SUPPLIER CODE OF CONDUCT
INTRODUCTION
Fort Garry Industries has a long-standing reputation for integrity and trustworthiness among its stakeholders. The Company’s reputation depends upon how it conducts its business and its commitment to corporate social responsibility. As one of Canada’s most trusted companies, Fort Garry Industries’ actions must be above reproach to maintain its stakeholders' confidence and avoid damage to its reputation.
The Supplier Code of Business Conduct is not just a document but a crucial tool designed to ensure that suppliers clearly understand how Fort Garry Industries expects to conduct its business with them.
The Company expects full compliance with all principles and processes related to this Supplier's Code of Business Conduct. Non-compliance may result in termination of the business relationship. All suppliers to Fort Garry Industries must carefully review the commitments in this Code and agree to abide by the commitments as a condition of doing business with the Company.
APPLICATION
This Code applies to the Company’s suppliers and sub-suppliers, including suppliers to the Company’s divisions and subsidiaries. Suppliers are defined as businesses that sell goods and/or services to the Company.
Employees who engage either merchandise or non-merchandise suppliers (e.g., services) are responsible for ensuring that suppliers review, sign, and commit to complying with the Company’s Code of Business Conduct for Suppliers.
FORT GARRY INDUSTRIES PRINCIPLES OF BUSINESS CONDUCT
Fort Garry Industries employees – and this Code of Conduct – are guided by the following principles of ethical business practice:
- comply with applicable laws, regulations, Company policies and procedures.
- respect the lives, rights, privacy, and property of others.
- avoid conflicts of interest in decisions that we determine or influence.
- conduct duties and business relationships honestly, fairly, and responsibly.
- sustain a culture in which ethical conduct is valued and recognized.
- maintain safe, healthy, and secure work environments.
- sustain responsible trading practices with all suppliers to promote decent, legal, and humane working conditions.
- manage compliance with the Supplier Code of Business Conduct as any other critical business activity.
Conflict of Interest
Participation in other businesses, organizations, or activities that compromise the employment relationship or disadvantage FGI will be considered a conflict of interest.
Examples of conflict of interest include, but are not limited to:
- Having a vested interest in an external business that may provide materials or services to FGI.
- Being offered services or materials as a result of your employment or position within FGI.
- Using a position with FGI to solicit service or materials for personal gain or sponsorship.
- Utilizing FGI equipment, services, or materials for personal use or an external business, personal event or personal benefit.
- Endeavour to induce any customer or supplier of FGI with whom you have a relationship or received information by virtue of or in connection with your employment with FGI to disrupt or terminate their relationship with FGI.
EXPECTATIONS OF SUPPLIERS
This section sets out the Company’s specific expectations regarding the workplace standards and business practices of its suppliers. These expectations are consistent with the Company's values, principles and policies regarding ethical business conduct.
The Company will seek to identify and engage suppliers who conduct their business based on a set of ethical standards compatible with its own. The Company will not knowingly do business with suppliers who do not meet the standards outlined in this Code.
Compliance with Laws
Suppliers will comply with the laws and regulations, whether domestic or foreign, which govern the conduct of their businesses.
Employment Standards
Suppliers will employ employees who are, in all cases, present voluntarily, not put at risk of physical harm due to their work environment, fairly compensated, and allowed the lawful right of free association.
Wages and Benefits
Suppliers will, at a minimum, provide wages and benefits that comply with the laws of their country of operation.
Working Hours
Suppliers will not exceed prevailing local work hours except where workers are appropriately compensated for overtime.
Child Labour
Suppliers will not employ child labour in any of their facilities. Suppliers' employees can be no younger than the age at which compulsory schooling has ended (except for legal student employment), but in no case younger than 141 years of age.
1As set by the International Labour Organization and adopted by Retail Council of Canada in their Responsible Trading Guidelines.
Forced or Slave Labour
Suppliers will not use forced or slave labour. Discrimination/Human Rights Suppliers must not discriminate against their employees in hiring practices or any other term or condition of work (other than legitimate occupational requirements allowed by law) on the basis of race, ancestry, place of origin, colour, ethnic origin, citizenship, religion, faith, political opinion, sex, sexual orientation, age, marital status, same-sex partnership status, family status or disability.
Disciplinary Practices
Suppliers will not use corporal punishment or other forms of mental or physical coercion.
Workplace Environment
Suppliers will provide workers with a safe and healthy working environment consistent with all applicable laws and regulations.
Environmental Protection
Suppliers will comply with all applicable environmental laws and regulations in their country and laws that govern the importation and sale of products in Canada, as well as all applicable Fort Garry Industries policies.
Confidentiality and Privacy
Suppliers will not disclose to others or use for their own purposes or the purposes of others any trade secrets, confidential information, knowledge, designs, data, skill, or any other information that the Company identifies to the supplier as confidential.
Fort Garry Industries must approve all confidentiality agreements that are required by suppliers.
In accordance with the intent of the Company’s Privacy Policy, suppliers will respect the privacy of personal information they collect, use, or disclose as a consequence of their business relationship with the Company.
Unlawful Payments
Suppliers will not offer or accept unlawful payments. Dealing with the Company’s Employees Fort Garry Industries expects its employees to treat all suppliers or those seeking to do business with the company with honesty, integrity, and respect. Employees must never be put in a position where personal or financial incentives or interests may impair their judgment and ability to make decisions in the company's best interest.
It is never acceptable for an employee to pay or accept a bribe, kickback, or other unlawful payment or benefit from securing a concession, contract, or other favorable treatment.
Sub-suppliers
Suppliers will certify that their sub-suppliers of materials or finished goods used in the manufacture of finished goods for the Company comply with a set of ethical standards compatible with this Supplier Code of Business Conduct. Proof of certification must be presented upon request.
Products and Services
Suppliers will supply only products and/or services that comply with the Company’s specifications and comply with all applicable Canadian legal requirements. Suppliers will supply only products and/or services that, when used as intended, are safe for employees, consumers, and the environment. Suppliers will cooperate fully with the Company and take appropriate steps, including notification of the Company’s customers and public product recalls, to address any health, safety, environmental or regulatory issues associated with their products and/or services.
SUPPLIER CERTIFICATION
All suppliers will certify that they have read this Supplier Code of Business Conduct and agree to abide by it. Suppliers will either complete the attached form or sign a contract with the Company incorporating the Supplier Code of Business Conduct.
Fort Garry Industries will determine the frequency of certification.
SUPPLIER ASSESSMENT AND MONITORING
REPORTING AND ADDRESSING CODE VIOLATIONS
Any person who believes that a violation of the Company’s Supplier Code of Business Conduct has occurred is asked to report the relevant information in confidence to FGI's Privacy Officer at (204) 632-8261 or via email at privacy@fgiltd.ca
The Company will make every effort to investigate all reported violations discreetly, fairly, and confidentially and will take appropriate action to maintain the integrity of its business.
QUESTIONS
Suppliers should direct any questions they may have regarding the Supplier Code of Business Conduct to the Company employee with whom they normally deal or FGI’s Purchasing Manager.