RBA Supplier Code of Conduct

Preface

This Supplier Code of Conduct is established in accordance with Version 8.0 of the Responsible Business Alliance (RBA) Code of Conduct. Its purpose is to ensure the protection of labor rights, occupational safety, environmental responsibility, and business ethics, while building a sustainable, compliant, and socially responsible supply chain.

Suppliers shall commit to complying with this Code and operate in accordance with the laws and regulations of their respective jurisdictions. Suppliers shall also require their subcontractors and secondary suppliers (e.g., dormitory, cleaning, and security service providers) to acknowledge and implement this Code.

A. Labor

Suppliers shall uphold internationally recognized standards and commit to respecting and protecting the fundamental rights and dignity of all types of workers, including temporary workers, migrant workers, student workers, contract workers, and direct employees. Refer to the appendix for applicable standards used in system development and continuous improvement.

1. 1.Prohibition of Forced Labor

• •Human trafficking, bonded labor, document retention, and recruitment fees are strictly prohibited
• •Employment contracts must be provided in the worker’s native language prior to departure, and may not be altered upon arrival
• •All work must be voluntary; workers may resign freely without penalty
• •Termination documents must be properly retained, and workers must have unrestricted access to personal identification

2.       2.Protection of Young Workers

• •Child labor is prohibited (under age 15 or below the legal minimum employment age)
• •Workers under 18 shall not engage in hazardous work, night shifts, or overtime
• •Student workers must be covered by formal educational partnerships and receive fair pay and protection

3.       3.Working Hours

• •Total working hours shall not exceed 60 hours per week, including overtime, and must comply with local laws
• •Overtime must be voluntary, with signed consent and clear wage calculation
• •Workers must receive at least one day off every seven days and may not work more than six consecutive days

4.       4.Wages and Benefits

• •Compensation must meet minimum wage laws and include itemized pay slips and lawful deductions
• •Wage deductions shall not be used as disciplinary measures
• •Temporary, migrant, and contract workers shall receive the same statutory benefits as regular employees

5.       5.Humane Treatment and Anti-Harassment

• •Physical abuse, verbal abuse, sexual harassment, corporal punishment, and psychological coercion are prohibited
• •Suppliers shall establish grievance channels and provide anti-harassment training and procedures

6.       6.Non-Discrimination and Equal Opportunity

• •Discrimination based on gender, age, race, religion, sexual orientation, disability, etc., is prohibited
• •Discriminatory medical tests, such as pregnancy or virginity checks, are strictly prohibited

7.       7.Freedom of Association and Labor Dialogue

• •Workers shall have the right to form or join labor unions and engage in collective bargaining
• •Regular labor-management meetings shall be held, and worker representatives shall be protected from retaliation

B. Health and Safety

Suppliers shall recognize that a safe and healthy work environment not only reduces occupational risks but also improves service quality and workforce stability. Continuous feedback collection and training are essential to workplace safety improvement.

1. 1.Occupational Safety

• •Provide PPE, safety training, risk assessments, and lockout/tagout (LOTO) procedures
• •Special protections shall be provided for pregnant and nursing workers, including lactation rooms and adjusted duties

2.       2.Emergency Preparedness

• •Conduct annual fire and earthquake evacuation drills
• •Maintain escape route maps, fire extinguishers, emergency lighting, and conduct regular inspections

3.       3.Injury and Illness Management

• •Establish systems for injury reporting, compensation, return-to-work tracking, and documentation
• •Provide health checks and follow-up for abnormal results

4.       4.Industrial Hygiene and Physical Demands

• •Assess and improve high-load tasks such as repetitive lifting, prolonged standing, and manual handling
• •Provide anti-fatigue mats, assistive tools, and rest arrangements

5.       5.Machine Safety and Protection

• •Inspect and maintain safety guards for forklifts, elevators, and other equipment
• •Provide operator training and valid certifications

6.       6.Public Health and Housing

• •Dormitories shall meet fire safety, ventilation, lighting, sanitation, and personal storage standards
• •Canteens and drinking water facilities shall be regularly inspected and comply with hygiene regulations

7.       7.Health and Safety Communication

• •All safety information and training shall be provided in languages workers understand
• •Post safety notices and encourage workers to report hazards proactively

C. Environmental Responsibility

Suppliers shall recognize that environmental protection is essential to sustainability and quality management. Operations shall minimize impact on communities, natural resources, and the environment, while safeguarding public health.

1. 1.Environmental Permits and Reporting

• •Obtain necessary permits for dormitories, kitchens, and cleaning operations, and submit regular reports
• •Maintain and update relevant registrations, operational records, and emission logs

2.       2.Pollution Prevention and Resource Conservation

• •Prohibit illegal waste disposal and pollutant discharge
• •Promote energy saving, waste reduction, and recycling, with documented improvements

3.       3.Hazardous Substance Management

• •For cleaning and chemical use, provide SDS, safety labeling, and proper storage
• •Hazardous waste shall be handled by licensed contractors, with contracts and disposal records retained

4.       4.Solid Waste and Air Emissions

• •Classify, record, and properly dispose of general and hazardous waste
• •Monitor and report air emissions in accordance with regulations

5.       5.Water Resource Management

• •Install water-saving devices in dormitories and offices, and track usage
• •Wastewater discharge shall comply with laws and be regularly tested

6.       6.Energy and Greenhouse Gas Management

• •Record electricity, fuel, and other energy usage
• •Promote LED lighting, HVAC optimization, and set carbon reduction targets

D. Business Ethics

To fulfill social responsibility and succeed in the marketplace, suppliers and their agents must uphold the highest ethical standards:

1. 1.Integrity and Anti-Corruption

• •Bribery, kickbacks, and improper benefits are strictly prohibited
• •Establish anti-corruption policies, training, and monitoring systems

2.       2.Transparency and Disclosure

• •Recruitment processes, fees, and wage structures must be clearly disclosed in writing
• •Falsifying worker data or concealing contract terms is prohibited

3.       3.Data Privacy and Protection

• •Personal data shall be handled in accordance with applicable privacy laws
• •Unauthorized disclosure or misuse of data is prohibited

4.       4.Grievance and Non-Retaliation Mechanism

• •Provide anonymous reporting channels and prohibit retaliation against whistleblowers
• •Establish procedures for handling complaints and providing feedback

5.       5.Fair Trade and Competition

• •Unfair competition, misleading advertising, and exclusionary practices are prohibited
• •All business conduct shall adhere to fair trade principles

6.       6.Responsible Sourcing and Mineral Origin

• •If conflict minerals or outsourced suppliers are involved, conduct due diligence and provide CMRT
• •Require secondary suppliers to sign and comply with this Code

7.       7.Avoidance of Conflicts of Interest

• •Disclose any potential conflicts of interest with clients
• •Prohibit private deals, nepotism, or inappropriate social interactions

E. Management System

Suppliers shall establish a management system aligned with this Code to ensure legal compliance, meet customer requirements, implement Code provisions, and effectively identify and control operational risks while driving continuous improvement.

1. 1.Company Commitment and Policy Statement

• •Senior management shall sign and publicly post policies on human rights, safety, environment, and ethics
• •Policies shall be communicated in languages employees understand and included in training

2.       2.Roles and Responsibilities

• •Assign dedicated personnel to lead system implementation and audit response
• •Senior management shall regularly review system performance

3.       3.Legal and Customer Requirements

• •Maintain a tracking system for laws and customer requirements
• •Update regularly and include in internal audit scope

4.       4.Risk Assessment and Control

• •Establish risk identification processes covering labor, safety, environment, and ethics
• •Define control measures and improvement plans based on risk levels

5.       5.Performance Targets and Monitoring

• •Set annual goals (e.g., injury rate, overtime hours, carbon emissions) and monitor progress
• •Include performance in management reviews and improvement cycles

6.       6.Training and Education

• •Develop annual training plans covering policies, risks, grievance handling, PPE, and data security
• •Retain materials, attendance records, and effectiveness evaluations

7.       7.Communication and Engagement

• •Establish internal and external communication channels, including labor meetings, supplier exchanges, and customer feedback
• •Encourage employee input and protect against retaliation

8.       8.Audit and Evaluation

• •Conduct annual self-assessments and internal audits
• •Cooperate with customer audits and implement corrective actions

9.       9.Corrective and Preventive Actions (CAPA)

• •Implement CAPA procedures for violations or grievances, including root cause analysis and follow-up
• •Assign responsible personnel, deadlines, and tracking records

10.  10.Documentation and Recordkeeping

• •Maintain system documents and records per legal and customer retention requirements
• •Protect personal and sensitive data through encryption, classification, and access control

11.  11.Supplier Responsibility Extension

• •Require secondary suppliers to sign this Code or equivalent standards
• •Conduct risk assessments and due diligence, and establish oversight and audit mechanisms
• •Provide contracts, audit reports, or improvement records upon request