CODE OF CONDUCT

June 2022

It is the desire of International Manufacturing and Logistics, LLC (dba OneSource IML), to not only be a good citizen of the United States, but also to conduct business in an ethical and moral manner in all of the countries of the world in which we have the privilege of doing business. As the scope and breadth of OneSource’s sourcing and customer base expands to include more diverse cultures, we must ensure that the businesspeople and companies with which we associate have the same values that we expect from our own employees. To achieve this end OneSource IML subscribes, and we endeavor to have our business partners subscribe, to the following principles in conducting business.
 

All of OneSource’s business partners should be familiar with the OneSource Company Code of Conduct, as it may be updated from time to time, and OneSource reserves the right to update and make changes to it at any time, with or without notice. If we do update the OneSource Code of Conduct, we will reflect the date of such update at the top of the Code of Conduct. It is the responsibility of each of our business partners to monitor and comply with the OneSource Code of Conduct, as it may be updated, and we encourage our business partners to periodically review the Code of Conduct online or by direct request to a OneSource representative to stay informed about any updates
 

  • Ethical Standards: We endeavor to respect the ethical and moral standards and beliefs of all peoples and cultures with whom we deal. We in turn expect our business partners to respect our rules and procedures.

  • Legal Requirements: We expect our employees and business partners to abide by the laws of the countries in which we conduct business. We also expect that international law related to the conduct of business between Nations be followed at all times.

  • Health and Safety: We strive to have a safe and healthy working environment in all the facilities where we have employees or operations. We also expect that any business partners to whom we provide work will endeavor to provide a safe/healthy environment for the employees in the workplace, and also in the living facilities provided to the workers, should such facilities be provided.

  • Environmental Safekeeping: We understand that the environment in which we live in is ours to maintain and protect. We subscribe to manufacturing practices that ensure the safekeeping of our natural resources and ecological surroundings and expect our business partners to also adhere to these principles.

  • Wages and Benefits: The wage and benefit structure of our business partners must comply with the applicable Country or State laws and OneSource minimum standards.

  • Working Hours: We expect our business partners to operate based on prevailing local work hours. Any time worked over the norm for the area should be compensated at the overtime rate as prescribed by the local labor laws and should be worked voluntarily. Subject to the requirements of local law, a regularly scheduled workweek including overtime should not exceed sixty (60) hours (except in extraordinary business circumstances). All employees are entitled to at least one day off in every seven-day period.

  • Child Labor: The use of child labor is not permissible. For a definition of “child”, we will first look to the national laws of the country in which business is being conducted. If, however, the laws of that country do not provide such a definition or if the definition includes individuals below the age of 15, we will define “child”, for purposes of determining use of illegal child labor, as anyone who is:

    • (a) less than 15 (or 14 where the law of that country permits); or

    • (b) younger than the compulsory age to be in school in the country in which business is being conducted, if that age is higher than 15.

  • Prison/Forced Labor: We will not knowingly utilize or purchase materials and/or product manufactured by prison or forced labor – indentured, bonded or otherwise. We also do not condone the practice of involuntary employee “deposits,” withholding of identity papers or any other practice that would restrict free movement of employees.

  • Discrimination: We recognize and are aware that cultural differences will exist between various peoples. However, we do believe that people should be employed based on their ability to perform a needed function; not on the basis of personal beliefs or characteristics.

  • Freedom of Association: We recognize and respect the right of employees to exercise their lawful rights of free association, including joining or not joining any association. We expect our business partners to also adhere to these principles.

  • Disciplinary Practices: We will not condone any type of harassment, abuse, corporal, mental or physical punishment by a business partner or an employee.


FACTORY

OneSource expects clear, open, and honest communication including all documents, payroll records, timecards, etc. Violation and genuine improvement will always be regarded higher than false documents or hidden violations. OneSource expects the factories and the factory management to maintain the highest standards. No offers of any kind, including but not limited to, gifts, factory products, gratuities or money shall be made or accepted.

All factories are required to receive approval for social responsibility before purchase orders can be issued.

OneSource expects all factory locations to display the Code of Conduct where it is easily viewable to all employees. Suggested areas include near time clocks, entrances to production floor or break rooms. The Code of Conduct should be displayed in the native language of any employees.

 

UFLPA

The Uyghur Forced Labor Prevention Act (UFLPA) establishes a rebuttable presumption that the importation of any goods, wares, articles, and merchandise mined, produced, or manufactured wholly or in part in the Xinjiang Uyghur Autonomous Region of the People’s Republic of China, or produced by certain entities, is prohibited, and that such goods, wares, articles, and merchandise are not entitled to entry to the United States. 

 

To ensure continued cooperative relationships and a strengthening supply chain, OneSource expects all factories guarantee the below:
 

  • Goods are not produced wholly or in part with convict labor, forced labor, and/or indentured labor (including forced or indentured child labor).

  • Goods are not produced wholly or in part in the Xinjiang Uyghur Autonomous Region of the People’s Republic of China (or by an entity included on a list required by the UFLPA). 

    • This includes guaranteeing no raw materials are procured from the above-mentioned region.

  • As a partner you agree to share and abide by 3rd party social compliance standards (such as those in BSCI, Sedex, SMETA).

  • Agree, if requested, to provide raw material supplier information, location, invoices, production records, and transportation documents to ensure purchasing is within approved regions.

  • Agree, if requested, to audits for social compliance and raw material traceability.  
     

OneSource expects not only the final goods factory with which a purchase order is placed to comply to these social compliance requirements and regional limitations, but also expects the factory to ensure that every aspect of its raw material procurement complies as well. This means that the factory with which OneSource is under contract with, is fully obligated to maintain records that show this full-scale traceability. Factory is expected, with every purchase order to confirm contact information, invoices, transportation documents, production output files, and verification of raw material supplies.

 

In addition, factory confirms that no aspect of its supply chain is done with the businesses or subsidiaries in the below US government lists:

 

 


Any non-compliance or lack of disclosure may result in cancellation of Purchase Order, destruction of goods, and transportation/fee liability.

 

SECURITY REQUIREMENTS (C-TPAT)

OneSource and many of its customers are partners in the US Customs-Trade Partnership Against Terrorism (C-TPAT) program. As such, it may be necessary for the vendor/factory to be familiar with the C-TPAT minimum security criteria and take the necessary steps to ensure their security procedures are in compliance with the C-TPAT program. Factories will be required to meet C-TPAT standards and be reviewed by independent monitors. The C-TPAT Foreign Partner Letter, C-TPAT Manufacturer’s Minimum Security Criteria (MSC) and Questionnaire, Container Inspection, Seal Inspection, OneSource General Factory Audit, and the OneSource Social Accountability Audit documents are attached below for reference.
 

  • Partner Letter

  • Manufacturer’s Minimum Security Criteria Checklist and Questionnaire

  • Container Inspection Checklist

  • Seal Inspection

  • OneSource General Factory Audit

  • OneSource Social Accountability Audit

 

INDEPENDENT REVIEW

Factories may be accepted independently by undergoing an audit by an independent third-party auditor. The results of the audit will determine what level of acceptance the factory receives and if the factory is required to make improvements or commit to making improvements before acceptance is granted.

OneSource will designate the audit firm that will be used to conduct the third-party audit. At no time may a factory designate an audit firm.

Based on the results of an audit or re-audit a factory will be assigned a rating. OneSource expects each factory to continuously work toward achieving higher acceptance levels. The acceptance level is reported on the vendor scorecard and factors into the overall vendor rating.

Frequently social compliance violations are caused by other factors in the factory. Excessive overtime may be caused by late planning and expedited orders from customers or inefficient production planning in the factory. Recordkeeping issues might be caused by inconsistent control of documents. Health and safety violations may be caused by a lack of understanding of requirements or limited safety resources. We encourage factories to find help identifying and eliminating the underlying problems. It is our belief that if the systemic issues are corrected, not only will the social compliance rating improve but the factory operation (delivery, profit, etc.) will also improve.

However, non-negotiable failures as the below points are ground for cessation of business with legal and financial penalties:
 

  • Goods are not produced wholly or in part with convict labor, forced labor, and/or indentured labor (including forced or indentured child labor).

  • Goods are not produced wholly or in part in the Xinjiang Uyghur Autonomous Region of the People’s Republic of China (or by an entity included on a list required by the UFLPA). 

    • This includes guaranteeing no raw materials are procured from the above-mentioned region.

 

SUB-CONTRACTING

Suppliers are not allowed to subcontract OneSource production without written permission from the OneSource. Any subcontractor must go through the normal enrollment and approval process and meet the acceptance standards before production can begin.

Upon discovery of unauthorized subcontracting, the subcontractor and the primary factory will be subject to review of OneSource standards. Depending on the result of the review, penalties will be assessed, including but not limited to, charge backs and destruction of the goods.