Code of Conduct

Our comittement / Code of Conduct


Introduction

In Tharaldsen AS we strongly believe in running a social responsible business. It is therefore vital for us to take responsibility for all our actions.

This Code of Conduct is based on, and reflects our commitment to respect and promote,

internationally agreed standards. We promote decent working and environmental standards in our supply chains. We cooperate closely with our suppliers and business partners in pursuit of this aim. In order to make our position clear to our suppliers, our own staff, and all other stakeholders, we have prepared this Code of Conduct. The Code of Conduct covers fundamental requirements for human rights, labour rights, ethical and environmental requirements, and anti-corruption in all our daily practices, including all our supply chains.


Principles

The business relationship between Tharaldsen AS and its suppliers is based on mutual respect,

and all parties should upkeep a good and constructive dialogue in pursuit of this Code of

Conduct.

We at Tharaldsen AS expect our suppliers to supply goods and services that are produced in

compliance with this code of conduct. We further expect our suppliers to communicate the

requirements of this Code of Conduct to their sub-suppliers and to monitor their work

towards compliance with the requirements.


Requirements relating to own practice

Our goal is to use our influence to work for respect for human rights, ethical trade and sustainable production processes, both within the company and towards our business partners. Tharaldsen AS shall contribute to continuous training for key personnel and its business partners regarding the goals and principles of this Code of Conduct. Tharaldsen AS will, when choosing suppliers, consider ethical and environmental criteria.


Fulfilment of these criteria is considered a competitive advantage.


Tharaldsen AS, and all Tharaldsen AS´s employees, do not accept any offers or any illegal or unlawful monetary gifts, or any other form of remuneration, in order to secure a business related or private benefit.


Tharaldsen AS and Tharaldsen AS´s suppliers shall avoid partners that operate in countries subject to international boycott by the United Nations or boycott by Norwegian Authorities. Tharaldsen AS will continuously evaluate and, improve our own policies and practices in order to

facilitate suppliers and sub-suppliers compliance with this Code of Conduct. We will do this in dialogue with our suppliers and other stakeholders.


Requirements to Supply Chain Conditions

The Suppliers of Tharaldsen AS should continuously work for the production of goods and

services to take place in compliance with the below mentioned internationally recognised

and defined standards.

As a general rule, the Suppliers must also ensure that their sub- suppliers comply with these

standards. Contract workers, day labourers and casual workers of the Suppliers or subsuppliers

must be included in this work as well.

Under certain political and/or cultural circumstances it may prove difficult to comply with

certain standards or to obtain the identities of or contact with all subcontractors. Under such

circumstances, one may choose an alternative and appropriate approach.

Suppliers are required to reach the primary goals of this Code of Conduct within a reasonable

timeframe and this will, as a rule, be a prerequisite for further trading with Tharaldsen AS.

Failure to improve the conditions will lead to considerations from Tharaldsen AS as whether to

end the business relationship with the respective Supplier. This will happen only when

3 repeated requests from Tharaldsen AS are ignored and/or upon failure to prove promised

improvements.


1. Forced and compulsory labour (ILO Conventions Nos. 29 and 105)

• There shall be no forced, bonded or involuntary prison labour.

• Workers shall not be required to lodge deposits or identity papers with their

employer and shall be free to leave their employer after reasonable notice.


2. Union Rights and the Right to Collective Bargaining (ILO Conventions Nos. 87, 98, 135

and 154)

• Workers, without distinction, shall have the right to join or form trade unions of their

own choosing and to bargain collectively. The employer shall not interfere with,

obstruct, the formation of unions or collective bargaining.

• Workers’ representatives shall not be discriminated and shall have access to carry out

their representative functions in the workplace.


3. Child Labour (UN Convention on the Rights of the Child (ILO Conventions Nos. 138, 182

and 79, and ILO Recommendation No. 146)

• The minimum age for workers shall not be less than 16 and comply with

i) the national minimum age for employment, or;

ii) the age of completion of compulsory education, whichever of these is higher.

If local minimum is set at 14 years in accordance with developing country exceptions

under ILO Convention 138, this lower age may apply.

• There shall be no recruitment of child labour defined as any work performed by a

child younger than the age(s) specified above.

• No person under the age of 18 shall be engaged in labour that is hazardous to their

health, safety or morals, including night work, or that is damaging to their education.

• Policies and procedures for remediation of child labour prohibited by ILO conventions

no. 138 and 182, shall be established, documented, and communicated to personnel

and other interested parties. Adequate support shall be provided to enable such

children to attend and complete compulsory education.


4. Discrimination (ILO Conventions Nos. 100 and 111 and the UN Convention on

Discrimination Against Women)

• There shall be no discrimination at the workplace in hiring, compensation, access to

training, promotion, termination or retirement based on ethnic background, caste,

religion, age, disability, gender, marital status, sexual orientation, union membership

or political affiliation.

• Measures shall be established to protect workers from sexually intrusive, threatening,

insulting or exploitative behaviour, and from discrimination or termination of

employment on unjustifiable grounds, e.g. marriage, pregnancy, parenthood or HIV

status.


5. Harsh or Inhumane Treatment (UN Covenant on Civil and Political Rights, Art. 7)

• Physical abuse or punishment, or threats of physical abuse, sexual or other

harassment and verbal abuse, as well as other forms of intimidation, is prohibited.


6. Health and Safety (ILO Convention No. 155 and ILO Recommendation No. 164)

Working conditions shall at a minimum comply with national occupational health and safety

regulations, and with international standards where domestic regulation is insufficient or

unspecified.

• The working environment shall be safe and hygienic, bearing in mind the prevailing

knowledge of the industry and of any specific hazards.

• There shall be access to clean toilet facilities in sufficient number and to potable

water. If appropriate, sanitary facilities for food storage shall be provided. Break areas

(such as a canteen) must be located separately from the production area and be clean

and in a good condition.

• Accommodation, where provided, shall be clean, safe and adequately ventilated, and

shall have access to clean toilet facilities and potable water.

• The factory shall ensure that the noise level is acceptable. The lighting must be

sufficient to ensure a safe working environment.

• There shall be proper ventilation, windows, fans, air conditioning and /or heating in

all workplaces, to meet circulation, ventilation, temperature and moisture

requirements.

• Each factory are required to have sufficient first aid equipment, which shall be clearly

marked and available for all workers. An adequate number of persons skilled in first

aid shall be present during working hours. There shall be routines for handling serious

injuries requiring outside medical attention.

• Suppliers shall secure protective measures to ensure the safety and health of

pregnant workers and new mothers. This includes temporary reassignments away

from work stations and work environments that may pose a risk to the health of

pregnant women and their unborn children. This may also include temporary

adjustments of working hours. Factories shall provide new mothers with

breast-feeding breaks and facilities.

• Machines shall have appropriate and functional safety devices which shall be

maintained on a regular basis. Safety instructions relevant to the machinery shall be

available in an understandable language.

• Workers shall receive regular and documented health and safety training, and such

training shall be repeated for new or reassigned workers.

• Responsibility for health and safety shall be assigned to a management

representative. Active cooperation between management and workers, and/or their

representatives, is essential to develop and implement systems for ensuring a safe

and healthy work environment. This may be achieved through the establishment of

Occupational Health and Safety Committees.

• Workers shall be equipped with appropriate personal safety equipment (PPE) free of

charge. Training shall be provided on proper use of such equipment. Areas where PPE

is needed are clearly marked.

• Hazardous chemicals and other substances shall be carefully managed. 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 minimising, so far as is

reasonably practicable, the causes of hazards inherent in the working environment.

• Risk areas and potential hazards shall be clearly marked by warning signs in

appropriate languages with pictograms, if possible.


7. Wages (ILO Convention No. 131)

• Wages and benefits paid for a standard working week shall as minimum meet

national legal standards or industry benchmark standards, whichever is higher. Wages

should always be enough to meet basic needs, including some discretionary income.

• All workers shall be provided with a written and comprehensible contract outlining

their wage conditions and method of payments before entering employment.

• Deductions from wages as a disciplinary measure shall not be permitted.


8. Working Hours (ILO Convention No. 1 and 14)

• Working hours shall comply with national laws and benchmark industry standards,

and not more than prevailing international standards. Weekly working hours should

not on a regular basis be more than 48 hours.

• Workers shall be provided with at least one day off for every 7 day period

• Overtime shall be limited and voluntary. Recommended maximum overtime is 12

hours per week, i.e. that the total working week including overtime shall not exceed

60 hours. Exceptions to this are accepted when regulated by a collective bargaining

agreement.

• Workers shall always receive overtime pay for all hours worked over and above the

normal working hours (see 8.1 above), minimum in accordance with relevant

legislation.


9. Regular Employment (ILO Convention No. 95, 158, 175, 177 and 181)

• Obligations to employees under international conventions, national law and

regulations concerning regular employment shall not be avoided through the use of

short term contracting (such as contract labour, casual labour or day labour),

sub-contractors or other labour relationships.

• All workers are entitled to a contract of employment in a language they understand.

• The duration and content of apprenticeship programmes shall be clearly defined.


10. Marginalized Populations (UN Covenant on Civil and Political Rights, art. 1 and 2)

Production and the use of natural resources shall not contribute to the destruction and/or

degradation of the resources and income base for marginalized populations, such as in

claiming large land areas, use of water or other natural resources on which these populations

are dependent.


11. Environment

• Production of Tharaldsen AS products and sourcing of raw materials must not, in the

shorter or longer term, harm the local or global environment in any way that directly

or indirectly threatens people’s health, environment or safety.

• Measures to minimize adverse impacts on human health and the environment shall

be taken throughout the value chain. This includes minimizing pollution, promoting

an efficient and sustainable use of resources, including energy and water, and

minimizing environmental harmful chemicals, fossil fuel, waste, and other

contributors to environmental damage or greenhouse gas emissions in production

and transport.

• The local environment at the production site shall not be exploited or degraded.

National and international environmental legislation and regulations shall be

respected and relevant discharge permits obtained.

• Tharaldsen AS’s List of Chemicals shall be respected for all Tharaldsen AS products.


12. Corruption

Corruption in any form is not accepted, including bribery, extortion, kickbacks and improper

private or professional benefits to customers, agents, contractors, suppliers or employees of

any such party or government officials.


13. Animal welfare

Tharaldsen AS discountenance and will not allow any kind of animal abuse in the source for raw

materials or in the production of Tharaldsen AS products. Animals shall be treated according to

regulations and humanely, and materials derived from animals shall be a by-product of food

production. Animals shall never be subjected to harsh or cruel treatment. Tharaldsen AS is

against animal testing and encourages all business partners to follow our policy on this

matter.


14. Management systems of suppliers

The management system is key to the implementation of the code of conduct. Tharaldsen AS

emphasises the importance of suppliers having systems that support such implementation.

Tharaldsen AS’s expectations in this regard are summed up in the following measures:

• The supplier should make a centrally placed employee responsible for the

implementation of the code of conduct in the supplier’s business.

• The supplier must make the code of conduct known in all relevant parts of its

organisation.

• The supplier must obtain Tharaldsen AS’s consent prior to outsourcing production or

parts of production to a sub-supplier/contractor, if this has not been agreed in

advance.

• The supplier must be able to give an account of where goods ordered by Tharaldsen AS

are produced.


Implementation

Both in cases where the minimum standards cannot be met immediately, and in cases where

these are already met, the supplier should work to continuously improve production

conditions.

The supplier shall strive to first communicate the primary goals to all subcontractors, then

report on relevant social aspects concerning the subcontractors’ businesses, and demand

that the primary goals are met by subcontractors within a realistic time frame.

Subcontracting of whole or part of the main order to another factory is strictly forbidden

without prior consent from Tharaldsen AS. The Supplier is obliged to inform Tharaldsen AS about

any sub-contractors in due time prior to production start.


Monitoring, reporting and independent verification of social responsibility

Suppliers to Tharaldsen AS must report annually on their progress and discrepancy in the work

to implement the primary goals and improvement of social conditions. Additional

theme-based surveys may also be carried out. Tharaldsen AS will give further guidance

concerning the reports and their format.

Our Suppliers must allow Tharaldsen AS, or those authorized by Tharaldsen AS, unrestricted access to its facilities and to all relevant records at all times, whether or not prior notice is 

provided. The supplier will be obliged to name and provide contact information for any subcontractors that Tharaldsen AS wishes to inspect.


Tharaldsen AS believes in co-operation and in cases of non-compliance with the requirements,

we are willing to work with our suppliers, other clients to the supplier and/or other

competent parties to prepare a plan for reaching the standards of this Code of Conduct.


Notifications and complaint mechanism

Tharaldsen AS wishes to be notified if conditions arise where Tharaldsen AS supply chain are connected with a negative impact on workers' rights or basic human rights.


Notification can be made in writing to the following address:

post@tharaldsen.no


Complaints about the practice of Tharaldsen AS`s Codes of Conduct can be made in writing to the following address:

terje@tharaldsen.no

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