Supplier Conduct
"JBOS Custom" refers to JBOS Custom and its current and former factory, assembly, and production partner operations.
"Supplier" means any company that provides materials, parts, equipment, products, or services to JBOS Custom.
JBOS Custom is committed to ensuring that working conditions in its supply chain are safe, that workers are treated with respect and dignity, and that manufacturing processes are environmentally responsible. Suppliers are expected to operate in full compliance with the laws, rules, and regulations of the countries in which they operate.
This Supplier Code of Conduct draws upon internationally recognized standards in order to advance social and environmental responsibility. JBOS Custom expects first-tier suppliers to implement this Code using appropriate management systems.
Supplier Code of Conduct
This Code is modeled on recognized electronics industry supplier responsibility standards. International Labor Organization Standards, the Universal Declaration of Human Rights, Social Accountability International, and the Ethical Trading Initiative are useful references for the expectations described here.
Labor and Human Rights
Suppliers must uphold the human rights of workers and treat them with dignity and respect as understood by the international community.
Discrimination
Suppliers may not discriminate against any worker based on race, color, age, gender, sexual orientation, ethnicity, disability, religion, political affiliation, union membership, or marital status in hiring and employment practices such as promotions, rewards, access to training, job assignments, wages, benefits, discipline, termination, and retirement.
Suppliers may not require a pregnancy test except where required by applicable laws or regulations.
Harsh Treatment and Harassment
Suppliers must be committed to a workplace free of harassment. Suppliers may not threaten workers with, or subject them to, harsh or inhumane treatment, including sexual harassment, sexual abuse, corporal punishment, mental coercion, physical coercion, or verbal abuse.
Involuntary Labor
Suppliers may not use any form of forced, bonded, indentured, or prison labor. All work must be voluntary and workers should be free to leave with reasonable notice.
Workers must not be required to hand over government-issued identification, passports, or work permits as a condition of employment.
Child Labor
Suppliers may not use child labor at any stage of manufacturing. Workers must be at least the minimum age for employment in that country or the age for completing compulsory education in that country, whichever is higher.
In no event may a worker be less than 16 years old except as permitted by ILO Minimum Age Convention No. 138. Workers under 18 years of age may not perform work likely to jeopardize their health, safety, or morals.
Except in emergency or unusual situations, a work week should be restricted to 60 hours, including overtime, and workers should be allowed at least one day off per seven-day week. Under no circumstances may working hours exceed the maximum set by applicable laws.
Remuneration
Suppliers must pay wages, benefits, and overtime to workers in accordance with applicable laws, including those related to minimum wages, overtime, hours, and legally mandated benefits.
The basis on which workers are paid must be clearly conveyed to them in a timely manner.
Freedom of Association
Suppliers must respect the right of workers to associate freely, join workers' organizations, seek representation, and bargain collectively, as permitted by and in accordance with local laws.
Suppliers may not discriminate with respect to employment based on union membership or participation in lawful union activities.
Health and Safety
JBOS Custom recognizes that integrating sound health and safety management practices into all aspects of business is essential to maintain high morale and produce reliable products. Suppliers must be committed to creating safe working conditions and a healthy work environment for all workers.
Protective Measures
Suppliers must provide appropriate controls, safe work procedures, preventative maintenance, and protective measures to mitigate health and safety risks in the workplace.
When hazards cannot be adequately controlled by these means, suppliers must provide appropriate personal protective equipment. Workers must have the right to refuse unsafe working conditions without fear of reprisal until management adequately addresses their concerns.
Industrial Hygiene
Suppliers must identify, evaluate, and control worker exposure to hazardous chemical, biological, and physical agents. When hazards cannot be adequately controlled by engineering and administrative means, suppliers must provide appropriate personal protective equipment.
Emergency Prevention, Preparedness and Response
Suppliers must anticipate, identify, and assess emergency situations and minimize their impact by implementing emergency plans and response procedures, including reporting, notification, evacuation procedures, worker training, drills, first-aid supplies, fire detection and suppression equipment, adequate exits, and recovery plans.
Occupational Injury and Illness
Suppliers must establish procedures and systems to manage, track, and report occupational injury and illness, including provisions to encourage worker reporting, classify and record cases, provide medical treatment, investigate causes, implement corrective actions, and facilitate return to work.
Physically Demanding Work
Suppliers must identify, evaluate, and control worker exposure to physically demanding tasks, including manual material handling, heavy lifting, prolonged standing, and highly repetitive or forceful assembly tasks.
Dormitory and Canteen
Suppliers must provide workers with clean toilet facilities, access to potable water, and sanitary food preparation and storage facilities. Worker dormitories provided by a supplier or labor agent must be clean and safe and provide emergency egress, adequate heat and ventilation, and reasonable personal space.
Communication
To foster a safe work environment, suppliers should ensure workers receive appropriate workplace health and safety information and training, including written health and safety information and warnings in the primary language of workers.
Worker Health and Safety Committees
Suppliers are encouraged to permit worker health and safety committees to enhance ongoing health and safety education and encourage worker input regarding health and safety issues in the workplace.
The Environment
Environmental considerations are an integral part of responsible business practices. Suppliers must be committed to reducing the environmental impact of their designs, manufacturing processes, and waste emissions.
Conflict Minerals Sourcing
As part of JBOS Custom's commitment to corporate responsibility and respect for human rights, where tantalum, tin, tungsten, and gold are used in products, our goal is that they are procured from sources that do not directly or indirectly finance or benefit armed groups in the Democratic Republic of Congo or adjoining countries.
We expect suppliers to maintain similar policies that enable reasonable assurance that supplied products and components containing conflict minerals are DRC conflict free. If JBOS Custom becomes aware of a supplier whose supply chain includes minerals from a conflict source, we will take appropriate risk mitigation actions consistent with OECD due diligence guidance.
Hazardous Substance Management and Restrictions
Suppliers must comply with applicable laws and regulations prohibiting or restricting specific substances. To ensure safe handling, movement, storage, recycling, reuse, and disposal, suppliers must identify and manage substances that pose a hazard if released to the environment.
Suppliers must comply with applicable labeling laws and regulations for recycling and disposal. Suppliers must post Material Safety Data Sheets for hazardous or toxic substances used in the workplace and train workers who may come into contact with such substances.
Waste water and Solid Waste Emissions
Waste water 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 or disposal.
Air Emissions
Air emissions of volatile organic chemicals, aerosols, corrosives, particulates, 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.
Environmental Permits and Reporting
Suppliers must obtain, maintain, and keep current all required environmental permits and registrations, and follow the operational and reporting requirements of such permits.
Pollution Prevention and Resource Reduction
Suppliers must endeavor to reduce or eliminate waste of all types, including water and energy, by implementing appropriate conservation measures in facilities, maintenance and production processes, and by recycling, reusing, or substituting materials.
Ethics
Suppliers must be committed to the highest standards of ethical conduct when dealing with workers, suppliers, and customers.
Corruption, Extortion, or Embezzlement
Corruption, extortion, and embezzlement in any form are strictly prohibited and may result in immediate termination as a supplier and in legal action.
Disclosure of Information
Suppliers must disclose information regarding business activities, structure, financial situation, and performance in accordance with applicable regulations and prevailing industry practices.
No Improper Advantage
Suppliers may not offer or accept bribes or other means of obtaining undue or improper advantage.
Fair Business, Advertising and Competition
Suppliers must uphold fair business standards in advertising, sales, and competition. Suppliers must offer means to safeguard customer information.
Whistle blowers
Suppliers must create programs to help protect supplier and worker whistleblower confidentiality.
Community Engagement
Suppliers are encouraged to engage the community to help foster social and economic development and contribute to the sustainability of the communities in which they operate.
Protection of Intellectual Property
Suppliers must respect intellectual property rights. Transfer of technology and know-how must be done in a manner that protects intellectual property rights.
Management Systems
Suppliers must adopt or establish a management system designed to ensure compliance with this Code and applicable laws and regulations, identify and mitigate related operational risks, and facilitate continuous improvement. ISO 14001, OHSAS 18001, and Eco Management and Audit System resources may be useful references.
The management system should contain the elements below.
Company Commitment
A corporate social and environmental responsibility statement should affirm the supplier's commitment to compliance and continual improvement.
Management Accountability and Responsibility
Suppliers should clearly identify company representatives responsible for implementation and periodic review of supplier management systems.
Legal and Customer Requirements
Suppliers should maintain a process to identify, monitor, and understand applicable laws and regulations and the additional requirements imposed by this Code.
Risk Assessment and Management
Suppliers should maintain a process to identify environmental, health and safety, and labor practice risks associated with operations, determine the relative significance of each risk, and implement appropriate procedures and controls.
Health and safety risk assessments should include warehouse and storage facilities, plant and facility support equipment, laboratories and test areas, bathrooms, kitchens, cafeterias, and worker housing.
Performance Objectives with Implementation Plans and Measures
Suppliers should maintain written standards, performance objectives, targets, and implementation plans, including periodic assessment of supplier performance against those objectives.
Training
Suppliers should provide appropriate training programs for managers and workers.
Communication
Suppliers should maintain a process for communicating clear and accurate information about performance, practices, and expectations to workers, suppliers, and customers, along with a clear complaint mechanism.
Worker Feedback and Participation
Suppliers should maintain an ongoing process to obtain feedback on processes and practices related to this Code and to foster continuous improvement.
Audits and Assessments
Suppliers should conduct periodic self-evaluations to ensure they and their subcontractors comply with this Code and applicable laws and regulations. JBOS Custom may audit periodically under terms and conditions set forth in supplier agreements.
Corrective Action Process
Suppliers should maintain a process for timely correction of deficiencies identified by internal or external audit, assessment, inspection, investigation, or review.
Documentation and Records
Suppliers should create documents and records to ensure regulatory compliance and conformity to this Code, with appropriate confidentiality measures to protect privacy.
References
JBOS Custom consulted the following references in preparing this Code.
- Eco Management and Audit System
- Electronic Industry Code of Conduct
- Ethical Trading Initiative
- ILO Code of Practice in Safety and Health
- ILO International Labor Standards
- ISO 14001
- National Fire Protection Association
- OECD Guidelines for Multinational Enterprises
- OHSAS 18001
- SA 8000
- United Nations Convention Against Corruption
- United Nations Global Compact
- Universal Declaration of Human Rights
- UN Norms on the Responsibilities of Transnational Corporations and other Business Enterprises with Regard to Human Rights
- OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas
