DelcoLink Group LTD. (“DelcoLink Group LTD.”), and its subsidiaries (collectively, the “DelcoLink Logistics” or “we” or “us” or “our”), have updated our Supplier Code of Conduct (“Policy”). This Policy may be updated to reflect changing legal, regulatory, or operational requirements. We encourage you to regularly review this page for the latest information on our privacy practices.
For the purposes of this policy, for all terms definitions please refer to Glossary of Terms (www.delcolink.com/legal-hub/for-everyone/glossary-of-terms). If you are unsure, electronically mail us at contact below.
SUPPLIER CODE OF CONDUCT
We are a global e-commerce and networking company. We connect individuals with markets. We contribute to the world by taking action to minimize our environmental footprint, to provide a safe, inclusive, and engaging working environment, to support the communities we operate in, and to follow trusted, transparent, and compliant business practices. We are fully aware of our responsibilities because of our activities thus, we have given ourselves a strict set of ethical standards to guide us in our business practices.
We expect all our suppliers, sub-contractors, third-party service providers, i.e., all establishments who do business with any company or division of ours, to adhere to the same ethical standards. For this objective, we have formed this Supplier Code of Conduct (SCoC) Policy, which sets the minimum standards for doing business with us.
LAWS AND ETHICAL STANDARDS
The supplier will comply with all laws applicable to its business. The supplier will support the principles of the United Nations Global Compact, the UN Universal Declaration of Human Rights, the UN Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises as well as the 1998 International Labor Organization Declaration on Fundamental Principles and Rights at Work, in accordance with national laws and practice. Especially must abide by Human Rights and Fair Labor Practices as below states.
CHILD LABOR
The supplier will not employ children under the legal age of employment in any country or local jurisdiction. The supplier will apply a minimum working age of 15 years old, even where local legislation permits younger children to be employed. Workers under the age of eighteen will only perform work in accordance with legal requirements of their country of employment (e.g., with regards to working time and working conditions) and subject to any requirement regarding education or training.
FORCED LABOR
The supplier will not use any form of forced, bonded, compulsory labor or modern forms of slavery. All labor must be voluntary. Workers must be allowed to maintain control over their identification documents (e.g., passports, work permits or any other personal legal documents). The supplier will ensure that workers do not pay fees or make any payment connected to obtaining employment throughout the hiring process and the employment period. The supplier will be responsible for payment of all fees and expenses (e.g., licenses and levies) relating to workers, where legally required. Punishment, mental and/or physical coercion as well as any other form of human trafficking are prohibited. Disciplinary policies and procedures should be clearly defined and communicated to the workers.
COMPENSATION AND WORKING HOURS
The supplier will comply with all applicable local laws and mandatory industry standards regarding working hours, including overtime, rest breaks and paid vacation. The supplier will compensate its workers in accordance with local wage legislation and terms of applicable collective bargaining agreements as well as with industry standards. The supplier will pay workers in a timely manner and clearly convey the basis on which workers are being paid (i.e., receive employment documents in a language they understand). Deductions from wages as a disciplinary measure will not be permitted, if not legally permitted.
FREEDOM OF ASSOCIATION AND COLLECTIVE BARGAINING
The employees of the supplier must be free to join or not to join a union/employee representation of their choice, free from threat or intimidation. The supplier understands and respects the right to collective bargaining in accordance with applicable local laws.
DIVERSITY AND INCLUSION
The supplier will promote an inclusive work environment that values the diversity of its employees. The supplier will be committed to equal opportunities and not discriminate or tolerate discrimination or harassment with respect to gender, ethnic and national origin, race, color, religion, age, disability and identity, or any other characteristic protected by law.
HEALTH AND SAFETY
We require our suppliers to strive to implement the standards of occupational health and safety at a prominent level by applying a health and safety management approach suitable for the business. The supplier will comply with applicable occupational health and safety regulations and provide a work environment that is safe and conducive to good health e.g., drinking water, to preserve the safety and health of employees, safeguard third parties and prevent accidents, injuries, and work-related illnesses. This includes regular workplace risk assessments and the implementation of sufficient hazard control and precautionary measures, including the provision of appropriate Personal Protective Equipment (PPE). Employees are to be educated and trained in health and safety issues in a language they understand.
DATA PROTECTION, DATA SECURITY, AND DISCLOSURE OF DATA
The supplier will adhere to applicable data protection laws, including security of personal data, as well as to respective regulations, e.g., PIPEDA, regarding personal data of customers, consumers, employees, and shareholders. The supplier will comply with all said requirements when personal data is collected, recorded, hosted, processed, transmitted, used, or erased.
The data security requirements applicable to suppliers with regards to any data entrusted to their control during and after their engagement with us are based on international standards, such as the Code of Practice for data Security Management. Suppliers should take account of the need to protect the confidentiality, integrity, and accessibility of data. At all times, the required level of data security and control to be guaranteed by suppliers must be proportionate with the sensitivity, value and criticality of the data being processed throughout the lifecycle of the data.
The supplier will protect and make only appropriate use of confidential data. The supplier will comply with any contractual requirements on data protection and data security and will not disclose any data that is not known to the public.
BRIBERY AND CORRUPTION
The supplier will comply with all applicable national and international anti-corruption laws and regulations. The supplier will not (neither directly nor indirectly) offer, provide or accept anything of value to improperly influence an official act or to secure an improper advantage to obtain or retain business. This includes so-called facilitation payments or other benefits provided to public officials for routine non-discretionary actions.
TRADE REGULATION
The supplier will comply with all applicable export control, sanctions and customs laws and regulations, including Prohibitions and Restrictions (“Trade Laws”). The supplier ensures that the supplier, its beneficial owner(s), all its agents and any other sub-contractors used by the supplier are not listed on any applicable Denied Party sanctions lists.
MONEY LAUNDERING AND FINANCIAL RECORDS
The supplier will adhere to relevant laws and regulations designed to combat money laundering activities. The supplier will maintain financial records and reports according to relevant laws and regulations.
FREE COMPETITION
The supplier will comply with applicable competition and anti-trust laws.
CONFLICTS OF INTEREST
A conflict of interest is any personal or financial interest, any business or personal activity or relationship, prior or current employment, or any obligation that may interfere with the ability to objectively perform job duties and responsibilities or impair independence and objectivity. Such conflict-of-interest situations include critical relationships such as a relationship by blood or marriage, partnership, participation or an investment in business partners or competitors. The supplier will immediately disclose any actual or potential conflict of interest related to its activities with us.
ENVIRONMENT
The supplier will comply with all applicable environmental laws, regulations and standards as well as implement an effective system to detect and eliminate potential hazards to the environment. We expect our suppliers to strive to support our environmental and climate protection commitments through the products and services they deliver, which should be done efficiently by taking the environmental impact into consideration. We also expect our suppliers to report relevant data on environmental and climate protection upon request. We expect our suppliers to take environmental and climate protection appropriately into account in their own operations, for example, by setting climate protection goals for themselves and achieving them.
CONFLICT MINERALS
The supplier will comply with all relevant laws and resulting due diligence obligations with respect to the sourcing of minerals and materials from conflict affected regions and high-risk areas, which may contribute to human rights abuses, corruption, the financing of armed groups or similar harmful effects.
COMMUNITY OUTREACH
We encourage our suppliers to give back to their local communities and engage in initiatives and activities that reflect the UN Sustainable Development Goals.
BUSINESS CONTINUITY PLANNING
The supplier will be prepared for any disruptions of its business (e.g., natural disasters, terrorism, supply chain disruptions, communicable disease outbreaks – epidemics or pandemics, data security issues, cyber-attacks). This vigilance includes business continuity plans that protect both employees as well as the environment from the effects of possible serious disruptions that may arise within the domain of operations.
BUSINESS PARTNER DIALOGUE
The supplier will implement comparable standards e.g., ethical standards, to the ones put out in this SCoC Policy for their own suppliers, as part of fulfilling their contractual obligations.
RESPECT AND DUTY OF CARE
All Suppliers are required to act and interact with respect and in good faith with employees of ours. Suppliers are to exercise due care in the use of property and equipment entrusted to them, as if the property is their own. When using property or materials that carry our trademark or brand, all suppliers will exercise particular care as any of their actions or activities may be associated with us. Any unauthorized use of branded or trademarked materials or equipment is to be avoided. It is considered a misuse of our branded or trademarked materials and equipment if even an appearance of impropriety can be inferred.
COMPLIANCE WITH THE SUPPLIER CODE OF CONDUCT
We reserve the right to check compliance with the requirements of this SCoC Policy, for example through self-assessments and audits either by us or third-party. The supplier will strive for continuous improvement, such as setting measurable targets on the environment, working conditions or diversity, and reporting on progress for sustainability. In case a breach is discovered, the supplier will create an incident report and present a corrective action plan. The terms and conditions set forth in this SCoC Policy reflect our values and commitment to our customers, the communities which we serve and the protection of the environment. Therefore, any breach of these terms and conditions must be cured. Without prejudice to any other contractual remedies, we may be entitled to, any failure to cure such a breach immediately will cause us to consider terminating the business relationship.
REPORTING IRREGULARITIES
We encourage anyone who wishes to report any violations from what is outlined in SCoC Policy or suspected breaches of law to write an electronic mail to the contact below.
CONTINUOUS IMPROVEMENT
The supplier should feel encouraged to proactively approach us with innovative ideas which contribute to further social, economic, or environmental enhancement. We value the open exchange of innovative ideas and are willing to explore new opportunities in conjunction with suppliers.
CHANGES TO THIS POLICY
The content of this Policy is for your general information and use only. These policies are subject to modification without notice. You acknowledge that this information may contain inaccuracies or errors and is subject to adjustment and we expressly omit liability for any such inaccuracies or errors to the fullest degree authorized by law. We urge you to regularly review this page (and all available policies & agreements) for the latest information on the Policy. Your continued use of our platform and internet sites constitutes your agreement to be obliged by such amendments to this Policy. Your only remedy, if you do not agree to the terms of this Policy, is to cease use of and access to our platform and internet sites.
Each version of this Policy is identified by its effective date on this article.
ENGLISH VERSION CONTROLS
Non-English versions of this Policy are supplied for accessibility only. In the occurrence of any ambiguity or conflict between interpretations, the English version is authoritative and rules.
CONTACT US
If you have inquiries or concerns concerning this Policy or about our legal practices, please contact us by electronic mail at Legal@delcolink.com or at:
DelcoLink Group LTD.
Legal Team of DelcoLink Logistics
200 – 250 UNIVERSITY AVENUE
TORONTO ON M5H 3E5
Last Updated: Dec 19, 2022