|Kluntz code of conduct|
CODE OF CONDUCT
Code of Conduct for vendors to Kluntz A/S
This Code of Conduct is intended to create and encourage commitment to responsible production and business principles around the world. The purpose is to ensure that vendors and their subcontractors produce components and supply services to Kluntz in a manner that respects the rights of their employees and the environment. In this way Kluntz also wishes to promote and support the principles in the Universal Declaration of Human Rights.
Acceptance of and compliance with this Code of Conduct, form an integral part of every Business Agreement with Kluntz. The Code of Conduct establishes a minimum requirement and Kluntz urges its vendors to strive for continued improvement within all areas covered by this Code of Conduct, in furtherance of human rights, labour standards and to the protection of the environment and refrainment from corruption.
UN GLOBAL COMPACT
The Global Compact lay down 10 principles in four important areas: Human rights, labour rights, environment and anticorruption.
It is essential to Kluntz that the men and women, who take part in the production of our products and components, whether in factories owned by vendors or their subcontractors, are treated decently and with dignity.
Kluntz adheres to the principles of this Code of Conduct and requires that our vendors do the same.
All Kluntz vendors must take appropriate action to ensure that the provisions of our Code of Conduct are communicated to managers and supervisors in their own language.
Child labour must not be engaged in or benefited from.
Child labour is defined as the employment of a person in a full-time position who is younger than the local legal minimum age for full time employment. The minimum age for employment shall not be less than the age of completion of compulsory schooling and, in any case, shall not be less than 15 years (or 14 years where established by national laws in accordance with the ILO developing-country exception). If child labour is detected, then, in addition to other actions pursuant to this Code of Conduct, Kluntz reserves the right to involve local or international organisations with a view to securing the child’s future.
Vendors must comply with all local laws and regulations regarding the employment of young workers, i.e., with respect to permitted types of work, work schedules and labour intensity. For work at night or in hazardous conditions, workers must be older than 18 years of age.
Kluntz generally encourages the creation of apprenticeship programs.
Kluntz’s position on child labour is elaborated in the appendix.
Forced or compulsory labour must not be used or benefited from. Employees must have the freedom of movement during the course of their employment. Guards must only be posted for normal security reasons to protect employees and the property of the company.
Physical punishment, threats of violence or other forms of mental or physical coercion or abuse must not be used.
Grievance procedures that provide employees with effective means to challenge disciplinary sanctions imposed upon the employees must be established. Decisions resulting from the use of such procedures must be accepted and abided by.
If fining is used as a disciplinary sanction, such fines must be imposed based on objective criteria known to the employees. In no case, however, may fines imposed reduce the net compensation payable to the employee for any relevant payment period below the minimum wage level determined under local laws and regulations.
Discrimination, directly or indirectly, in hiring and employment practices on grounds of race, colour, sex, language, religion, political or other opinion, age, national, social or ethnic origin, property, sexual orientation, birth or other status must not be engaged in or supported.
It must not be required that female employees are subjected to mandatory pregnancy tests.
It must not be required that employees are subjected to mandatory HIV/AIDS tests.
Compensation, Rest, Leisure and Holidays
Wages and Benefits
Employees must be provided with written confirmation of employment terms, if and as required by local laws and regulations.
The rights of the employees to choose to be a member of a trade union and to bargain collectively as permitted by local laws and regulations must not be interfered with or restricted.
Retaliation practices must not be used to prevent workers from expressing dissatisfaction with their working conditions openly and in a loyal manner.
A safe and healthy working environment must be provided, in compliance with all local laws and regulations.
As a minimum it must be ensured that:
Emergency procedures and plans
Local laws and regulations regarding the protection of the environment must be complied with.
Corruption and Bribery
Bribes must not be offered, promised, given, accepted, condoned, knowingly benefited from, or demanded.
Vendors must be in compliance with the best practices of:
E.g. following the Supply Chain Security / Container Security Initiative and C-TPAT Guidelines and recommendations of the U. S. Customs Service.
Monitoring and Evaluation
Kluntz reserves the right to monitor and audit vendors at any time to verify compliance with this Code of Conduct. Vendors shall maintain, on site, any documentation that may be necessary to demonstrate compliance with this Code of Conduct.
All vendors are required to provide:
Failure to permit full access will be viewed as non-compliance with this Code of Conduct, and business relations with the vendors denying access will be terminated. The result of all monitoring visits will be documented in a monitoring report. If an on-site inspection reveals non-compliance with this Code of Conduct (other than by failure to permit access as set forth above), Kluntz will enter into a constructive dialogue with the vendor in question in order to improve conditions. Kluntz will request adequate action plans to correct issues of non-compliance and will undertake follow-up inspections to verify that improvements are made. If improvements do not progress in a manner acceptable to Kluntz, business relations with the vendor will be terminated.
A Family Friendly Work Environment – Kluntz Position on Child Labour
Kluntz does not condone or support child labour. We believe that children must have time to learn through education and time to play in order to thrive as children. Kluntz believes that the rights and interests of children are consistent with children undertaking safe part time work as long as the national and international laws and standards for legal employment as a minimum are respected and met. In doing so, we recognize that the problem of child labour does exist in many countries, and Kluntz contributes to its socially responsible prevention and solution.
Kluntz does not in any form or fashion accept children undertaking harmful work but supports the principle of children working part-time under safe conditions that allow them to complete school and time to play.
Kluntz supports the United Nations Convention on the Rights of the Child (UNCHR) (1989) stipulated in:
In addition to the U.N. Convention on the Rights of the Child, Kluntz bases its approach to working children on the following definitions and principles:
Other worst forms of child labour:
In effect and in accordance with Kluntz Code of Conduct this means:
Kluntz, as part of its prevention of child labour, aims to promote a family friendly work environment, and encourages all of its vendors and their subcontractors to treat all workers with decency and respect. Kluntz recognizes that the wage and employment conditions have an important impact on children. If parents and adult workers are treated well and paid a living wage, there is less need for children to supplement family incomes by working.
Kluntz also recognizes that establishing fair and ethically correct policies for production and sourcing reflects positively on worker’s conditions, including the conditions of working children. Therefore, Kluntz and its vendors must work towards continually improved production planning and procurement policies and practices that do not put unnecessary pressure on suppliers and sub-suppliers to reduce lead time and require overtime work.
Vendors are obliged to take the appropriate measures to ensure that no child labour occurs at suppliers’ and their sub-contractors’ places of production. (Places of production refer to all places of extraction, manufacturing, transport and service activities related to producing for Kluntz.)
If child labour is found in any place of production, Kluntz will require the vendor to implement a socially responsible corrective action plan with the assistance of Kluntz. If the corrective action is not implemented within the agreed timeframe, or if repeated violations occur, Kluntz will terminate all business with the vendor concerned.
The action plan may differ in content dependent on the situation of the company and the child. However the corrective action plan has to ensure that all actions to handle working children must take the child’s best interests into account and include the child and its family in decisions with regards to the child’s future.
Kluntz may from time to time co-operate with national and international organizations protecting the interests of children and young workers. If Kluntz’s vendor are found to be in non-compliance with this Code of Conduct including the appendix on child labour, such vendor shall co-operate with Kluntz and/or its national or international partner organization to the fullest extent possible, to avoid that such non-compliance may cause harm to children or young people and to ensure more viable and sustainable alternatives for the children.