Keeler Hardware Supplier Code of Conduct
Version 20100321A

Keeler Hardware is committed to ensuring that working conditions in Keeler Hardware’s supply chain are safe, that workers are treated with respect and dignity, and that manufacturing processes are environmentally responsible. Keeler Hardware’s suppliers (“Suppliers”) commit, in all of their activities, to operate in full compliance with the laws, rules, and regulations of the countries in which they operate.

Keeler Hardware recognizes the nature of current manufacturing practices where our Suppliers regularly use sub-suppliers and sub-contractors. Keeler Hardware’s Suppliers commit to ensuring the principles and practices outlined here are reflected in their dealings with their sub-suppliers and sub-contractors.

Keeler Hardware’s Supplier Code of Conduct (“Code”) draws upon internationally recognized standards, in order to advance social and environmental responsibility. Keeler Hardware requires that Suppliers implement this Code.

Keeler Hardware requires all Suppliers to confirm their commitment to this Code on an annual basis. Keeler Hardware requires all Suppliers to report any material breaches of the Code to Keeler Hardware. Keeler Hardware will maintain a register of current compliant Suppliers and publish that information on our website www.keelerhardware.com.au

Keeler Hardware reserves the right to amend or update the Code as and when required. In that instance, Keeler Hardware will issue previously compliant Suppliers with a copy of the revised Code and seek their commitment within 90 days

Keeler Hardware recognize that our customers will sometimes specify the supply of product from manufacturers that have not agreed to comply with this Code. In those circumstances, Keeler Hardware will attempt to bring this matter to the attention of our customer and seek their instruction.

Where Keeler Hardware become aware of circumstances or events that indicate a Supplier may have breached the Code we will bring this matter to the attention of the Supplier and seek their immediate response, in the case that there is reasonable evidence to conclude that a Supplier has breached the Code then that Supplier will be immediately remove the registration of that Supplier. Keeler Hardware reserves the right to seek third party advice or counsel in assessing the compliance of a Supplier.

Keeler Hardware may visit (and/or have external monitors visit) Supplier facilities, with or without notice, to assess compliance with this Code and if necessary to audit Supplier’s practices.

Violations of this Code may result in immediate termination as an Keeler Hardware Supplier and in legal action.



Labor and Human Rights
Suppliers must uphold the human rights of workers, and treat them with dignity and respect as understood by the international community.


Human Trafficking and Slavery
Suppliers shall commit to not participate in human trafficking or slavery.


Antidiscrimination
Suppliers shall not discriminate against any worker based on race, colour, age, gender, sexual orientation, ethnicity, disability, religion, political affiliation, union membership, national origin, or marital status in hiring and employment practices such as applications for employment, promotions, rewards, access to training, job assignments, wages, benefits, discipline, and termination. Suppliers shall not require a pregnancy test or discriminate against pregnant workers except where required by applicable laws or regulations or prudent for workplace safety. In addition, Suppliers shall not require workers or potential workers to undergo medical tests that could be used in a discriminatory way except where required by applicable law or regulation or prudent for workplace safety.


Fair Treatment
Suppliers shall commit to a workplace free of harassment. Suppliers shall not threaten workers with or subject them to harsh or inhumane treatment, including sexual harassment, sexual abuse, corporal punishment, mental coercion, physical coercion, verbal abuse or unreasonable restrictions on entering or exiting company provided facilities. Suppliers shall prohibit harassment and unlawful discrimination in the workplace.


Prevention of Involuntary Labor
Suppliers shall not use any form of forced, bonded, indentured, or prison labor. All work must be voluntary and workers shall be free to leave work or terminate their employment with reasonable notice. Workers must not be required to surrender any government-issued identification, passports, or work permits as a condition of employment. Suppliers shall ensure that third party agencies providing workers to Supplier are compliant with the provisions of the Code and the laws of the sending and receiving countries, whichever is more stringent in its protection of workers. Suppliers shall ensure that contracts for both direct and contract workers clearly convey the conditions of employment in a language understood by the worker. Where workers are required to pay a fee in connection with obtaining employment, Suppliers shall be responsible for payment of all fees and expenses in excess of the amount of one month of the worker’s anticipated net wages. Such fees and expenses include, but are not limited to expenses associated with recruitment, processing or placement of both direct and contract Workers.


Prevention of Under Age Labor
Child labor is strictly prohibited. Suppliers shall not employ children. The minimum age for employment or work shall be 15 years of age, the minimum age for employment in that country, or the age for completing compulsory education in that country, whichever is higher. This Code does not prohibit participation in legitimate workplace apprenticeship programs that are consistent with International Labour Organization and United Nations protocols.


Juvenile Worker Protections
Suppliers may employ juveniles who are older than the applicable legal minimum age for employment but are younger than 18 years of age, provided they do not perform work likely to jeopardize their heath, safety, or morals, consistent with International Labour Organization and United Nations protocols.


Working Hours
Working hours shall be fair and reasonable, and workers shall take at least one day off every seven-days. All overtime shall be voluntary. Under no circumstances shall workweeks exceed the maximum permitted under applicable laws and regulations.


Wages and Benefits
Suppliers shall pay all workers at least the minimum wage required by applicable laws and regulations and provide all legally mandated benefits. In addition to their compensation for regular hours of work, workers shall be compensated for overtime hours at the premium rate required by applicable laws and regulations. Suppliers shall not use deductions from wages as a disciplinary measure. Suppliers shall offer vacation time, leave periods, and holidays consistent with applicable laws and regulations. Suppliers shall pay workers in a timely manner and clearly convey the basis on which workers are being paid.


Freedom of Association
Suppliers must respect the right of workers to associate freely, form and join workers organizations of their own choosing, seek representation, and bargain collectively, as permitted by and in accordance with applicable laws and regulations. Suppliers shall not discriminate with respect to employment based on union membership and, in particular, shall not make employment subject to the condition that the worker relinquish union membership or agree not to join a union or cause the dismissal of or otherwise prejudice a worker by reason of union membership or participation in union activities outside working hours (or within working hours if the Supplier has consented to such activities or if required by applicable law or regulation). Suppliers shall protect against acts of interference with the establishment, functioning, or administration of workers’ organizations in accordance with applicable laws and regulations.


Health and Safety
Keeler Hardware recognizes that integrating sound health and safety management practices into all aspects of business is essential to maintain high morale and produce innovative products. Suppliers shall commit to creating safe working conditions and a healthy work environment for all of their workers.


Occupational Injury Prevention
Suppliers shall eliminate physical hazards where possible. Where physical hazards cannot be eliminated, Suppliers shall provide appropriate engineering controls such as physical guards, interlocks, and barriers. Where appropriate engineering controls are not possible, Suppliers shall establish appropriate administrative controls such as safe work procedures. In all cases, Suppliers shall provide workers with appropriate personal protective equipment. Workers shall not be disciplined for raising safety concerns and shall have the right to refuse unsafe working conditions without fear of reprisal until management adequately addresses their concerns.


Prevention of Chemical Exposure
Suppliers shall identify, evaluate, and control worker exposure to hazardous chemical, biological, and physical agents. Suppliers must eliminate chemical hazards where possible. Where chemical hazards cannot be eliminated, Suppliers shall provide appropriate engineering controls such as closed systems and ventilation. Where appropriate engineering controls are not possible, Suppliers shall establish appropriate administrative controls such as safe work procedures. In all cases, Suppliers shall provide workers with appropriate personal protective equipment.


Occupational Safety Procedures and Systems
Suppliers shall establish procedures and systems to manage, track, and report occupational injury and illness. Such procedures and systems shall encourage worker reporting, classify and record injury and illness cases, investigate cases and implement corrective actions to eliminate their causes, provide necessary medical treatment, and facilitate the workers’ return to work.


Ergonomics
Suppliers shall identify, evaluate, and control worker exposure to physically demanding tasks, including manual material handling, heavy lifting, prolonged standing, and highly repetitive or forceful assembly tasks.


Dormitory and Dining
Suppliers shall provide workers with clean toilet facilities, access to potable water, and sanitary food preparation and storage facilities. Worker dormitories provided by the Supplier or a third party agency shall be clean and safe and provide adequate emergency egress, adequate heat and ventilation, reasonable personal space, and reasonable entry and exit privileges.


Health and Safety Communication
In order to foster a safe work environment, Suppliers shall provide workers with appropriate workplace health and safety information and training, including written health and safety information and warnings, in the primary language of the workers. Suppliers shall post, in the primary language of its workers, Material Safety Data Sheets for any hazardous or toxic substances used in the workplace and properly train workers who will come into contact with such substances in the workplace.


Worker Health and Safety Committees
Suppliers are encouraged to initiate and support worker health and safety committees to enhance ongoing health and safety education and to encourage worker input regarding health and safety issues in the workplace.


Environmental Impact
At Keeler Hardware, environmental considerations are an integral part of our business practices. Suppliers shall commit to reducing the environmental impact of their designs, manufacturing processes, and waste emissions.


Hazardous Substance Management and Restrictions
Suppliers shall comply with any applicable laws and regulations prohibiting or restricting the use or handling of specific substances. To ensure safe handling, movement, storage, recycling, reuse, and disposal, Suppliers shall identify and manage substances that pose a hazard if released to the environment and comply with applicable labelling laws and regulations for recycling and disposal.


Solid Waste Management
Suppliers shall manage and dispose of non-hazardous solid waste generated from operations as required by applicable laws and regulations.


Wastewater and Stormwater Management
Suppliers shall monitor, control, and treat wastewater generated from operations before discharge as required by applicable laws and regulations. Supplier shall take appropriate precautions to prevent contamination of stormwater runoff from its facilities.


Air Emissions Management
Supplier shall characterise, monitor, control and treat air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting chemicals, and combustion byproducts generated from operations, as required by applicable laws and regulations, before discharge.


Environmental Permits and Reporting
Suppliers must obtain, maintain, and keep current all required environmental permits (e.g. discharge monitoring) and registrations and follow the operational and reporting requirements of such permits.


Pollution Prevention and Resource Reduction
Suppliers must endeavour to reduce or eliminate solid waste, wastewater and air emissions, including energy-related indirect air emissions, by implementing appropriate conservation measures in their production, maintenance and facilities processes, and by recycling, re-using, or substituting materials.


Ethics
Suppliers must be committed to the highest standards of ethical conduct when dealing with workers, suppliers, and customers.


Business Integrity
Corruption, extortion, and embezzlement, in any form, are strictly prohibited. Suppliers shall not violate any international anti-corruption conventions, and applicable anti-corruption laws and regulations of the countries in which they operate, and shall not engage in corruption, extortion or embezzlement in any form. Suppliers shall not offer or accept bribes or other means to obtain an undue or improper advantage. Suppliers must uphold fair business standards in advertising, sales, and competition.


Disclosure of Information
Suppliers must accurately record and disclose information regarding their business activities, structure, financial situation, and performance in accordance with applicable laws and regulations and prevailing industry practices.


Whistleblower Protection and Anonymous Complaints
Suppliers shall create programs to ensure the protection of Supplier and worker whistleblower confidentiality and prohibit retaliation against workers who participate in such programs in good faith or refuse an order that is in violation of the Keeler Hardware Supplier Code of Conduct. Suppliers shall provide an anonymous complaint mechanism for workers to report workplace grievances in accordance with local laws and regulations.


Community Engagement
Suppliers are encouraged to engage the community to help foster social and economic development and to contribute to the sustainability of the communities in which they operate.


Protection of Intellectual Property
Suppliers must respect intellectual property rights; safeguard customer information; and transfer of technology and know-how must be done in a manner that protects intellectual property rights.


Management Commitment
Suppliers must adopt or establish a management system designed to ensure compliance with this Code and applicable laws and regulations, identify and mitigate related operational risks, and facilitate continuous improvement.