Supplier Code of Conduct

ETHICS

Suppliers shall conduct their business in an ethical manner and act with integrity.

BUSINESS INTEGRITY AND FAIR COMPETITION

All corruption, extortion and embezzlement are prohibited. Suppliers shall not pay or accept bribes or participate in other illegal inducements in business or government relationships. Suppliers shall conduct their business consistent with fair and vigorous competition and in compliance with all applicable anti-trust laws. Suppliers shall employ fair business practices, including accurate and truthful advertising.

IDENTIFICATION OF CONCERNS

All workers should be encouraged to report concerns or illegal activities in the workplace, without threat of reprisal, intimidation or harassment. Suppliers shall investigate and take corrective action if needed.

PRIVACY

Suppliers shall safeguard and make only proper use of confidential information to ensure that company and worker privacy rights are protected.

LABOR

Suppliers shall be committed to uphold the human rights of workers and to treat them with dignity and respect.

FREELY CHOSEN EMPLOYMENT

Suppliers shall not use forced, bonded, indentured or involuntary prison labor. Workers are not required to lodge “deposits” or their identity papers with their employer and are free to leave their employer after reasonable notice. Chicken of the Sea prohibits any use of slavery or human trafficking in its supply chain, and Suppliers shall take reasonable precautions to ensure that its own suppliers do not engage in these practices.

CHILD LABOR AND YOUNG WORKERS

Suppliers shall not use child labor. The term “child” refers to any person employed under the age of 15 (or 14 where the law of the country permits), or under the age for completing compulsory education, or under the minimum age for employment in the country, whichever is greatest. We support the use of legitimate workplace apprenticeship programs which comply with all laws and regulations applicable to such apprenticeship programs.

NON-DISCRIMINATION

Suppliers shall provide a workplace free of harassment and discrimination. Discrimination for reasons such as race, color, age, gender, sexual orientation, ethnicity, disability, religion, political affiliation, union membership or marital status is not tolerated. Suppliers shall further comply with all provisions of Executive Orders 11246 and 11375 related to equal employment opportunity, including providing necessary documentation to the US Federal Government to ascertain compliance with such rules, regulations and orders.

FAIR TREATMENT

Suppliers shall provide a workplace free of harsh and inhumane treatment, including any sexual harassment, sexual abuse, corporal punishment, mental or physical coercion or verbal abuse of workers and no threat of any such treatment.

WAGES, BENEFITS AND WORKING HOURS

Suppliers shall pay workers according to applicable wage laws, including minimum wages, overtime hours and mandated benefits.

All workers shall be provided with written and understandable information about their employment conditions in respect to wages before they enter employment and about the particulars of their wages for the pay period concerned each time that they are paid. Suppliers are also expected to communicate with the worker whether overtime is required and the wages to be paid for such overtime.

Deductions from wages as a disciplinary measure shall not be permitted nor shall any deductions from wages not provided for by national law be permitted without the expressed permission of the worker concerned. All disciplinary measures should be recorded.

FREEDOM OF ASSOCIATION

Suppliers shall respect the rights of workers, as set forth in local laws, to associate freely, join or not join labor unions, seek representation and join workers’ councils. Where the right to freedom of association and collective bargaining is restricted under law, the Supplier facilitates, and does not hinder, the development of parallel means for independent and free association and bargaining.

Open communication and direct engagement with workers to resolve workplace and compensation issues is encouraged. Workers shall be able to communicate openly with management regarding working conditions without threat of reprisal, intimidation or harassment.

HEALTH AND SAFETY

Suppliers shall provide a safe and healthy working environment, including for any company-provided living quarters.

WORKER PROTECTION

Suppliers will provide their employees with a safe and healthy workplace in compliance with all applicable laws and regulations. A safe and hygienic working environment shall be provided, bearing in mind the prevailing knowledge of the industry and of any specific hazards. Adequate steps shall be taken to prevent accidents and injury to health arising out of, associated with, or occurring in the course of work, by minimizing, so far as is reasonably practicable, the causes of hazards inherent in the working environment.

WORKER TRAINING

Workers shall receive regular and recorded health and safety training, and such training shall be repeated for new or reassigned workers.

SANITATION AND HYGIENE

Access to clean toilet facilities and to potable water, and, if appropriate, sanitary facilities for food storage shall be provided. Accommodation, where provided, shall be clean, safe, and meet the basic needs of the workers.

EMERGENCY PREPAREDNESS AND RESPONSE

Suppliers shall identify and assess emergency situations in the workplace and any company-provided living quarters, and minimize their impact by implementing emergency plans and response procedures.

ENVIRONMENT

Suppliers shall operate in an environmentally responsible and efficient manner, and they shall minimize adverse impacts on the environment. Suppliers are encouraged to conserve natural resources, to avoid the use of hazardous materials where possible and to engage in activities that reuse and recycle.

ENVIRONMENTAL AUTHORIZATIONS

Suppliers shall comply with all applicable environmental regulations. All required environmental permits, licenses, information registrations and restrictions shall be obtained and their operational and reporting requirements followed. Suppliers must also comply with any additional environmental requirements specific to the products or services being provided to Chicken of the Sea International as called for in design and product specifications, and contract documents.

WASTE AND EMISSIONS

Suppliers shall have systems in place to ensure the safe handling, movement, storage, recycling, reuse or management of waste, air emissions and wastewater discharges. Any waste, wastewater or emissions with the potential to adversely impact human or environmental health shall be appropriately managed, controlled and treated prior to release into the environment.

SPILLS AND RELEASES

Suppliers shall have systems in place to prevent and mitigate accidental spills and releases to the environment.

MANAGEMENT SYSTEMS

Suppliers shall use management systems to facilitate continual improvement and compliance with the expectations of these principles.

COMMITMENT AND ACCOUNTABILITY

Suppliers shall demonstrate commitment to the concepts described in this document by allocating appropriate resources. Suppliers must make this Code of Conduct and other relevant information available to employees in the native language(s) of the employees and supervisors.

LEGAL AND CUSTOMER REQUIREMENTS

Suppliers shall identify and comply with applicable laws, regulations, standards and relevant customer requirements. Suppliers must maintain documentation necessary to demonstrate compliance with this Code of Conduct and must provide Chicken of the Sea International with access to that documentation upon its request.

In the event of Supplier’s noncompliance with this Code on Conduct, current Orders and ongoing relationship may be cancelled, terminated, or suspended in whole or in part and the Supplier may be declared ineligible for further Purchase Orders by Chicken of the Sea International.

NONCOMPLIANCE PROCEDURES

The provisions of this Code constitute minimum and not maximum standards, and this Code should not be used to prevent companies from exceeding these standards. Companies applying this code are expected to comply with national and other applicable law and, where the provisions of law and this Code of Conduct address the same subject, to apply that provision which affords the greater protection.