Responsible and Ethical Sourcing Policy
Responsible and Ethical Sourcing Policy
- Purpose
We are committed to conducting business responsibly and ethically. This Responsible and Ethical Sourcing Policy outlines our expectations for suppliers, contractors, and service providers to ensure that goods and services are sourced in a manner that respects human rights, promotes fair labor practices, protects the environment, and upholds ethical business conduct. The Company recognizes that responsible sourcing is an ongoing process and seeks to continuously improve its practices in line with evolving legal requirements and responsible business standards. This policy supports our broader commitments under our Code of Conduct and our Modern Slavery and Human Trafficking Statement.
- Scope
This policy applies to all suppliers, vendors, contractors, consultants, and service providers engaged by the Company. It covers all sourcing and procurement activities and applies in all jurisdictions in which the Company operates or sources goods and services. Suppliers are expected to apply the principles of this policy in their own operations and, where appropriate, to promote similar standards within their supply chains.
- Core Principles
We expect our suppliers to operate in accordance with the principles set out below and to take reasonable steps to ensure that these principles are embedded within their business practices and decision-making processes.
3.1 Human Rights and Labor Standards
Suppliers must not use forced, bonded, compulsory, or involuntary labor and must not employ child labor, in compliance with applicable laws and international standards. Suppliers are expected to respect workers’ rights to fair wages, reasonable working hours, and lawful benefits, and to recognize freedom of association and the right to collective bargaining where permitted by law. All workers must be treated with dignity and respect, and suppliers must provide a workplace free from discrimination, harassment, or abuse. The Company expects suppliers to address identified risks proactively and to take corrective action where shortcomings are identified.
3.2 Health and Safety
Suppliers are expected to provide a safe and healthy working environment and to comply with all applicable occupational health and safety laws. Reasonable measures must be implemented to prevent workplace accidents, injuries, and occupational hazards, including appropriate training, supervision, and risk mitigation measures relevant to the nature of the work performed.
3.3 Ethical Business Conduct
Suppliers must conduct their business in compliance with all applicable laws and regulations. The Company maintains zero tolerance for bribery, corruption, fraud, or other unethical business practices, and suppliers are expected to maintain accurate and honest business records and reporting. Suppliers must avoid conflicts of interest that could improperly influence business decisions and must act with integrity in all dealings with the Company.
3.4 Environmental Responsibility
Where relevant to the goods or services provided, suppliers are expected to comply with applicable environmental laws and regulations and to take reasonable steps to minimize their environmental impact. This includes responsible management of waste, emissions, energy use, and natural resources, and a commitment to continual improvement in environmental performance where practicable.
- Supplier Due Diligence and Risk Management
We take a proportionate, risk-based approach to ethical sourcing. This may include supplier assessments during selection and onboarding, enhanced review of suppliers operating in higher-risk regions or industries, and ongoing monitoring where appropriate. Suppliers are expected to cooperate with reasonable requests for information related to ethical sourcing and compliance. Suppliers must promptly notify the Company of any actual or suspected breaches of this policy or related risks.
- Reporting Concerns
Suppliers and their workers are encouraged to report any concerns or violations related to human rights abuses, unsafe working conditions, or ethical or legal misconduct. Reports should be made through available reporting channels and will be treated confidentially to the extent reasonably possible. Retaliation against individuals who raise concerns in good faith is not tolerated, and the Company expects suppliers to maintain similar non-retaliation principles within their own operations.
- Non-Compliance and Corrective Action
Where a supplier is found to be in breach of this policy, the Company may require corrective actions within a defined timeframe. Continued non-compliance may result in the suspension or termination of the business relationship. Serious violations, including forced labor or human trafficking, may result in immediate termination. The Company may also consider the supplier’s willingness and ability to remediate issues when determining appropriate actions.
- Responsibilities
Management is responsible for implementing this policy within procurement and supplier management processes. Employees involved in sourcing and procurement are expected to comply with this policy and to raise concerns when identified. Suppliers are responsible for ensuring compliance within their own operations and, where relevant, within their supply chains, and for communicating this policy or equivalent standards to relevant personnel.
- Review and Updates
This policy will be reviewed periodically and updated as necessary to reflect legal requirements, best practices, and business developments.
This policy is approved by the management of Spunky Food Co., Ltd.
