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Environmental and Ethical Conduct Charter for Suppliers

Environmental responsibility and ethical conduct is a key commitment of Po-Zu. The suppliers are required to guarantee safe working conditions, treat workers with dignity and respect, act fairly and ethically, and use environmentally responsible practices wherever they produce resources for Po-Zu. Suppliers are required to operate with respect for the principles incorporated in this Code of Conduct and in compliance with the applicable laws and regulations. As Po-Zu wants to go beyond compliance with law, this Code of Conduct incorporates the principles included in recognised international standards. The following Code of Conduct incorporates the expectations for each supplier regarding labor and human rights, health and safety, environmental protection, ethics and management practices.

Po-Zu requires its suppliers’ compliance with the following code, and any violations of this Code could harm the business relationship with Po-Zu, which could lead to termination. This Code of Conduct applies to the Po-Zu’s direct suppliers as well as their subsidiaries, affiliates, and subcontractors providing goods or services to Po-Zu.

Labour and Human Rights
This code serves to ensure that all workers throughout the supply chain of Po-Zu are treated in a fair and ethical way. All workers shall be treated with dignity and respect, while respecting human rights to its highest standard.

Supplier shall not discriminate against any worker based on age, disability, ethnicity, gender, marital status, national origin, political affiliation, race, religion, sexual orientation, or union membership, in hiring and other employment practices. Supplier shall not require pregnancy or medical tests, except where required by applicable laws or regulations or prudent for workplace safety, and shall not improperly discriminate based on test results.

Anti-Harassment and Abuse
Supplier shall commit to a workplace free of harassment and abuse. Supplier shall not threaten workers with, or subject them to, harsh or inhumane treatment, including but not limited to verbal abuse and harassment, psychological harassment, mental and physical coercion, and sexual harassment.

Prevention of Involuntary Labor and Human Trafficking
Supplier shall ensure that all work is voluntary. Supplier shall not traffic persons or use any form of slave, forced, bonded, indentured, or prison labor. Involuntary labor includes the transportation, harboring, recruitment, transfer, receipt, or employment of persons by means of threat, force, coercion, abduction, fraud, or payments to any person having control over another person for the purpose of exploitation.

Supplier shall not withhold workers’ original government-issued identification and travel documents. Supplier shall ensure that workers’ contracts clearly convey the conditions of employment in a language understood by the workers. Supplier shall not impose unreasonable restrictions on movement within the workplace or upon entering or exiting company-provided facilities.

Supplier shall ensure that the third-party recruitment agencies it uses are compliant with the provisions of this Code and the law. Suppliers recruiting foreign contract workers either directly or through third party agencies shall be responsible for payment of all fees and expenses in excess of one month of the worker’s anticipated net wages.

Prevention of Underage Labor
Supplier shall employ only workers who are at least 15 years of age or the applicable minimum legal age, whichever is higher. Supplier may provide legitimate workplace apprenticeship programs for educational benefit that are consistent with Article 6 of ILO Minimum Age Convention No. 138 or light work consistent with Article 7 of ILO Minimum Age Convention No. 138.


Juvenile Worker Protections
Supplier may employ juveniles who are older than the applicable legal minimum age but are younger than 18 years of age, provided they do not perform work that might jeopardize their health, safety, or morals, consistent with ILO Minimum Age Convention No. 138. Supplier shall not require juvenile workers to work overtime or perform night work.


Student Worker Protections
Supplier shall ensure proper management of student workers through proper maintenance of student records, rigorous due diligence of educational partners, and protection of students’ rights in accordance with applicable law and regulations. Supplier shall provide appropriate support and training to all student workers.


Working Hours
A work week shall be restricted to 60 hours, including overtime, and workers shall take at least one day off every seven days except in emergencies or unusual situations. Supplier shall follow all applicable laws and regulations with respect to working hours and days of rest, and all overtime must be voluntary.


Wages and Benefits
Supplier shall ensure that all workers receive at least the legally mandated minimum wages and benefits. Supplier shall offer vacation time, leave periods, and time off for legally recognized holidays. Supplier shall compensate workers for overtime hours at the legal premium rate. Supplier shall communicate pay structure and pay periods to all workers. Supplier shall pay accurate wages in a timely manner, and wage deductions shall not be used as a disciplinary measure.


Freedom of Association and Collective Bargaining
As legally permitted, Supplier shall freely allow workers to associate with others, form, and join (or refrain from joining) organizations of their choice, and bargain collectively, without interference, discrimination, retaliation, or harassment. In the absence of formal representation, Supplier shall ensure that workers have a mechanism to report grievances and that facilitates open communication between management and workers.

Health and Safety
Po-Zu puts emphasis on workers’ health and safety. Workers shall be guaranteed a safe work environment and the supplier shall integrate robust health and safety management practices. Workers shall have the right to refuse unsafe work and to report unhealthy working conditions.

Occupational Health, Safety, and Hazard Prevention
Supplier shall identify, evaluate, and manage occupational health and safety hazards through a prioritized process of hazard elimination, engineering controls, and/or administrative controls. Supplier shall provide workers with job-related, appropriately maintained personal protective equipment and instruction on its proper use.

Emergency Prevention, Preparedness, and Response
Supplier shall identify and assess potential emergency situations. For each situation, Supplier shall develop and implement emergency plans and response procedures that minimize harm to life, environment, and property.

Incident Management
Supplier shall have a system for workers to report health and safety incidents and nearmisses, as well as a system to investigate, track, and manage such reports. Supplier shall implement corrective action plans to mitigate risks, provide necessary medical treatment, and facilitate workers’ return to work.

Supplier shall identify, evaluate, and control worker exposure to tasks that pose ergonomic risk such as excessive force, improper lifting positions, or repetitiveness. Supplier shall integrate this process into the qualification of all new or modified production lines, equipment, tools, and workstations.

Working and Living Conditions
Supplier shall provide workers with reasonably accessible and clean toilet facilities and potable water. Supplier-provided dining, food preparation, and storage facilities shall be sanitary. Worker dormitories provided by Supplier or a third-party shall be clean and safe and provide reasonable living space.

Health and Safety Communication
Supplier shall provide workers with appropriate workplace health and safety training in their primary language. Health and safety related information shall be clearly posted in the facility.

Worker Health and Safety Committees
Supplier is encouraged to initiate and support worker health and safety committees to enhance ongoing health and safety education and to encourage worker input on, and participation in, health and safety issues in the workplace.

Protecting the planet and environmental responsibility is at the core of the values of Po-Zu. All shall develop, implement, and engage in environmentally responsible business practices.

Hazardous Substance Management and Restriction
Supplier shall implement a systematic approach to identify, manage, reduce, and responsibly dispose of or recycle hazardous substances. Supplier shall comply with Po-Zu’s Regulated Substances Specification for all goods it manufactures for and provides to Po-Zu.

Non-Hazardous Waste Management
Supplier shall implement a systematic approach to identify, manage, reduce, and responsibly dispose of or recycle non-hazardous waste.

Wastewater Management
Supplier shall implement a systematic approach to identify, control, and reduce waste water produced by its operations. Supplier shall conduct routine monitoring of the performance of its wastewater treatment systems.

Storm water Management
Supplier shall implement a systematic approach to prevent contamination of storm water runoff. Supplier shall prevent illegal discharges and spills from entering storm drains.

Air Emissions Management
Supplier shall identify, manage, reduce, and responsibly control air emissions emanating from its operations that pose a hazard to the environment. Supplier shall conduct routine monitoring of the performance of its air emission control systems.


Boundary Noise
Supplier shall identify, control, monitor, and reduce noise generated by the facility that affects boundary noise levels.

Environmental Permits and Reporting
Supplier shall obtain, keep current, and comply with all required environmental permits. Supplier shall comply with the reporting requirements of applicable permits and regulations.

Pollution Prevention and Resource Reduction
Supplier shall reduce energy, water, and natural resource consumption by implementing conservation and substitution measures. Supplier shall minimize hazardous substances consumption by implementing reduction and substitution measures.


Po-Zu expects the highest standards of ethical conduct from its suppliers in every aspect of its business, including relationships, practices, sourcing, and operations.

Business Integrity
Supplier shall not engage in corruption, extortion, embezzlement, or bribery to obtain an unfair or improper advantage. Supplier shall abide by all applicable anti-corruption laws and regulations of the countries in which it operates, including the Foreign Corrupt Practices Act (FCPA) and applicable international anti-corruption conventions.

Disclosure of Information
Supplier shall accurately record information regarding its business activities, labor, health and safety, and environmental practices and shall disclose such information, without falsification or misrepresentation, to all appropriate parties.

Protection of Intellectual Property
Supplier shall respect intellectual property rights and safeguard customer information. Supplier shall manage technology and know-how in a manner that protects intellectual 
property rights.

Anonymous Complaints
Supplier shall provide an anonymous complaint mechanism for managers and workers to report workplace grievances.

Community Engagement
Supplier is encouraged to help foster social and economic development and contribute to the sustainability of the communities in which it operates.

Responsible Sourcing of Minerals
Supplier shall exercise due diligence, in accordance with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and HighRisk Areas, on its entire supply chain with respect to the sourcing of all tin, tantalum, tungsten, diamonds and gold contained in its products, to determine whether those metals are from the Democratic Republic of the Congo (“DRC”) or any adjoining country and, if so, to determine whether those metals directly or indirectly financed or benefited armed groups that are perpetrators of serious human rights abuses in the DRC or an adjoining country. Countries that adjoin the DRC are Angola, Burundi, Central African Republic, the Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia.

Management Commitment
Po-Zu believes that a robust management system and commitment lead to enriching the social and environmental well-being of the supply chain. Po-Zu holds its suppliers accountable to this Code and the supplier shall implement or maintain, as applicable, a management system that facilitates compliance with this Code, while ensuring continuous improvement.

Company Statement
Supplier shall develop a company statement affirming its commitment to high standards of social and environmental responsibility, ethical conduct, and continuous improvement. Supplier shall post this statement in the primary local language at all of its facilities.

Management Accountability and Responsibility
Supplier shall identify company representatives responsible for ensuring implementation and periodic review of its management systems. Supplier shall have a Corporate Social Responsibility (CSR) or Sustainability representative that reports directly to executive management and has the responsibility and authority to manage social and environmental compliance requirements for the business.

Risk Assessment and Management
Supplier shall develop and maintain a process to identify labor and human rights, health and safety, environmental, business ethics, and legal compliance risks associated with its operations; determine the relative significance of each risk; and implement appropriate procedures and controls to control the identified risks.


Performance Objectives with Implementation Plans and Measures
Supplier shall have written standards, performance objectives, targets, and implementation plans, including periodic assessments of the performance against those objectives.

Audits and Assessments
Supplier shall perform periodic evaluations of its facilities and operations, and the facilities and operations of its subcontractors and next-tier suppliers to ensure compliance with this Code and the law.

Documentation and Records
Supplier shall have processes to identify, understand, and implement applicable laws and regulations and requirements of this Code. Suppliers shall maintain documents and records to ensure regulatory compliance.

Training and Communication
Supplier shall develop and maintain management and worker training programs to facilitate proper implementation of its policies and procedures and to fulfill Supplier’s continuous improvement objectives.

Supplier shall have a process for communicating clear and accurate information about its performance, practices, policies, and expectations to its workers, next-tier supplier(s), and customers.

Supplier shall have an ongoing process to obtain feedback on its practices related to this code and to foster continuous improvement.


Corrective Action Process
Supplier shall have a process for timely correction of any deficiencies or violations identified by an internal or external audit, assessment, inspection, investigation, or review.