AMB Supply Chain Code of Conduct
MISSION
The AMB Supply Chain Code of Conduct is aligned with the AMB Code of Conduct, these documents ensure that all our business partners, suppliers, and manufacturers meet our basic expectations of doing business related to legal requirements, ethical practices, human rights, and environmental management.
AMB philosophy requires to only engage with employees, commercial intermediaries, suppliers, and other partners who act in a way consistent with our shared commitment to ethical business practices and compliance with laws. Especially, we expect our suppliers to consider the present Code and share it with their employees.
This supplier code of conduct is created for the purpose of ensuring that AMB’s suppliers adhere to high standards of safe working conditions, fair and respectful treatment of employees, and ethical practices.
CONTENTS:
POLICY REQUIREMENTS (introduction)
Ethics and Social Responsibility ……………………………………………………..
Labor and Employment Rights ……………………………………………………….
Environmental Health and Safety…………………………………………………..
Review and documentation policy …………………………………………………….
POLICY REQUIREMENTS (introduction)
AMB SPA requires all our directors, officers, and employees along with those working on our behalf to comply with all laws and to act ethically and with integrity at all times. Working together we will build a sustainable business relationship that will enable us all to be successful. At the same time, we require our supply chain partners to adhere to these principles and to reflect these same principles upon their suppliers.
Our supply chain partners must:
- comply with all applicable laws, regulations, and industry requirements;
- comply with and promote the Ethic and Social Responsibly Principles which aspire to be the leading standard on worker welfare;
- manage their operations so any potential negative impact to the environment or community is prevented or minimized where unavoidable;
- provide a safe and healthy work environment for their employees and must provide adequate training, work procedures, and appropriate personal protective equipment.
ETHICS AND SOCIAL RESPONSIBILITY
Anticorruption (FCPA, UK Bribery Act, Principle 10 – UN global compact)
Supplier should work against all forms of corruption, including extortion and bribery (Principle 10).
It must not be tolerated or permitted engaging in bribery, embezzlement, extortion, kickbacks or other forms of corruption. Supply chain partners shall not offer or give anything of value to a foreign official, a foreign political party official, a foreign political party or a candidate for foreign political office that might be considered a bribe and shall make accurate and complete entries in its records following generally accepted accounting procedures as required by local law and will not will not accept any payment or other benefit as an inducement or reward for any act or forbearance or in connection with any matter or business transacted by or on behalf of AMB.
Transparency
The Supplier conducts business honestly, fairly and free from any bribery or corruption.
The Supplier should undertake to:
- prevent any conflict of interest between the Parties;
- not to accept or offer bribes, preferential payments or any valuable object for the purpose of obtaining or entertaining business or any undue benefits or advantages, having to comply, in general, with existing anti-corruption legislation;
- comply with all rules and regulations, including those provided by the Company, relating to the safety and quality of products and services;
- disclose with transparency and accuracy the details of its business operations, organizational structure, economic situation and performance in accordance with the laws and regulations in force, in particular disclose conditions that may be in conflict with the Policy or any applicable regulations or laws in facilities that manufacture, inspect, package, store or handle AMB goods;
- disclose in advance any relationship with any AMB director, officer or employee, or any other person or entity working with AMB that represents or might appear to represent a conflict of interest.
- Supply chain partners must also have in place adequate policies and procedures designed to effectively prevent bribery, corruption and facilitation of tax fraud. It is avoided offer any incentive to any AMB director, officer, employee, or such person’s family or friends in order to obtain, retain, or influence AMB business. Any involvement by a Supplier in any conflict may be grounds for a termination of business relationship.
LABOR AND EMPLOYMENT RIGHTS
The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.
The Supplier should undertake to the below human rights principles:
- support and respect the protection of internationally proclaimed human rights (principle 1);
- should ensure that their own operations are not complicit in human rights abuses (principle 2);
- respect human rights and not be complicit in human rights violations;
- be active to resolve any human rights violations.
The Supplier should uphold to the below labor principles:
- the effective abolition of child labor (Principle 5):
to be compliant with the minimum employment age limit defined by national law or by International Labor Organization (“ILO”) Convention 138, whichever is higher. The ILO Convention 138 minimum employment age is the local mandatory schooling age, but not less than 15 years of age (14 in certain developing countries), subject to exceptions allowed by the ILO and national law not to employ persons under the age of 18, or the minimum age under national law, whichever is higher (in line with ILO Convention 138 on Child Labour);
- the elimination of forced or compulsory labor (Principle 4):
not use any form of forced labor, which means any work or service performed involuntarily under threat of penalty.
- the freedom of association and the effective recognition of the right to collective bargaining (Principle 3):
recognize the rights of employees to form and/or join unions and bargain collectively. Supplier shall not retaliate or discriminate against any employee choosing to exercise their right to do so;
- the elimination of discrimination in respect of employment and occupation (Principle 6):
- not to discriminate against any employee or potential employee in compliance with AMB’s ethic principles;
- be inclusive and ensure that their employees and other stakeholders are always treated with dignity and respect as well AMB believes in the value of diversity and is committed to actively creating an environment where each team member feels empowered to learn, grow, and maximize his/her personal contribution;
- provide a workplace free from harassment, which can take many forms, including sexual, verbal, physical or visual behavior that creates or could create an offensive, hostile, or intimidating environment.
Economic rights
Supplier shall provide employees with wages and benefits that meet the minimum required amount by applicable laws/regulations. In countries where no minimum wage law applies, employees shall be paid at a rate comparable to the prevailing industry average. Supplier is expected to pay personnel in legal tender, on a regular basis, and in a timely manner. All wages and benefits should be paid in a regular, timely manner in accordance with contractual agreements.
The Supplier will maintain a reasonable overall pattern of required working hours and days off for its employees so that total work hours per week do not regularly exceed industry norms, working time shall not exceed 48 hours per week.
Anti-human trafficking
The Supplier declares that no materials supplied to AMB are produced directly or indirectly by means of slavery or human trafficking.
The Supplier shall be Compliant with all applicable labor laws including the Modern Slavery Act 2015 of the United Kingdom and the Australian Modern Slavery Act 2018.
The Supplier declares to be compliant with AMB ANTI HUMAN TRAFFICKING policy, to which reference is made. (section MODERN SLAVERY (ANTI HUMAN TRAFFICKING) POLICY https://www.ambpackaging.com/modern-slavery-policy/).
ENVIRONMENTAL HEALTH AND SAFETY
For AMB Environmental protection is a primary value, starting from the management of daily activities up to its operational choices. Supplier shall comply with all environmental laws and regulations and should work to promote and improve:
- “Energy saving”
- “Waste management”
- the correct re-use of recyclable products
- profitable use of the resources.
- Transportation technology (to ensure that new technologies get more people (or things) to their destination faster, safer and with the fewest amount of resources possible)
The Supplier should uphold to the below Environment Principles:
- Support a precautionary approach to environmental challenges (Principle 7);
- initiatives to promote greater environmental responsibility (Principle 8);
- encourage the development and diffusion of environmentally friendly technologies (Principle 9).
The Supplier is requested to actively collaborate in environmental management and the continuous improvement of environmental protection, according to the AMB’s policy.
Supplier shall provide its employees with a safe and healthy working environment in accordance with applicable local and national laws which shall include appropriate protection from exposure to hazardous materials and access to potable water and clean sanitation facilities.
REVIEW, MONITORING AND DOCUMENTATION POLICY
The AMB Supplier Code of conduct signature is integrated into AMB procurement decisions.
On request, Supplier will furnish AMB with relevant information and data to support its compliance with this Code.
Supplier is obligated to communicate changes to their product, process, manufacturing location, and/or service with AMB.
If a Supplier becomes aware of any violation of these guidelines by any of its employees, officers, or representatives or any employee, officer, or representative of AMB, the Supplier should report such violation to AMB’s email address: sustainability@ambpackagng.com
AMB reserves the right to verify by audit or other means each Supplier’s compliance with the Code. In cases where AMB becomes aware of any actions or conditions not in compliance with the Code, AMB reserves the right to demand corrective measures or terminate an agreement with any Supplier that does not comply with the Code.
Supplier shall allow AMB to conduct quality and compliance systems audits at Supplier’s facility. Supplier shall provide access to information pertaining to personnel, facilities, records, and control documents relevant to the supply of products and raw materials to AMB.