UN also discourages discrimination regarding access to training, promotion, and rewards.
1.5. Working Hours
Modulift UK Ltd expects its suppliers to comply with all applicable working hour requirements as established by local law. Wages should be paid in-full and on time, with the national legal standards or industry benchmark standards, whichever is higher, as a minimum requirement. Suppliers must ensure that all overtime work is voluntary and compensated at the prevailing overtime rates.
Modulift UK Ltd expects its suppliers to comply, at a minimum, with all wage and hour laws and regulations, including those pertaining to minimum wages, overtime wages, piece rates, other elements of compensation and to provide legally mandated benefits.
2. Human Rights
2.1. Human Rights
Modulift UK Ltd expects its suppliers to support and respect the protection of internationally proclaimed human rights and to ensure that they are not complicit in human rights abuses.
2.2. Harassment, Harsh or Inhumane Treatment
Modulift UK Ltd expects its suppliers to create and maintain an environment that treats all employees with dignity and respect. The supplier must not use any threats of violence, sexual exploitation or abuse, verbal or psychological harassment or abuse.
No harsh or inhumane treatment coercion or corporal punishment of any kind is tolerated, nor is there to be the threat of any such treatment.
2.3. Health and Safety Standards
At Modulift UK Ltd, recognised safety best practise and a encouraged culture of safety is an integral part of our business operation. Modulift UK Ltd expects its suppliers to follow all relevant legislation, regulations and directives in the country in which they operate to ensure a safe and healthy workplace or any other location where production or work is undertaken.
At a minimum, suppliers should strive to implement recognized management systems and guidelines such as the ILO Guidelines on Occupational Safety and Health (ILO-OSH-2001) which can be found at ILO's website and ensure at a minimum, reasonable access to potable water and sanitary facilities; fire safety; emergency preparedness and response; industrial hygiene; adequate lighting and ventilation; occupational injury and illness and machine safeguarding. Suppliers will also ensure these same standards apply to any dormitory or canteen facilities.
Modulift UK Ltd strongly encourages its suppliers to adopt the best practise detailed within ISO 45001:2018.
2.4. Occupational Safety, Welfare & Competence
Suppliers shall comply with all the applicable health and safety related laws and regulations. Workers shall never be disciplined for raising safety concerns and for refusing to work in an unsafe environment. Clear procedures shall be in place to identify, manage, control, record and report occupational hazards, risks, injuries and illnesses appropriately. Furthermore, Suppliers shall implement corrective actions to eliminate the root causes of injuries and illnesses. Suppliers shall ensure that employees are free to raise, without prejudice, welfare or mental health issues and take apropriate action to address such concerns. Where hazardous substances are used, relevant supervision, data sheets, controls and emergency plans shall be provided. Suppliers shall ensure there are adequate washing facilities for all their employees, especially at locations where acids or other corrosive substances are handled. All electrical equipment and wires shall be safely insulated, equipped with safety fuses and regularly inspected and repaired.
A key factor in safety is employee competence and training. Modulift’s minimum expectation is that all employees or contractors of a supplier, working on or engaged in the supply of products and/or services to Modulift, are fully competence and trained to complete their function, both safely and in accordance with the requirements specified in any Purchase Order, Supply Agreement or Contract. Records of training and competence are to be held and validity maintained by the supplier, adhering to all legislative training requirements, with evidence available upon request by Modulift.
3. Corporate Responsibility & Ethics
3.1. Corruption & Counterfeiting
Modulift UK Ltd expects its suppliers to adhere to the highest standard of moral and ethical conduct, to respect local laws and not engage in any form of corrupt practices, including extortion, fraud, or bribery, at a minimum. Modulift UK Ltd recognises that counterfeiting poses a serious threat within many of the industry sectors we serve. Therefore we will only use suppliers who have been vetted to verify quality, which includes evidence of supply from traceable sources, in line with our own practises and expectations. Modulift UK Ltd adopts a zero tolerance approach to any form of corrupt practise or counterfeiting. Agreement to this Code, is agreement to this zero tolerance approach.
3.2. Conflict of Interest
Suppliers are expected to disclose to Modulift UK Ltd any situation that may appear as a conflict of interest, and disclose to Modulift UK Ltd if any employee or professional under contract with Modulift UK Ltd may have an interest of any kind in the supplier's business or any kind of economic ties with the supplier.
3.3. Gifts and Hospitality
Modulift UK Ltd is careful with accepting or offering any type of gift or offer of hospitality that may influence the receiver’s integrity.
Company employees may not offer to, or accept from, third parties, gifts, hospitality, rewards, benefits or other incentives that could affect either party’s impartiality, influence a business decision or lead to the improper performance of an official duty. Similarly, they may not offer or accept cash donations.
Company employees may offer and accept ‘reasonable’ and ‘proportionate’ gifts and entertainment. In determining what is ‘reasonable’ and ‘proportionate’, employees are governed by the detailed particulars as set out in Modulift’s Anti-Bribery and Anti-Corruption Policy (BMM 100 App A7).
In all cases they must ensure that the gift or benefit:
is being given as an expression of goodwill and not in expectation of a return favour (a gift designed to secure a return favour could be seen as a bribe).
is commensurate with generally accepted standards for hospitality taking into account the norms for the industry/professional sector in which it is offered.
is being provided openly and transparently, and is of a nature that will not cause the company embarrassment if publicly reported.
complies with local laws and regulations, including the recipient’s own rules (bearing in mind that government rules on offering and receiving gifts or benefit are often particularly tight).
meets the value limits set by the company and has all required approvals. In cases of uncertainty, employees must seek advice from their line managers.
3.4. Data Protection
Suppliers are expected to comply fully with all current data protection laws applicable to them, subject to their geographical location. For UK suppliers this is the Data Protection Act 2018 and for EU Suppliers the General Data Protection Regulations. Modulift’s own compliance is evidenced through our Data Protection Policy (BMM 100 App A11).
At Modulift UK Ltd, environmental responsibility is an integral part of our business practices. We promote suppliers who are committed to reducing their environmental impact. The supplier shall work towards reducing its environmental impact through an active and responsible leadership. The most commonly prioritized aspects of environmental impact are; exploitation of natural resources, energy, fresh water, emissions to air and water, noise and dust, risks to cause soil pollution, waste disposal and product related aspects such as design, packaging and transportation. We encourage our suppliers to have a documented Environmental Management System (EMS) in place in order to manage the organization’s procedures and production processes in a comprehensive and documented manner, specifically adhering to environmental regulations. Modulift UK Ltd strongly encourages its suppliers to adopt the best practise detailed within ISO 14001:2015.
4.2. Hazardous Substance Management and Regulations
The supplier must comply with all national laws and regulations prohibiting or restricting specific substances. Suppliers shall for example comply with material restrictions (e.g. REACH) and continuously maintain records of relevant raw material declarations such as Material Data Sheets (MDS) or similar. In terms of documentation, suppliers must have appropriate management systems and routines in place in order to monitor:
The handling of any chemicals in its operations in an environmentally safe way;
The handling of any Conflict minerals shall follow international rules to implement reporting and
disclosure requirements regarding conflict minerals.
The handling, storing and disposing of hazardous waste in an environmentally safe manner;
Routines to avoid pollution;
Emergency routines to prevent and minimize the effects on health and environment in the event
of an emergency situation or an accident;
How development and diffusion of environmentally friendly technologies and/or materials are
addressed and encouraged where applicable.
4.3. Wastewater and Solid Waste
Wastewater and solid waste generated from operations, industrial processes and sanitation facilities must be monitored, controlled and treated as required by applicable laws and regulations before discharge and disposal. In any case, Modulift UK Ltd requires its suppliers to characterize, monitor, control and treat waste water and any solid waste in a responsible manner. Records and evidence of treatment procedures should be provided upon request.
4.4. Air Emissions
Air emissions of volatile organic chemicals, aerosols, corrosives, particles, ozone depleting chemicals and combustion by-products generated from operations must be characterized, monitored, controlled and treated as required by applicable laws and regulations before discharge. Regardless of applicable national regulations, Modulift UK Ltd requires its suppliers to characterize, monitor, control and treat air emissions in a responsible manner. Records and evidence of treatment procedures should be provided upon request.
4.5. Pollution Prevention and Resource Reduction
Suppliers must endeavour to reduce or eliminate waste of all types, including water and energy, by implementing appropriate conservation measures in its facilities and throughout its production processes. Furthermore, we expect our suppliers, as a natural part of their own commitment to environmental policies, to consider reusing, recycling or substituting materials with improved environmental properties where applicable. Consideration of environmentally friendly technologies should also be addressed and encouraged where applicable.
Suppliers must obtain, maintain and keep all required environmental permits and registrations and follow the operations and reporting requirements of such permits.
Modulift UK Ltd will not conduct business with any supplier engaged in violations of fundamental human rights. The following practices are therefore considered unacceptable:
The use of bonded and forced labour, including forced prison labour and human trafficking.
Worst forms of child labour, including forced child labour, child prostitution, and other work which is likely to jeopardise the health, safety and morals of children.
Any harsh, inhumane or degrading treatment or punishment of employees.
The exposure of employees to life-threatening work environments, where they have not been informed of the dangers and where protective measures have not been undertaken.
Deliberately causing substantial pollution to air or water or substantial soil contamination.
Any complicity in violations of international humanitarian law and other crimes against the human person as defined by international law, including war crimes, crimes against humanity, genocide, torture, forced disappearances, hostage taking and extrajudicial, summary or arbitrary executions.
Violation of Zero-tolerance Standards
If Modulift UK Ltd has reason to believe that such violations are being committed by a supplier, the business relationship will be terminated immediately. If we have reason to believe that a supplier knowingly operates in violation of fundamental human rights, the supplier will be reported to the proper authorities.