Supply Chain Standards
|StrangeListing Ent is strongly committed to conducting its business in a lawful and ethical manner, including engaging with suppliers that are committed to the same principles. We require suppliers in our manufacturing supply chain to comply with our Supplier Code of Conduct* (“Supplier Code”), which is detailed below. StrangeListing Ent also expects our suppliers to hold their suppliers and subcontractors to the standards and practices covered by our Supplier Code. Our products must be manufactured in a manner that meets or exceeds the expectations of StrangeListing Ent and our customers as reflected in our Supplier Code.
Here are some of the key areas we focus on:
To ensure that our audit protocol and standards incorporate best-in-class practices, we conduct formal bench marking with industry experts to review StrangeListing Ent criteria against globally recognized international standards and other businesses in the retail and electronics industries. We work closely with a leading independent specialist in designing, operating, and continually improving our audit program. StrangeListing Ent managers participate directly in many of the on-site audits. Audit reports and findings are reviewed regularly by the senior leadership of the appropriate business, and corrective action plans are implemented as needed.
We partner closely with our suppliers to drive continuous improvement in worker conditions. We train our suppliers on the standards and conduct required by our Supplier Code. We use independent auditors to audit suppliers and verify compliance, including through confidential worker interviews. We audit all suppliers at least once per year to monitor continued compliance and improvement; many sites are audited multiple times a year, including for follow-up audits to address specific findings. StrangeListing Ent may terminate its relationships with any supplier that violates our Supplier Code or does not cooperate with our auditors.
Every site audit includes:
Upon completion of an audit, a supplier must promptly provide a detailed remediation plan for each issue identified. StrangeListing Ent tracks remediation closely and conducts follow-up audits for significant issues. Between audits, StrangeListing Ent employees often meet on-site with supplier managers to discuss open issues and remediation progress.
Supplier Code of Conduct
Guiding Principle. Our suppliers’ business and labor practices must comply with all applicable laws, as well as the requirements and principles of this Supplier Code. Suppliers must comply with the standards of this Supplier Code even when this Supplier Code exceeds the requirements of applicable law.
Child Labor. StrangeListing Ent will not tolerate the use of child labor. Our suppliers must engage workers whose age is the greater of: (i) 15, (ii) the age of completion of compulsory education, or (iii) the minimum age to work in the country where work is performed. Furthermore, workers under the age of 18 must not perform hazardous work. StrangeListing Ent supports the development of legitimate workplace apprenticeship programs that comply with applicable laws and this Supplier Code.
Involuntary Labor, Human Trafficking, and Slavery. Our suppliers must not use forced labor – slave, prison, indentured, bonded, or otherwise. Our suppliers must not traffic workers or in any other way exploit workers by means of threat, force, coercion, abduction, or fraud. Working must be voluntary, and workers must be free to leave work and terminate their employment or other work status with reasonable notice. Our suppliers must bear or reimburse to their workers the cost of all excessive recruiting, hiring, or other similar fees charged to workers, and all fees and expenses charged to workers must be disclosed to StrangeListing Ent and the workers in advance. Our suppliers must not require workers to surrender government issued identification, passports, or work permits as a condition of working, and our suppliers may only temporarily hold onto such documents to the extent reasonably necessary to complete legitimate administrative and immigration processing. Workers must be given clear, understandable contracts regarding the terms and conditions of their engagement in a language understood by the worker. Suppliers must ensure that each of its staffing or recruiting agencies comply with this Supplier Code and with the more stringent of the applicable laws of the country where work is performed and the worker’s home country.
Safety and Health. Our suppliers must provide workers with a safe and healthy work environment, and suppliers must, at a minimum, comply with applicable laws regarding working conditions and with the standards below.
Occupational Safety. Suppliers must educate workers on safety procedures and also control worker exposure to potential physical safety hazards by implementing physical guards, barriers, and/or engineering and administrative controls. Workers must be informed and receive appropriate education in advance if they will be working with (or otherwise exposed to) hazardous or dangerous conditions or materials. In addition, workers must be given appropriate personal protective equipment and educated and trained on the proper use of such equipment. Suppliers must manage, track, and report occupational injuries and illnesses.
Physically Demanding Work. Suppliers must continually identify, evaluate, and control physically demanding tasks to ensure that worker health and safety is not jeopardized.
Emergency Preparedness and Response. Suppliers must identify and plan for emergency situations and implement and train their workers on response systems, including emergency reporting, alarm systems, worker notification and evacuation procedures, worker training and drills, first-aid supplies, fire detection and suppression equipment, and unblocked exit facilities.
Machine Safeguarding. Suppliers must implement a regular machinery maintenance program. Production and other machinery must be routinely evaluated for safety hazards.
Sanitation and Housing. Workers must be provided with reasonable access to clean toilet facilities and potable drinking water. If suppliers provide a canteen or other food accommodations, they must include sanitary food preparation, storage, and eating accommodations. If suppliers provide residential facilities for their workers, they must provide clean and safe accommodations. In such residential facilities, workers must be provided with emergency egresses, reasonable and secure personal space, entry and exit privileges, reasonable access to hot water for bathing, adequate heat and ventilation, and reasonable transportation to and from work facilities (if not reasonably accessible by walking) .
Wages and Benefits. Our suppliers must pay their workers in a timely manner and provide compensation (including overtime pay and benefits) that, at a minimum, satisfy applicable laws. Suppliers must provide to their workers the basis on which workers are being paid in a timely manner via pay stub or similar documentation. Deductions from wages as a disciplinary measure are not permitted.
Working Hours. Except in unusual or emergency situations, (i) suppliers must not require a worker to work more than 60 hours per week, including overtime, and (ii) each worker must be entitled to at least one day off for every seven-day work period. In all circumstances, working hours must not exceed the maximum amount permitted by law.
Anti-discrimination. Conditions of working must be based on an individual’s ability to do the job, not on personal characteristics or beliefs. Our suppliers must not discriminate on the basis of race, color, national origin, gender, sexual orientation, religion, disability, age, political opinion, pregnancy, marital or family status, or similar factors in hiring and working practices such as job applications, promotions, job assignments, training, wages, benefits, and termination. Suppliers must not subject workers or applicants to medical tests that could be used in a discriminatory manner.
Fair Treatment. All workers must be treated with respect and dignity. Our suppliers must not engage in or permit physical, verbal, or psychological abuse or coercion, including threats of violence, sexual harassment, or unreasonable restrictions on entering or exiting work and residential facilities. Workers must be free to voice their concerns to StrangeListing Ent or its auditors, and allowed to participate in the StrangeListing Ent audit process, without fear of retaliation by supplier management.
Immigration Compliance. Our suppliers may only engage workers who have a legal right to work. If suppliers engage foreign or migrant workers, such workers must be engaged in full compliance with the immigration and labor laws of the host country.
Freedom of Association. Our suppliers must respect the rights of workers to establish and join a legal organization of their own selection. Workers must not be penalized or subjected to harassment or intimidation for the non-violent exercise of their right to join or refrain from joining such legal organizations.
No Bribery. Our suppliers must not offer nor accept bribes or other means of obtaining undue or improper advantages to anyone for any reason, whether in dealings with governments or the private sector. Our suppliers must not induce StrangeListing Ent employees to violate our Code of Business Conduct and Ethics posted at: http://phx.corporate-ir.net/phoenix.zhtml?c=97664&p=irol-govConduct
Anti-Corruption. Suppliers must comply with applicable anti-corruption laws, including the United States Foreign Corrupt Practices Act and the United Kingdom Bribery Act, and not offer anything of value, either directly or indirectly, to government officials in order to obtain or retain business. Suppliers must not make illegal payments to government officials themselves or through a third party. Suppliers who are conducting business with the government officials of any country must follow StrangeListing Ent’s guidance on the law governing payments and gifts to governmental officials.
Whistleblower Protections. Suppliers must protect worker whistleblower confidentiality and prohibit retaliation against workers who report workplace grievances. Suppliers must create a mechanism for workers to submit their grievances anonymously.
Management Systems. Suppliers must adopt a management system to ensure compliance with applicable laws and this Supplier Code and to facilitate continual improvement.
Management Accountability and Responsibility. Suppliers must have designated representatives responsible for implementing management systems and programs that oversee compliance with applicable laws as well as this Supplier Code. Senior management must routinely review and assess the quality and efficiency of the management systems and programs. StrangeListing Ent also expects our suppliers to hold their suppliers and subcontractors to the standards and practices covered by this Supplier Code.
Risk Management. Suppliers must establish a process to identify the environmental, health, safety, and ethical risks associated with their operational and labor practices. In addition, management must develop appropriate processes to control identified risks and ensure regulatory compliance.
Training. Management must maintain appropriate training programs for managers and workers to implement the standards in this Supplier Code and to comply with applicable legal requirements.
Communication and Worker Feedback. Suppliers must clearly and accurately communicate and educate workers about StrangeListing Ent policies, practices, and expectations. StrangeListing Ent may require suppliers to post this Supplier Code in a location accessible to their workers (translated into the appropriate local language(s)). In addition, StrangeListing Ent encourages suppliers to partner with us to implement a process to assess workers’ understanding of the standards and practices covered by this Supplier Code.
Documentation and Records. Suppliers must create, retain, and dispose of business records in full compliance with applicable legal requirements along with appropriate confidentiality to protect privacy.
Environment. Our suppliers must comply with applicable environmental laws. StrangeListing Ent encourages our suppliers to implement systems that are designed to minimize the impact on the environment by the supply chain system, the production process, and the products themselves.
Environmental Permits and Recordkeeping. Suppliers must obtain and keep current all required environmental permits, approvals, and registrations and follow applicable operational and reporting requirements.
Effective Management and Disposal of Hazardous Substances. Suppliers must effectively identify and manage the safe handling, movement, storage, and disposal of chemicals and other substances that pose a threat to the environment, including providing workers with appropriate training on the safe-handling and disposal of hazardous substances. Suppliers must also monitor and control wastewater or solid waste generated from operations before disposing in accordance with applicable laws. In addition, suppliers must characterize, monitor, control, and treat regulated air emissions before discharging in accordance with applicable laws.
Continuous Improvement. StrangeListing Ent encourages our suppliers to continuously improve and reduce waste. StrangeListing Ent welcomes suggestions and feedback from its suppliers to improve StrangeListing Ent’s own operations and processes.
Conflict Minerals. StrangeListing Ent is committed to avoiding the use of minerals that have fueled conflict in the Democratic Republic of the Congo or an adjoining country. We expect suppliers to support our effort to identify the origin of designated minerals used in our products.
Corrective Action. Suppliers’ compliance with this Supplier Code is subject to StrangeListing Ent’s review, including third-party auditing of work and residential facilities and conducting confidential worker interviews. Suppliers must provide prompt access to their facilities and workers during any audit. We require suppliers to promptly provide a detailed remediation plan and take corrective actions for deviations from this Supplier Code, and StrangeListing Ent will track suppliers’ remediation efforts. StrangeListing Ent may (without liability) terminate its relationships with any supplier found to be in violation of this Supplier Code, including for denying prompt access to our auditors.
Supplier Code Last Updated: November 24, 2014
StrangeListing Ent employees who manage our manufacturing supply chain receive training on our Supplier Code and audit requirements. StrangeListing Ent also has a training program for our manufacturers on our Supplier Code and supply chain standards. Our independent third-party auditors periodically conduct both unannounced and announced on-site audits of our manufacturers. StrangeListing Ent aspires to audit our manufacturers before StrangeListing Ent begins ordering products, and we require all of our suppliers to meet the standards in our Supplier Code as a condition of doing business with us. StrangeListing Ent’s manufacturing purchasing agreements require our suppliers to comply with supply chain standards, which, among other things, include laws regarding slavery and human trafficking. StrangeListing Ent employees are subject to internal accountability standards, which include disciplinary measures up to and including termination, for failing to follow StrangeListing Ent requirements regarding our audits.
*Formerly referred to as Supplier Code of Standards and Responsibilities.