ETHICAL SOURCING CODE OF CONDUCT
Alignment to the SDG’s
The United Nations Sustainable Development Goals (SDGs) invite action from the private sector to address some of the world’s most pressing development issues. Situated in a broader ethical sourcing framework, our Supplier Code of Conduct is one way Oppenheimer aligns with the SDG’s. By managing actual and potential human rights and environmental risks in our supply chain we are, in a small way, contributing towards SDG 8 on decent work and economic growth, and SDG 12 on responsible consumption and production.
Purpose and scope
Our Supplier Code of Conduct (“Code”) sets out the minimum standards of behaviour we require of our suppliers. The Code is applicable to all contract suppliers who are expected to cascade these requirements to their own supply chain. We ask our suppliers to not just comply with the Code, but to use reasonable endeavours to exceed it and promote continual improvement throughout their business operations.
Our Commitment
We are committed to leading by example, acting with integrity and fostering an ethical culture where everyone embraces a sense of personal responsibilty for doing the right thing in the right way. Oppenheimer is committed to sustaining the highest legal, environmental, ethical and professional standards consistent with the Ten Principles of the UNGC in the areas of human rights, labour, environment and anti-corruption. This is a valuable opportunity to influence, educate and work with our supplier base, ensuring transactions are both transparent and fair. We are committed to implementing our Supplier Code of Conduct to ensure that people and environment impacted by our business operations are treated with respect.
PEOPLE
Suppliers shall be committed to uphold human rights of workers, and to treat them with dignity and respect as understood by the international community. This applies to all workers including temporary, migrant, student, contract, direct employees and any other type of worker.
All suppliers must comply with applicable international and national laws and standards in relation to labour practices and human rights.
Voluntary Employment
Forced, bonded (including debt bondage) or indentured labour or involuntary prison labour: slavery or trafficking of persons shall not be used. This includes transporting, harbouring, recruiting, transferring or receiving persons by means of threat, forced coercion, abduction or fraud for the purpose of labour or service. There shall be no unreasonable restrictions on workers’ freedom of movement including unreasonable restrictions on entering or exiting company-provided facilities. All work must be voluntary, and employees shall be free to terminate their employment in accordance with established laws, regulations, and rules. Employees must not be required to surrender their government issued identification, passports or work permits as a condition of employment.
Child Labour & Young Workers
a) The term “child”refers to any person under the age of 15, or under the age for completing compulsory education, or under the minimum age for employment in the country, whichever is greatest. Child labour should not be used at any level of the supply chain.
b) Young Workers, those under 18 years of age, shall not perform work that is likely to jeopardise their health or safety, including night shifts and overtime. Work shall not interfere with their education or be harmful to their mental, social or moral development.
Working Hours
Working hours are not to exceed the maximum set by law, workers shall not be required to work more than 60 hours per 7-day week, including overtime, except in extraordinary business circumstances. Workers shall be allowed at least one day off every seven days. Overtime shall be compensated at the prevailing overtime rates.
Wages and Benefits
Compensation paid to workers shall comply with all applicable wage laws, including those relating to minimum wages, overtime hours and legally mandated benefits. In compliance with local laws workers shall be compensated for overtime at pay rates greater than regular hourly rates. Deductions from wages as a disciplinary measure shall not be permitted.
Other deductions for accommodation, meals, transport, or personal protective equipment should not exceed minimum costs.
Humane Treatment
There is to be no harsh or inhumane treatment, including
any sexual harassment, sexual abuse, corporal punishment, mental or physical coercion or verbal abuse of workers; nor is there to be the threat of any such treatment. Disciplinary policies and procedures in support of these requirements shall be clearly defined and communicated to workers.
Freedom of Association and Collective Bargaining
Suppliers are to respect the rights of workers to associate freely and communicate openly with management regarding working conditions without fear of harassment, intimidation, penalty, interference or reprisal. Suppliers shall recognise and respect any rights of workers to exercise lawful rights of free association, including joining or not joining any association of their choice. Suppliers must also respect any legal right of workers to bargain collectively.
Labour Hire
Workers shall not be required to pay employers’ or agents’ recruitment fees or other related fees for their employment. If any such fees are found to be have been paid by workers, they must be repaid within 90 days. As part of the hiring process, migrant workers specifically recruited overseas must be provided with a written employment agreement in their native language that contains a description of terms and conditions of employment prior to the worker departing from his or her country of origin. Particular attention should be given to the recruitment and treatment of at risk groups, notably migrant workers, refugees and asylum seekers.
Anti-discrimination
Suppliers shall not discriminate against any worker based on their age, disability, ethnicity, gender, marital status, national origin, political affiliation, race, religion, sexual orientation, or union membership, in hiring and other employment practices such as promotions, rewards and access to training. Workers shall be provided with reasonable accommodation for religious practices. In addition, workers or prospective workers should not be subjected to medical tests or physical exams that could be used in a discriminatory way. Parental and carers leave should be provided for, at a minimum as required by national law.
Equality, Diversity and Community
Suppliers shall promote a culture of enabling a supply chain that includes equality, diversity and actively support programs that look to ensure a diverse worker base. Oppenheimer will continue to, where possible, pursue a strategy of Indigenous Procurement and deepen existing engagement. More broadly, Oppenheimer has a genuine commitment to community engagement across a number of sectors including health, education, the environment and human rights. We seek to engage suppliers that share a passion for creating positive outcomes for local and international communities.
HEALTH AND SAFETY
Every employee has the right to work in a safe and healthy work environment. A safe and healthy work environment also enhances operational performance, increase morale and contributes to employee retention. All suppliers must make a proper provision for the health and safety of their employees, contractors, visitors and those in the community who may be impacted by their operations. Suppliers must comply with applicable international and national laws and standards in relation to health and safety management.
Occupational Safety
Suppliers are required to ensure worker exposure to potential health and safety hazards are controlled in the following order; a) elimination; b) substitution; c) engineering controls; d) administration controls; and e) personal protective equipment. This includes production and other machinery evaluated for safety hazards, as well as worker exposure to chemical and biological agents. Procedures and process are to be in place to ensure the prevention, management, reporting, classification recording and tracking or occupational injury or illness. Procedures must encourage worker reporting, allow for provision of medical treatment, provide mechanisms for investigation and corrective action and facilitate the return of workers to work. Workers should be encouraged to raise health and safety concerns and be empowered to refuse to work in unsafe conditions.
Emergency Preparedness
Potential emergency situations and events are to be identified and assessed, and their impact minimised by implementing emergency plans and response procedures including: emergency reporting, employee notification and evacuation procedures, worker training and drills, appropriate fire detection and suppression equipment, adequate exit facilities and recovery plans. Such plans and procedures shall focus on minimising harm to life, the environment and property.
Welfare
Suppliers shall keep their workplace at a comfortable temperature, have adequate lighting and be suitably ventilated. Work sites shall be adequately clean and hygienic and have sanitary food, preparation, storage and eating facilities. There shall be clean drinking water, clean toilet and washing facilities.
Communication & Training
Suppliers shall provide workers with appropriate and regular workplace health and safety related information and training, including fore training, production safety, and correct use of protective equipment and first aid equipment. Clear safety warning signs, in the primary language of the workers, shall be displayed on relevant equipment and hazardous or toxic substances or objects.
GOVERNANCE
Oppenheimer may verify the compliance of all its direct suppliers with the Code. Such verification will be conducted by way of a supplier self-evaluation or, where agreed, an audit by Oppenheimer (or an external resource designated by Oppenheimer) who may visit the supplier’s facilities with appropriate notice.
Compliance with the principle contained in the Code is a criteria that will be taken into consideration in Oppenheimer’s supplier selection process.
Whenever a situation of non-compliance is identified or a supplier finds it difficult to undertake appropriate measures, this should be reported and shared with the relevant representative of Oppenheimer. As a preferred course of action, Oppenheimer commits to work with suppliers to develop and implement a corrective action plan to improve the situation. Should there be instances of repeated non-conformance, Oppenheimer will regard such conduct as a serious failure to adhere to this Code of Conduct and reserves its rights accordingly.
To raise a concern, the supplier can send an email to:
enquiry@oppenheimer.com.au
Oppenheimer will ensure that all raised compliance issues in the Code are resolved quickly, fairly and at the proper level in Oppenheimer.
