Black Diamond Kennel

OPERATING STANDARDS

This policy was last modified on March 28, 2023.

BDKLV, LLC., and its affiliates and subsidiaries (collectively referred to herein as “BDK” or the “Company”) is dedicated to global citizenship and sustainability, and we expect the factories, subcontractors, distributors, manufacturers, business partners, service providers, suppliers and agents who are affiliated with the production of Black Diamond Kennel goods (collectively, “Suppliers”) to share in these commitments. BDK does not own the factories making its products or employ the employees in those factories, so it is essential that our Suppliers assume direct responsibility for protecting the environment and championing better lives for their employees. To that end, we require all Suppliers to observe certain operational standards set forth herein (“Standards”) for a safe, sustainable, inclusive, and ethical workplace that embraces a fundamental effort toward continuous improvement.

LEGAL AND ETHICAL STANDARDS

We expect our Suppliers to observe all applicable local and national laws as well as international regulations and standards in the operation of their business. While we recognize the different legal and cultural environments in which Suppliers operate, we expect them to align with our Standards even when they offer greater protections than those imposed by local, regional, and national laws.

Anti-Bribery/Conflict of Interest – Suppliers must not engage in offering or accepting compensation of any value (such as gifts, discounts, services, loans, payments), either directly or indirectly, to or from any of the Company’s employees, service providers or to any government or political officials, to obtain an unfair or improper advantage. Suppliers shall also avoid any form of fraud or any action that creates, or appears to create, a conflict of interest with the Company.

Subcontracting – Suppliers are prohibited from subcontracting with unapproved suppliers for manufacturing or services and are responsible for ensuring that their subcontractors are held accountable to these Standards. Suppliers are only permitted to use homework with prior written consent and approval by the Company.

International Trade Compliance – Suppliers must comply with all applicable international laws relating to the import and export of products and are expected to participate in the Company’s Supply Chain Security program.

Transparent Record Keeping – Suppliers must maintain and make immediately available for inspection accurate records.

 

LABOR, HUMAN RIGHTS & SAFETY

Employment Relationships & Responsible Recruitment – Circumventing national or local laws to avoid regular employee entitlements such as benefits, wages or other legal obligations is prohibited. Suppliers will ensure no fee recruitment, no withholding of work/travel documents, and no restrictions on freedom of movement. When applicable, Suppliers will inform their employees of the basic terms of their employment before leaving home.

Wages and Benefits – Suppliers’ wage and benefit policies must be consistent with and comply with all laws regulating local wages, overtime compensation, and legally mandated benefits. Wages must also be paid timely and include a wage calculation for each pay period, as provided for under applicable law. Suppliers should provide compensation that is sufficient to meet workers’ basic needs and provide some discretionary income. If compensation does not meet workers’ basic needs and provide some discretionary income, Suppliers should work with BDK to make improvements to progressively realize a level of compensation that does meet these standards.

Working Hours – All regular and overtime hours must be voluntary and in accordance with national laws. Under ordinary business circumstances, employees must not be required to work excessive working hours and overtime and have at least one day off in seven.

Health & Safety – Suppliers will ensure that their employees are provided a safe and healthy work environment and are not subject to unsanitary or hazardous living or working conditions. Supplier-provided housing facilities shall be in a separate building. Every Supplier must obtain, maintain, and comply with all safety and health permits, including but not limited to, an obligation to ensure building integrity and fire safety with regularly scheduled emergency practice evacuations and frequent inspection of exit doors for proper emergency use.

No Child Labor – Use of child labor is prohibited (employees under the age of 16). Supplier employees between the ages of 16 and 18 must not be subject to night and/or hazardous work.

Freedom of Association & Collective Bargaining – Suppliers should permit their employees the right to associate with others, form and join (or choose not to join) organizations of their choice, and bargain collectively in accordance with applicable law, without risk of discrimination, harassment, interference, or retaliation, subject to applicable domestic law and practice. Where the right to freedom of association and collective bargaining is restricted under law, the Supplier must engage in their best efforts to otherwise comply with these principles.

Voluntary Employment – Suppliers are prohibited from working with or arranging for purchase of any materials or services that supports or utilizes forced, indentured, bonded, or compulsory labor obtained through human trafficking, coercion, or slavery.

Respect & Fairness – Suppliers must maintain a workplace free of discrimination, harassment, abuse and retaliation, and treat their employees with respect and dignity. Engaging in or tolerating physical, racial, sexual, psychological or verbal harassment, coercion, punishment or abuse is strictly prohibited.

No Discrimination – Suppliers must forbid discrimination in employment practices, including recruitment, hiring, compensation, training, benefits, advancement, promotion, discipline, termination or retirement, on the basis of gender, race, religion, age, disability, sexual orientation, nationality, pregnancy, marital status, gender identity or expression, genetic information, trade union status or activity, disability, social group, ethnic origin, caste or any other personal characteristics, beliefs or other status protected by applicable law. Suppliers must share our commitment to principles and practices that prioritize diversity, equity, and inclusion. Suppliers must ensure equal pay for all, including benefits, equal treatment, equal review of performance and equal opportunity for promotion. Special attention should be paid to marginalized groups (such as women).

ENVIRONMENTAL AND ANIMAL WELFARE

Environmental Compliance – Suppliers must conduct their operations consistent with applicable environmental laws and best practices. Suppliers will maintain and comply with current environmental licenses and permits in the locale of operation. Suppliers shall also operate and source product in such a manner that respects the environment and local communities, with particular concern to avoid deforestation, pollution, habitat loss and rising greenhouse gas emissions.

Wastewater, Waste Management, & Chemical Management – Suppliers should strive to use water efficiently, minimize waste, and properly dispose of hazardous and non-hazardous waste. Suppliers shall comply with product safety restrictions and prohibitions of hazardous substances in the markets of product distribution.

Animal Sourcing Principles – Suppliers must embrace a fundamental concern for animal welfare and share our commitment to principles, practices, and regulations that require animals in our supply chain to be treated ethically and humanely.

Management and Effective Grievance Mechanisms
Management – Compliance with these Standards and the terms of the Vendor Compliance Packet is subject to ongoing review by BDK and third-party auditors. For these purposes, BDK expects Suppliers to be transparent, maintain proper records, and provide prompt access to facilities, records, and their employees upon request. BDK also expects Suppliers to perform periodic audits of their suppliers and subcontractors’ facilities and operations to ensure equal compliance with these Standards.

Grievance Mechanism – Suppliers shall provide their employees with an effective grievance mechanism to report workplace concerns or violations of these Standards to management confidentially and anonymously, without the fear of retaliation.

Suppliers will maintain policies, systems, processes, and training for grievance procedures and tracking to ensure a timely response to the employee that will also be subject to on-going review by BDK and third- party auditors.

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