Videri Partner Code of Conduct

Introduction

Videri Inc. (together with our subsidiaries, “Videri” or “we”) is committed to compliance with applicable laws, social responsibility, environmental protection and fair cooperation as the guiding principles of all that we do. Our objective is to balance our economic, environmental, and social responsibilities.

This Supplier Code of Conduct forms the basis of all business relationships with Videri and applies to our direct business partners and their affiliates, agents and representatives (hereinafter collectively “Partners”).

Partners accept the points below and are responsible for complying with them. Partners shall also inform theirsuppliers of goods and services (hereinafter “Suppliers”) of all principles and requirements described herein, require them to comply with them and to pass on the commitment to compliance throughout their supply chain. Partners shall take this Code of Conduct into account when selecting their Suppliers.

This Code of Conduct is intended to address compliance with all applicable laws, rules and regulations – particularly those relating to permits, working conditions, wages, employee health and safety, human rights, the environment, climate, and supply chain due diligence obligations.

This Code of Conduct is based on the core principles as set out in the Business Social Compliance Initiative (BSCI), the conventions of the International Labor Organization (ILO), the United Nations Universal Declaration of Human Rights, the U.N. Convention on the Rights of the Child and the U.N. Conventions for Elimination of All Forms of Discrimination, the principles of the U.N. Global Compact as well as the OECD Guidelines for Multinational Enterprises.

The principles set forth in this Code of Conduct are to be regarded as minimum standards. Where required by applicable laws and regulations, higherstandards will be met and maintained. Partners may also introduce higher standards at any time.

Discrimination

Partners will not subject any workers to any discrimination in employment, including hiring, salary/wages, benefits, promotion, discipline, termination or retirement, based on gender, race, color, religion, caste, age, disability, sexual orientation, maternity or marital status, nationality, political opinion, union membership or social or ethnic origin.

Respectful Conduct

  • Partners will undertake disciplinary action only in accordance with the law.
  • Partners will treat all workers with respect, dignity and fairness. No workershall be subjected to any physical, psychological, sexual, verbal abuse or harassment. 
  • Partners will not resort to corporal punishment, violence or intimidation against any worker.

 

Forced Labor

  • Partners will not tolerate any form of forced or compulsory labor, servitude, modern slavery orsimilar working conditions and implement appropriate safeguards against the mistreatment of individuals in their business.
  • Partners will not require their workers to deposit original identification, travel documents or other important documents as a condition of employment.
  • Partners will permit any worker to leave the employment after a reasonable and agreed period of notice or at least the legal period of notice.
  • Partners will not hold back any wages or a part thereof in order to exercise pressure on any worker to continue the employment.
  • If Partners recruit foreign contract workers, Partners will not require them to remain in employment for any period beyond the legal period of notice against their will. A copy of the contract will be given to foreign contract workers in a language understood by them. Partners will not require workers to pay any fee to a recruitment agent.

Child Labor

  • Partners will not tolerate child labor. The minimum age for hiring will not be less than 15 years or the legal minimum age – whichever is higher.
  • Compliance with all laws applicable to the employment of young workers regarding employment restrictions for hazardous, unsafe and unhealthy operations, working hours, wages, working conditions and appropriate documentation will be ensured and documentation will be available upon request.
  • Partners will have a written recruitment policy and a system to verify the age of workers and will maintain appropriate and reliable proof of age for all workers.

Wages & Benefits

  • Partners will pay at least the legal minimum wage, regularly and at the agreed point of time.
  • Partners will pay the statutory social security/insurance contributions for eligible workers.
  • Trainees and apprentices will receive wages in accordance with applicable laws.
  • Any deductions from wages will be made in accordance with the law. There will be no punitive deductions from the wages of workers.
  • Partners will pay overtime wages as mandated by the law. The hourly rate of wage for overtime will be higher than the ordinary rate of wage.
  • The overtime premium for piece rate workers will be calculated in accordance with the law. In the absence of a relevant regulation, itshall be calculated in a way that meets the legal overtime premium rate meant for fixed rate workers.
  • Partners will maintain a copy of all required records according to legal regulations relating to contract workers for inspection.
  • Partners will not endeavor, beyond a reasonable level, to employ contract workers, trainees or apprentices in order to avoid payment of certain benefits, which may have to be granted to regular workers.
  • Partners will provide paid annual leave, holidays and other leaves such as maternity leave or medical leave as prescribed by the law.
  • Bonus-, pension- and retirement benefits will be paid as mandated by the law.
  • Partners will provide an understandable wage statement to every worker for each wage cycle in the form prescribed by the law. The wage statementshould indicate at least the days worked, wage or piece rate earned, allowances if any, social security/statutory deductions, incentives/bonuses, and overtime wage if any.

Working Hours

  • Working hours will comply with the applicable law.
  • In countries where the local law restricts working overtime, Partners will follow the local law. Irrespective of local regulations, Partners will not require workers to work in excess of 60 hours per week including overtime on a regularly scheduled basis.
  • Partners will comply with any local laws and regulations regarding worker overtime/night shifts, including in particular those relating to pregnant or young workers. Partners will take the necessary measures for the safety of all workers when overtime or night shifts are required.
  • Overtime work shall be strictly voluntary. Workers will have the right to refuse overtime work without any threat of punishment.
  • Workers will have at least one day off per week. If a worker is required to work on the worker’s weekly day off due to any business reasons, Partners will allow a compensatory day off within the next three days or as stipulated by local law. In any case, no worker will be required to work for more than 13 days without being given a day off.
  • Nursing mothers will be permitted reasonable breaks to feed their babies without any deductions.
    Pregnant workers will be given reasonable breaks.

Health & Safety

  • Partners will comply with all local regulations relating to the health and safety in the workplace.
  • Partners will operate to ensure healthy, humane and productive working conditions including adequate lighting, air circulation, ventilation, heating/cooling of the workplace.
  • A risk assessment for each working place will be performed when required by law. Itshall be repeated on a regular basis, in any case in the event of relevant changes to the working environment and when accidents have occurred. Adequate protection will be provided from fire, accidents, toxic materials, chemical spillage, dangerous machinery parts and electrical risks. Workers will be provided appropriate personal protective equipment according to the risk assessment – such as gloves, aprons, masks, goggles, earplugs, headgear and rubber boots – free of cost. Workers will be given necessary training to use the personal protective equipment.
  • Partners will place at least one adequately stocked first aid kit on each floor of each building in a designated area which is clearly marked. An adequate number of workers will be trained in basic first aid.
  • Partners will store hazardous substances in safe, secure, separate and ventilated areas with appropriate labelling. Partners will post a list of all hazardous substances used in the facility/workplace mentioning applicable first aid for the information of workers.
  • Partners will have procedures in place to ensure pregnant workers are not required to perform tasks that can be unsafe or unduly strenuous for them.
  • The workplace will have clearly marked adequate exits for emergency evacuation of workers. Evacuation routes will be posted in all work areas. Evacuation assembly points will be clearly marked.
  • All escape doors will be kept unlocked and aisles, exits and stairs will be free from any obstruction during working hours to facilitate an emergency evacuation. All aisles, exits and stairwells will have emergency lights.
  • Partners will train an adequate number of workers in using emergency equipment, such as fire extinguishers. The training will take place at least once a year for each shift.
  • The workplace will be equipped with a sufficient number of suitable fire detectors and fire extinguishers in all sections/floors. Fire extinguishers will be readily accessible and easily identifiable.The location of fire extinguishers will be marked and free of obstructions. Fire detectors and fire extinguishers will be inspected and maintained periodically. Regular fire drills will be conducted and documented in accordance with legal requirements, but at least once a year.
  • All machinery will be equipped with suitable operational safety devices. A maintenance log will record inspections and services which are required at least once a year.
  • Workers will not exceed the maximum allowed time according to local regulations in an area with high noise level. Partners will comply with all applicable laws and regulations relating to noise levels in the workplace.

Hygiene

  • Partners will provide safe drinking water for all workers with adequate access to it throughout the working day.
  • The workplace will have an adequate number of clean toilets/bathrooms with running water for all workers allowing adequate access to them throughout the day.
  • If provided, the company canteen and break rooms will be kept clean ensuring general hygiene and comfort.

Freedom of Association

  • Partners will recognize and respect the right of workers to lawfully form and join trade unions or associations of their own choice and to bargain collectively.
  • Partners will facilitate a parallel independent mechanism to enable workers to organize and bargain collectively if the local law prohibits formal trade unions.
  • Partners will notsubject any workers to any discrimination, victimization, intimidation, penalty or any other threat to restrict and interfere with their right to associate.
  • Partners will not directly or indirectly force or influence any worker to join or not to join a particular union.

Environment Protection

  • Partners will comply with all applicable environmental rules, laws and regulations.
  • Partners will have an Environment Management System (EMS) and a disaster management plan to deal with any environmental emergency.
  • Partners will dispose of all waste material, by-products and hazardous pollutants in an environmentally responsible manner. If applicable due to the nature of the processes used, Partners will have a waste, emission and/or wastewater treatment plant conforming to applicable law.
  • Partners will minimize waste and maximize recycling to protect and conserve the natural environment.

Energy Efficiency

  • Partners will commit to achieving third-party certification to a nationally adopted version of ISO 50001 or demonstrating ongoing energy performance improvements which meets, at a minimum, options 1,2 or 3 below:
    • Option 1: Annual past facility energy performance improvement of at least 2.5% calculated as the change in average annual facility energy performance61 over a period of the most recent 3 to 5 years. Energy performance improvement shall be demonstrated by providing an ENERGY STAR Challenge for Industry Statement of Energy Improvement.
    • Option 2: Annual past facility energy performance improvement of at least 2.5% calculated as the change in average annual facility energy performance over a period of the most recent 3 to 5 years. Energy performance improvement shall be demonstrated by documentation of energy performance improvement showing energy savings calculations, using an Accepted Measurement and Verification Method.
      • Where the supplier has data indicating that relevant variables significantly affect energy performance (e.g., production, weather), the organization is required to normalize energy performance to those relevant variables.
    • Option 3: Third-party certification to ANSI/MSE 50028-1: Superior Energy Performance 50001
      • Program – Additional Requirements for Energy Management System 5, or a nationally adopted equivalent program, and average annual facility energy performance improvement of at least 1.0% per year over a period of 12 to 36 months, achievement periods in monthly increments between 12 and 36 months are allowable.

Bribery and Corruption

  • Partners will comply with all applicable anti-bribery and anti-corruption laws.
  • Partners will not tolerate any form of and shall not engage directly or indirectly in any form of corruption or bribery, and shall not grant, offer or promise anything of value to a public official or to a counterparty in the private sector to influence official action or obtain or retain business or secure some other improper advantage.

Supply Chain Due Diligence

  • Partners will comply with all obligations arising from supply chain due diligence laws (e.g., LKSG (DE), Duty of Vigilance Law 2017 (FR), The Modern Slavery Act 2015 (UK), The Modern Slavery Act 2018 (AU)) with respect to the protection of human rights and environmental obligations specified therein and ensure compliance by their direct and indirect suppliers.
  • Partners will integrate supply chain due diligence obligations into their corporate policies, establish clear internal responsibilities, conduct annual risk analyses of their supply chain, conduct necessary inspections within their supply chain, take appropriate preventive and/or remedial actions related to the identified risks, establish a complaints system and a system to review and document the effectiveness of their actions taken.

Monitoring and Management

  • Partners will ensure the enforcement of the principles set out in this Code of Conduct throughout their organization and supply chain. To comply with and monitor these principles, Partners will establish a management system that includes clear responsibilities and procedures, ongoing monitoring and appropriate documentation of the same.
  • Videri or third parties authorized by Videri (who are subject to confidentiality obligations) are entitled to verify compliance with this Code of Conduct at a Partner’s premises after prior notice.
  • The contents of this Code of Conduct will be freely available to all of Partner’s workers. Partners will ensure that every worker fully understands the contents of this Code of Conduct.
  • If violations of this Code of Conduct are identified, Partners will take prompt remedial action and inform Videri.
  • We have the right to terminate the business relationship with Partners if they violate the principles of this Code of Conduct.