Ethical Trade Policy

DecoPac, Inc. (“DecoPac”) requires each supplier (“Supplier”) to comply with this Ethical Trade Policy (the “Policy”) in its manufacturing, producing or supplying of any goods or services described in any DecoPac Purchase Order (the “Goods”). For the purposes of this Policy, any purchase order, invoice, or other similar document used for the purchase of the Goods shall collectively be referred to as a “Purchase Order”.

Supplier shall comply with all applicable labor and employment laws and regulations including but not limited to the Federal Fair Labor Standards Act (or any foreign or international equivalents) and the Workplace Code of Conduct of the Fair Labor Association. Supplier shall maintain and adhere to the highest standards of ethical business practices, and at minimum, regardless of permissions granted under applicable law, Supplier agrees to the following:

1. No Forced Labor. Supplier shall not permit the use of forced or involuntary labor, whether prison, bonded, indentured or otherwise, or modern slavery, of any kind. All work must be voluntary, and personnel of Supplier shall be free to leave work or terminate their employment with reasonable notice. Supplier personnel must not be required to surrender any government issued identification, passports, driver’s license, work permits, or similar as a condition of employment. Supplier must comply with all aspects of applicable laws and regulations related to forced or involuntary labor, or modern slavery, including the Modern Slavery Act of 2015.
2. No Child Labor. Supplier shall not engage in the use of child labor, and shall not employ any personnel below the applicable minimum age requirement in the jurisdiction in which the Goods are manufactured, processed, or otherwise supplied; provided, however, that, under no circumstances shall Supplier permit anyone under the age of fifteen (15) years old to work for Supplier.
3. Health and Safety. Supplier shall comply with applicable laws and regulations regarding occupational health and safety, as well as to ensure Supplier personnel have a clean, safe, and healthy work environment. At minimum, Supplier shall provide its personnel with sanitary facilities in proper working order including potable water and toilet, fire safety and prevention, adequate lighting, proper ventilation, proper equipment maintenance, adequate evacuation plans, and proper training of personnel to cover potential hazards that may be encountered in their scope of work. All work environments must meet all applicable building codes and construction standards, as well as zoning and use permits. If Supplier provides residential facilities or living accommodations to its personnel, Supplier shall ensure these same standards apply to such residential facilities or living accommodations. Supplier shall commit to a working environment free of harassment or abuse, regardless of form of such harassment or abuse. Suppliers shall not threaten, use, or permit the use of corporal punishment, physical, sexual, psychological or verbal harassment, threats of violence, or other forms of physical or mental abuse, intimidation, or coercion. Supplier shall comply with and commit to adhering to all applicable human rights standards for the jurisdiction in which it operates.
4. Non-Discrimination. Supplier shall employ or contract with personnel on the basis of their ability to perform the designated scope of work, rather than on the basis of race, ethnicity, nationality, gender, sex, age, sexual orientation, disability, political affiliation, social origin, religion, cultural beliefs, marital status, maternity, or similar factors. Supplier shall ensure that all personnel receive equal treatment in all aspects of employment or the work environment.
5. Working Hours. Supplier must comply with applicable laws and regulations governing maximum hours of work and overtime for personnel. Where applicable law does not limit the hours of work, Supplier shall not require personnel to work more than the regular work week in such jurisdiction (not to exceed forty-eight (48) hours per week) plus twelve (12) hours of overtime. Supplier personnel shall be entitled to at least one full working day off in every seven (7)-day period.
6. Wages and Benefits. Supplier shall fairly compensate its personnel in compliance with applicable laws and regulations. In jurisdictions where applicable law does not provide for overtime compensation, Supplier shall pay personnel at minimum the personnel’s regular wages for overtime work. Supplier shall provide all other legally mandated benefits.
7. Collective Bargaining & Freedom of Association. Supplier shall permit personnel to, and recognize and respect the rights of personnel to, peacefully, lawfully, and freely associate, organize, and bargain collectively in accordance with applicable laws and regulations. Supplier shall not interfere with, obstruct, or prevent such legitimate and lawful activities. Supplier personnel shall not be subject to intimidation or harassment in the rightful exercise of their legal rights to join or to refrain from joining an organization.
8. Environmental Standards. Supplier shall comply with all applicable environmental laws, regulations, and policies, and the protection and preservation thereof. Supplier shall commit to reducing the environmental impact of their operations including but not limited to elimination of the use of toxic or hazardous substances from the production process and reducing the impact of waste emissions.
9. Anti-Bribery and Anti-Corruption. Supplier shall comply with applicable anti-bribery and anti-corruption laws, including but not limited to the U.S. Foreign Corrupt Practices Act of 1977 (FCPA) and the U.K. Bribery Act 2010. Supplier represents it will not receive nor offer any illegal or improper bribe, kickbacks, payment, gift or thing of value for the purpose of achieving an undue or improper advantage over competitors or other businesses. Supplier must maintain and adhere to fair business standards in advertising, sales, and competition, including compliance with applicable laws and regulations for such standards.
10. Export Controls and Economic Sanctions. Supplier shall comply with the U.S. Export Administration Regulations, the International Traffic in Arms Regulations, the sanctions and regulations administered by the Office of Foreign Assets Control, and any other applicable export laws, restrictions, and regulations (collectively, “Export Controls”) to ensure no products or services offered under this Agreement are (a) exported, re-exported, or transferred in-country directly or indirectly in violation of Export Controls, or (b) used by any person and/or for any purposes prohibited by Export Controls. Supplier will not, directly or indirectly, deliver DecoPac products or related items thereto to (i) an individual, entity, country or region identified on the Consolidated Screening List, available at https://www.trade.gov/consolidated-screening-list, (ii) an individual or entity in Russia or Belarus ((i) and (ii) collectively, “Sanctions Target”), or (iii) to any party that is 50% owned by one or more Sanctions Target. Supplier represents that it is not a Sanctions Target, and it is not otherwise prohibited (based on 50% ownership, location for operations or use or other legally relevant factors) from providing products or services, as applicable, without a license or other approval under Export Controls.

Supplier shall maintain documentation and records to demonstrate compliance with the foregoing and shall make such documentation and records available for DecoPac’s review at any time and upon DecoPac’s request. Supplier shall cause any of its subcontractors, vendors, or suppliers to comply with the provisions set forth in this Policy, and shall remain responsible for the acts or omissions of such parties under this Policy.