The purpose of this Supplier Code of Conduct (Code) is to articulate our expectations and requirements for all suppliers providing goods and/or services to AirTrunk (we, us, our).
A “supplier” includes our consultants, partners, general contractors, subcontractors, direct suppliers and selected sub-suppliers who provide goods and/or services to AirTrunk.
All our suppliers have a responsibility to monitor compliance with this Code and to notify us of any breaches and take reasonable steps to address, remedy and prevent repetition of any breach of this Code or possible breaches of this Code.
We reserve the right to undertake audits and risk assessments to verify compliance with our Code and expect our suppliers to cooperate and provide supporting evidence as we may reasonably require monitoring and review their compliance.
Our suppliers are expected to adopt or establish a management system to carry out the responsibilities in this Code. The management system will be designed to: (1) ensure executive level accountability for compliance; (2) identify and mitigate operational risks; (3) facilitate continual improvement; and (4) permit anonymous whistleblowing.
Our suppliers shall procure that their employees complete any trainings as required and notified by AirTrunk (including training administered through a third-party training platform) to demonstrate their commitment to and ensure compliance with this Code, applicable laws and regulations and generally recognised standards.
2. Your conduct
We seek to work with businesses whose values match our own. We require our suppliers to comply with all applicable laws and regulations and, in all cases, to meet the standards and principles set out in this Code across all areas of their business. Compliance with such laws, regulations, standards and principles is a material consideration for us in assessing every aspect of our supplier relationships.
Ethics, anti-bribery and corruption
Our suppliers must comply with, and must not knowingly permit anyone to violate, applicable laws relating to anti-bribery, anti-money laundering, anti-corruption, extortion, embezzlement, fraud, tax evasion, antitrust and competition, or similar or related activities. Suppliers must maintain policies and procedures to monitor compliance such laws, to prohibit and prevent the engagement in such activities and to implement enforcement procedures to ensure compliance.
Suppliers must seek to identify and report any conflicts of interest, be it competing personal or professional interests. Our suppliers will avoid even the appearance of conflicts of interest in their work with us.
Our suppliers will maintain a policy reasonably assuring that any conflict minerals (including tantalum, tin, tungsten and gold) in products that they manufacture does not benefit armed groups that commit human rights abuses and must provide due diligence materials to us upon request.
Any offer or exchange of business courtesies by our suppliers, if permissible, must be modest and infrequent, have a legitimate purpose and should never be given to obtain or retain an improper benefit or advantage.
Intellectual Property, Privacy and Confidentiality
Our suppliers will respect and protect intellectual property rights, and will use information technology, software and intellectual assets responsibly.
Our suppliers will protect the privacy of personal information of everyone with whom they do business and comply with all privacy and data protection laws, regulations and standards.
Our suppliers must safeguard confidential and proprietary information to which they have access in connection with their provision of goods and/or services to AirTrunk. They must implement security standards and procedures to ensure that confidential and proprietary information is securely stored, disclosed only on a need-to-know basis and used only for permitted purposes.
Suppliers will not retain confidential and proprietary information beyond the period prescribed under applicable laws or such period as required in order to perform its contractual obligations to us, whichever is more restrictive.
Diversity and inclusion Our suppliers must comply with all applicable anti-discrimination laws, regulations and guidelines, and promote diversity, inclusion and equal opportunity within their own workplace, including in its employment practices (including for recruitment, retention, remuneration, training and promotion).
Health and safety
Our suppliers must comply with all applicable health and safety laws and ensure a safe working environment for its employees and anyone else affected by their businesses.
Our suppliers will provide workers with ready access to clean toilet facilities, potable water, and sanitary food preparation, storage and eating facilities. If our suppliers provide workers with residential facilities and transportation, they must meet local housing and safety standards and residential facilities will be clean and safe, with adequate personal space, entry and exit privileges, emergency egresses, heating and ventilation, and hot water for showering.
Labour
Our suppliers will comply with all applicable employment and labour laws, regulations and fair practices (including on mandated wages and benefits, wage deductions and minimum working age), and shall have policies and procedures in places to support these requirements.
All work must be voluntary, and our suppliers will not use or permit any form of forced, bonded or indentured labour. Suppliers will not unreasonably restrict workers’ freedom to move into, out of or at working facilities.
Except in emergency or unusual situations, for suppliers’ workers paid hourly, workweeks are expected not to exceed 60 hours per week (including overtime) or, if less, the maximum set by local laws, international standards, AirTrunk requirements or in freely negotiated and legitimate collective agreement, and workers should be allowed at least one day off every seven days.
Our supplier’s workers will be permitted to associate freely, bargain collectively and seek representation in accordance with local laws. Suppliers must maintain grievance procedures to allow workers to raise workplace concerns to the attention of management for appropriate resolution without fear of reprisal or harassment.
Human rights Our suppliers, whether directly or through their operations and supply chain, must comply with all applicable human rights related laws in respect of their employees. They must conduct their business activities in a manner which respects human rights and must not hold another person in slavery or servitude, employ, engage or otherwise use forced or compulsory labour, trafficked labour or child labour; nor engage in or permit the use of corporal punishments, harassment, bullying or mentally, physically, verbally or sexually abusive or inhumane treatment of workers, or any other unlawful behaviour towards workers. Our suppliers must have in place adequate procedures to identify, prevent, mitigate and account for modern slavery and other human rights impacts in their operations and supply chains. They must notify us if they become aware of an instance of modern slavery in their operations or supply chains.
Environmental and Sustainability
Our suppliers must comply with all applicable environmental laws and regulations, and continually strive to improve their sustainability performance, focusing on reduction (as appropriate) of waste, hazardous materials, energy efficiency, carbon emissions, water and natural resources consumption.
Our suppliers will comply with AirTrunk’s requirements regarding the prohibition or restriction of specific substances in manufacturing or product design, product and packaging labelling, material content, and recycling, and disposal as directed by AirTrunk.
Our suppliers will obtain and keep current all required environmental permits, approvals and registrations, and follow their operational and reporting requirements.
Our suppliers will track and monitor their consumptions of resources referred to in paragraph 2.8(1).
Our suppliers will monitor, control, treat and reduce hazardous air emissions, wastewater and waste generated from its operations. Our suppliers will adhere to AirTrunk’s specific requirements restricting use of specific substances notified from time to time.
Business Records Our suppliers should honestly and accurately record and report all business dealings and information in accordance with prevailing industry practice and comply with all applicable laws regarding their completion and accuracy. Their business records must be created, retained and disposed of in compliance with record retention policies and all applicable laws and regulations.
Questions & Concerns For any question or concern about proper conduct or the content of this Code, our suppliers are encouraged to promptly raise the issue with their primary AirTrunk contact to resolve it. If that is not possible for appropriate, please contact AirTrunk Head of Risk & Sustainability or use the whistleblowing process set out in AirTrunk’s Whistle-blower Policy (available on AirTrunk’s website).
