CABINETWORKS GROUP SUPPLIER BUSINESS PRACTICES POLICY
Revised April 2023
Cabinetworks Group prides itself on its reputation for honesty, integrity, and excellence in business. Cabinetworks therefore expects and requires that all suppliers, at all times, operate in full compliance with both the letter and spirit of all laws, including but not limited to human rights, labor, health and safety, environmental, intellectual property, anti-bribery and anti-corruption, trade compliance, and competition and antitrust laws.
Suppliers are further expected and required to commit to the highest standards of ethical conduct when dealing with workers, suppliers, customers, and other relevant stakeholders. Suppliers are required to accurately record and disclose information regarding business activities, structure, financial situation, and performance in accordance with applicable laws.
Cabinetworks will monitor suppliers to ensure they are adhering to the spirit and letter of applicable laws, including but not limited to the following:
- Forced Labor
Suppliers shall uphold the human rights of all workers and treat them with dignity and respect.
Suppliers shall only employ or engage workers who meet the applicable minimum legal age requirement, except that in no event shall suppliers employ any person under the age of 16, even if local laws permit otherwise. Notwithstanding the foregoing, suppliers may allow individuals aged 15 or older to work as part of a bona-fide apprentice program. Such programs must be in compliance with local law and be intended to provide instruction in one or more particular industrial disciplines as part of enrollment in an educational institution.
Suppliers shall not use or engage in any indentured or forced labor, slavery or servitude, human trafficking, or prison or compulsory labor. Suppliers shall also conduct due diligence necessary to ensure that its suppliers also comply with this policy.
All work must be voluntary, and workers shall be free to leave supplier facilities upon reasonable notice and at the end of each workday, or terminate their employment without the expectation or requirement to pay any fees, or the forfeit of pay or benefits legally owed.
- Suppliers must not require workers to surrender any government-issued identification, passport, or work permit as a condition of employment. If workers prefer the employer keep passports or other government-issued paperwork for safekeeping, the supplier needs to provide adequate facilities for the safety of the worker documents and allow the worker free access to the documents.
- Suppliers must provide all documents relevant to employment of foreign migrant workers in a language the worker can understand prior to departing from their country of origin.
- Foreign migrant workers cannot be required to pay recruitment fees or other fees related to being hired or as a condition of employment, termination, or voluntary separation.
The following situations are also considered forced labor:
- Sourcing materials produced or manufactured in the Xinjiang Uyghur Autonomous Region (XUAR) in the People’s Republic of China.
- Utilizing labor from workers involuntarily relocated from the XUAR to another region or country.
- Compliance with Labor Laws
Compensation and Working Hours
Suppliers shall set working hours, wages, and overtime pay in compliance with all applicable laws. Workers shall be paid at least the minimum legal wage or, in the absence of a minimum legal wage, a wage that meets local industry standards.
Discrimination and Disciplinary Practices
Suppliers shall hire workers on the basis of ability to do the job. Workers shall be treated with dignity and respect. Suppliers shall not engage in or permit corporal punishment, verbal, sexual, psychological abuse or harassment, or threatened or actual violence. Suppliers shall not engage in any discrimination or harassment, whether based on gender, race, color, religion, ethnicity, social background, age, sexual orientation, gender identity, national origin, disability, political conviction, military veteran status, marital status, pregnancy status, or any additional legally protected characteristics.
Freedom of Association
Suppliers shall respect workers right to join or not join any lawful organization, including but not limited to trade unions and works councils, and shall comply with all applicable laws pertaining to freedom of association and collective bargaining.
- Compliance with Health & Safety Standards
Cabinetworks is committed to being a global leader in safeguarding the health and safety of workers, officers, directors, agents, and contractors. Suppliers shall comply with Cabinetworks’ Environmental, Health, and Safety (“EHS”) policies and standards, and any site-specific EHS requirement or protocol while on-site at a Cabinetworks location or at a Cabinetworks customer location on behalf of Cabinetworks. Suppliers shall:
- Take responsibility for the health and safety of workers.
- Ensure a safe work environment and minimize physical, chemical, and other hazards through proper design, engineering and administrative controls, maintenance, and safe work procedures as well as ongoing safety training.
- Provide workers with appropriate personal protective equipment where hazards cannot be adequately controlled by other means.
- Provide and properly maintain physical guards, interlocks, and barriers where machinery presents a potential injury hazard to workers.
- Minimize the impact of emergency situations through the implementation of emergency plans and response procedures.
- Provide training and ensure that workers are appropriately trained and educated in respect of health and safety matters.
- Compliance with Environmental Laws
Environmental considerations and sustainability are an integral part of Cabinetworks business practices. Suppliers shall:
- Maintain all required environmental permits and registrations and follow the operational and reporting requirements of such permits.
- Comply with regulated substance and product content specifications and with any applicable laws identifying, prohibiting, or restricting the use, content, handling or disposal of specific substances.
- Minimize environmental pollution and make continuous improvements to reduce or eliminate solid waste, wastewater, and air emissions by appropriate conservation measures in their production, maintenance, and facility processes.
- Manage, control, treat, and/or dispose of non-hazardous solid waste, wastewater, and/or air emissions generated from operations as required by applicable laws.
- Promptly notify proper authorities (if legally required) and remediate any environmental emission, discharge, or other event that is not in accordance with both applicable laws and accepted practices.
- Anti-Bribery / Anti-Corruption
Cabinetworks is committed to complying with all anti-corruption laws, including but not limited to the U.S. Foreign Corrupt Practices Act and similar laws, that prohibit bribes, kickbacks, or other corrupt actions to obtain or retain business or obtain any improper advantage. Suppliers shall not directly or indirectly solicit, receive, offer, or pay any form of bribe, kickback, or other corrupt payment, to or from any person or organization, including but not limited to government agencies or officials, companies, or employees of those companies. Suppliers shall prohibit any and all forms of bribery, corruption, fraud, extortion, theft, or embezzlement by employees.
When doing business with or conducting business on behalf of Cabinetworks, suppliers may for legitimate business purposes: (i) offer gifts or entertainment to suppliers, customers, or other business associates; or (ii) accept gifts or entertainment offered by suppliers, customers, or other business associates; provided that in each instance the gift or entertainment:
- is unsolicited
- is not illegal or in violation of this policy
- is not a bribe, kickback, or other illicit payment
- is not given in exchange for any consideration
- would not embarrass Cabinetworks if disclosed publicly
- does not create the appearance (or an actual or implied obligation) that the gift giver is entitled to preferential treatment, an award of business, better prices, or improved terms of sale
- does not directly or indirectly benefit any government agency or public official.
- Conflict Minerals Sourcing
In accordance with the SEC’s Conflict Minerals Rule, Cabinetworks has implemented processes to identify whether tin, tantalum, tungsten, or gold (collectively “Conflict Minerals”) are contained in its products, and, if so, whether the Conflict Minerals might originate from sources that directly or indirectly finance or benefit armed groups operating in the Democratic Republic of the Congo (DRC) and surrounding countries. Cabinetworks expects suppliers to source any required Conflict Minerals from suppliers who meet these Supplier Business Practices Policy requirements, to implement traceability measures for Conflict Minerals, and to provide Cabinetworks with all requested information, including information about all suppliers in the supply chain.
- Perform sufficient due diligence into the supply chain to determine whether products sold or provided to Cabinetworks contain Conflict Minerals and, if so, whether and to what extent those metals are sourced from conflict-free smelters.
- Report the results of such due diligence to enable Cabinetworks to comply with legal obligations and policy goals.
- Commit to being or becoming “conflict-free”, so that any such metals are sourced only from conflict-free smelters.
Cabinetworks continues to support responsible in-region mineral sourcing from the DRC and adjoining countries. To that end, Cabinetworks does not intend to discourage suppliers from sourcing Conflict Minerals from these regions. Rather, Cabinetworks encourages suppliers to source these minerals from smelters and refiners verified as compliant with the Conflict-Free Sourcing Program (CFSP), or a similar program, whether or not in an identified region of conflict.
- Protection of Intellectual and Physical Property
Suppliers shall respect intellectual property rights and safeguard Cabinetworks information. Transfer of technology and know-how shall be done in a manner that protects intellectual property rights. Suppliers shall implement processes and procedures and exercise due diligence to detect and avoid counterfeit parts. Suppliers shall not use any patent, trade secret, confidential information, name, trademark, or image owned by Cabinetworks except as licensed in conjunction with supplier’s work for Cabinetworks.
Suppliers shall protect all Cabinetworks physical property, including any inventory, machinery, equipment, marketing or instructional literature, training materials, or other physical property.
- Compliance Monitoring
Suppliers shall allow Cabinetworks and/or any of its representatives or agents access to supplier facilities and all relevant records associated with the products and services provided to Cabinetworks. Suppliers and Cabinetworks shall establish a mutually agreeable date and time for access. However, risks to Cabinetworks business may require immediate access to the products, services, and associated records and suppliers shall accommodate requests from Cabinetworks for reasonable access as required. Suppliers also agree to cooperate with Cabinetworks in the investigation of any allegations of wrongdoing, misconduct, or corruption.
Suppliers shall contractually require its suppliers and/or subcontractors to conform to standards of conduct equivalent to the provisions of this policy and will refrain from engaging or continuing to work with suppliers who fail to comply with this policy.
Suppliers shall not do business with any entity, individual, or financial institution that is listed on the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) list of sanctioned entities found at https://home.treasury.gov/policy-issues/financial-sanctions/specially-designated-nationals-and-blocked-persons-list-sdn-human-readable-lists.
Cabinetworks reserves the right to audit supplier’s suppliers and/or subcontractors for compliance to this policy and suppliers shall accommodate the Cabinetworks audit as required. Suppliers shall also ensure that its workers comply with this policy when providing goods or services to Cabinetworks. Suppliers shall promptly report to Cabinetworks written notice of any known breach of this policy and implement within 30 days a corrective action plan to cure all non-compliance.
- Commitment to Compliance
Suppliers shall provide training to workers as needed to meet the expectations of this policy and shall also ensure that its suppliers, vendors, and subcontractors are also trained on this policy.
Suppliers shall, at the request of Cabinetworks, provide periodic certification of compliance with this policy.
Cabinetworks will not knowingly work with suppliers that do not respect this policy. Any reported non-compliance will be investigated, and appropriate action will be taken. Any violation of this policy may result in termination of business without further consequence to Cabinetworks. Cabinetworks reserves the right to hold suppliers responsible for the reasonable costs of investigating and remedying any non-compliance.
Cabinetworks encourages individuals to report any known or suspected violations of this policy to the Cabinetworks Group Ethics Hotline (the “Hotline”) at 844-890-0005 or www.lighthouse-services.com/CABINETWORKSGROUP. International calls to the Hotline can be made by first dialing the access code for the country of the caller and entering the toll-free number 800-603-2869. Access codes are found at https://www.business.att.com/collateral/access.html. When prompted for the company name, the caller should state Cabinetworks Group supplier in addition to supplier company name.
Reports to the Hotline can be made on a confidential and anonymous basis. Cabinetworks will make efforts to maintain such confidentiality and anonymity during any internal investigation of the reported issue and, where applicable, remedial actions taken, except as otherwise required by law or court order.
Suppliers shall implement processes to address the confidentiality and protection of a worker who in good faith raises a concern, makes a report, or assists with an investigation related to potential ethical or criminal violations. Cabinetworks further prohibits retaliation of any kind for making a good faith report regarding known or suspected non-compliance, and any such retaliation is also a violation of this policy.