SNOAP  Code of Conduct

At SNOAP, we strive to be a good neighbor by understanding and seeking to effect positive economic, environmental and social impacts of our company operations. We are on a journey toward long-term sustainability, which we hope will sustain us for generations to come.

As part of our on-going sustainability efforts we have developed the SNOAP Code of Conduct to ensure that our ingredients and packaging suppliers’ and co-packers’ operations meet basic expectations of doing business as they relate to legal requirements, ethical practices, human rights and environmental law. These broad standards are primarily based on the Universal Declaration of Human Rights and the International Labor Organization (ILO) conventions. Compliance with the Code of Conduct is expected from suppliers at a minimum level.

Compliance with all the Code of Conduct criteria is an expectation of doing business with SNOAP. Every Vendor that supplies SNOAP must read the Code and sign the Code of Conduct Acknowledgement form. While SNOAP recognizes that global companies operate in a variety of different legal and cultural environments, we expect our Vendors to comply with all the criteria listed in the Code. We hope that suppliers strive to exceed these base standards.

The following eight categories encompass the Code of Conduct:

Vendor Ethical Practices

1. Vendor shall not engage in corrupt or unethical practices, such as paying bribes in exchange for a job or seeking improper advantage to secure delivery of goods or services.
2. Vendor shall not misrepresent relevant information in dealings with customers and competitors in order to gain an unfair competitive advantage.
3. If any legal judgments are levied against Vendor, Vendor observes and complies with them.
4. Vendor recognizes that the provisions herein represent the base standard in terms of legal requirements, ethical practices, human rights, slavery & human trafficking and environmental law and takes appropriate steps to encourage their suppliers are also meeting the spirit of this Code of Conduct.

Child Labor SNOAP does not condone the hiring of child labor under any circumstances. At a minimum, Vendors do not engage in any practice inconsistent with the rights set forth in the Convention on the Rights of the Child, the ILO Minimum Age Convention (C.138-1973) or the Prohibition and Immediate Elimination of the Worst Forms of Child Labor Convention (C.182-1999). The use of child labor, as defined below, by suppliers is strictly prohibited.

1. Vendor observes all applicable laws, codes and regulations of the governing country, states and localities that limit employment of minors, including but not limited to hours of work, wages, education, and working conditions.
2. Where local laws and regulations related to child labor are less stringent than the Code of Conduct, then Vendors are expected to meet the criteria outlined in the Code of Conduct.
3. With regard to age, the Vendor and any sub-contractors only employs young workers that are at or above 15 years old, or the legal minimum age for employment in that country, whichever is greater. For countries that do not specify a minimum age for work, the minimum age of work shall be 15 years Young workers between the ages of 15 and 16 may be permitted to work only during those periods of time when they are not legally required to be attending school.
4. Workers under the age of 18 shall not be exposed to unsafe, unhealthy, or hazardous working conditions under any circumstances.
5. If child labor is found at vendor or sub-contractor, vendor or sub-contractor will offer adequate financial support for the child to attend school.

Freely Chosen Employment

1. Vendor observes all applicable laws, codes and regulations of the governing country, states and localities governing freely chosen employment, including but not limited to the use of slave or bonded labor.
2. Where local laws and regulations are less stringent than the Code of Conduct, then Vendors are expected to meet the criteria outlined in the Code of Conduct.
3. Vendor or sub-contractors do not allow under any circumstances the use of slave labor, bonded labor, indentured labor, human trafficked labor or prison labor.
4. Any restrictions for workers to voluntarily end their employment, such as notice periods in excess of legal requirements, withholding of identity papers or substantial fines for terminating their employment contracts, are prohibited.
5. Employees may freely leave facility premises when shift ends.
6. Vendor shall not require workers to surrender their identity papers or other original personal documents or pay deposits as a condition of employment.
7. If Vendors are using labor brokers in their employee hiring practices, recruitment fees shall not be more than the equivalent of one month’s net wages. If a Vendor has used a labor broker who has overcharged workers, Vendor will ensure that workers have been reimbursed.

Working Hours and Compensation

1. Vendor observes all applicable laws, codes and regulations of the governing country, states and localities governing working hours and compensation, including but not limited to the amount of hours and overtime permissible per week.
2. Where local laws and regulations governing working hours and compensation are less stringent than the Code of Conduct, then Vendors are expected to meet the criteria outlined in the Code of Conduct.
3. Working time shall not, on a regular basis, exceed 48 regular hours and 12 hours overtime per week for hourly workers. When it is necessary to exceed 60 hours per week, suppliers shall provide workers with appropriate compensation and additional days off. In cases where local law has stricter limitations for regular and overtime hours, then those shall be followed.
4. Employees shall be provided with at least one day off following every six consecutive days of working.Vendor recognizes that wages are essential for meeting employees’ basic needs. Vendor pays workers and/or ensures that workers receive an hourly, overtime, and any incentive (or piece rate) wage at a rate that is at least the legal minimum or the prevailing industry wage, whichever is higher. When no minimum wage is stated, provide basic or living needs wage.
5. Vendor provides their workers all legally required benefits without deductions.
6. Vendor must post the legal minimum wage.
7. Vendor provides workers with documentation, in a language understood by all workers, regarding their wages and benefits, including any deductions from wages. Individual documentation must be sufficiently detailed to maximize worker’s understanding. Disciplinary measures do not include monetary fines, including deductions from wages.

Humane Treatment

1. Vendor observes all applicable laws, codes and regulations of the governing country, states and localities governing humane treatment of workers, including but not limited to freedom from harassment or use of physical or verbal abuse.
2. Where local laws and regulations governing working humane treatment of workers are less stringent than the Code of Conduct, then Vendors are expected to meet the criteria outlined in the Code of Conduct.
3. Vendor ensures that facility managers/ supervisors/ foremen/ security personnel do not use or threaten use of corporal punishment, physical or psychological coercion, intimidation or any form of non-physical abuse, including verbal abuse. Threatening, either explicitly or implicitly, to withhold workers’ basic rights, including wages, benefits, access to food, services, etc. can be considered coercive behavior.
4. Vendor prohibits harassment because of race, religion, gender, age, disability, sexual orientation, political opinion, national extraction, or social origin.
5. Vendor prohibits behavior, including gestures, language and physical contact, that is sexually coercive, threatening, abusive or exploitative.
6. Hiring and employment decisions are made solely on the basis of the skill, ability and performance of workers. Discrimination is prohibited on the basis of race, religion, gender, age, disability, sexual orientation, political opinion, national extraction, pregnancy and virginity, or social origin.

Freedom of Association

1. Vendor observes all applicable laws, codes and regulations of the governing country, states and localities governing labor associations or unions.
2. Where local laws and regulations governing freedom of association, labor associations or unions are less stringent than the Code of Conduct, then Vendors are expected to meet the criteria outlined in the Code of Conduct.
3. In the absence of such laws, Vendor agrees not to impair workers ability to form or join labor associations or unions. In situations whereby the legal system or industry practice does not support or severely restricts the right of freedom of association, Vendor will consider facilitating other means to achieve effective representation of workers’ interests.
4. Vendor recognizes and respects workers’ rights to forming and/or joining organizations of their choosing, and recognizes workers’ rights to bargain collectively through those organizations.
5. Vendor shall not impose any punitive actions against workers who form and/or join unions. Punitive actions include threatening, fining, suspending or firing workers exercising those rights.
6. Vendor ensures that representatives of worker organizations (trade unions, etc) are not subject to discrimination, harassment, and/or intimidation and such representatives have access to their members in the workplace.

Safe Working Conditions

1. Vendor complies with all applicable laws, codes and regulations of the governing country, states and localities for safety policies and provides safety training relevant to workers’ jobs and responsibilities to ensure worker protection from workplace hazards.
2. Where local laws and regulations are less stringent than the Code of Conduct, then Vendors are expected to meet the criteria outlined in the Code of Conduct.
3. Vendor acquires, maintains and keeps current all required permits as mandated by applicable law.
4. Vendor monitors use and storage of chemicals potentially dangerous to human health, such as pesticides and fungicides.
5. Vendor takes appropriate steps to identify and prevent workplace hazards and uses its best efforts to correct them. Vendor provides personal protective equipment at employer’s cost and material safety data sheets.
6. Vendor documents all aspects of their training programs (e.g. attendees, issues, etc.) and investigates and maintains records on any incidence that either caused or might have caused a workplace injury.
7. Vendor posts its safety and health standards in a place that is accessible by all employees.
8. Vendor assesses risks to new and expectant mothers and provide for their safety.
9. Where housing is provided to workers, all facilities are in compliance with applicable housing laws and regulations, occupancy requirements, and health and safety laws.

Environmental Practices

1. Vendor complies with all applicable environmental laws, codes and regulations of the governing country, states and localities for environmental practices, such as ensuring all waste materials are disposed in an environmentally responsible manner.
2. Where local laws and regulations are less stringent than the Code of Conduct, then Vendors are expected to meet the criteria outlined in the Code of Conduct.
3. Vendor obtains and keeps current all environmental permits and registrations as required by environmental laws and regulations.
4. Vendor ensures that all waste materials resulting from a by-product of production (e.g. hazardous substances, wastewater and solid waste, air emissions) are disposed of properly and in an environmentally responsible manner according to local laws and regulations.