We strive to conduct business according to the highest ethical standards and expect our suppliers to share our values. JM’s Supplier Code of Conduct (“Code”) is our framework to ensure that our suppliers, sub-contractors and business partners throughout our supply chain act lawfully, respectfully and responsibly towards employees, suppliers and business partners.
Basis for the code
This Code is based on the ten principles of the UN Global Compact1 and its underlying conventions and declarations. The supplier shall always follow national legislation and, when applicable, follow international legislation with a wide territorial scope such as:
- The UK Bribery Act
- The UK Modern Slavery Act
- The Foreign Corrupt Practices
- The Dodd Frank Act
- The EU Conflict Minerals Regulation
This Code sets out minimum requirements to which the supplier must adhere. If national regulations set out a more stringent position than this Code, such regulations shall prevail.
Covered areas
Human Rights
Human rights
Internationally recognized human rights shall be protected and respected. Suppliers shall ensure that they do not directly or indirectly violate human rights.
Privacy rights
The supplier shall protect personal information of employees and suppliers when personal information is collected, stored, processed, transmitted, or shared.
Freedom of association
All employees shall be free to form, join or not to join a trade union or employee organisation of their choice. Employees shall also have the right to bargain collectively without fear of reprisals.
Child labour
No person below the legal age of employment shall be used as labour. It is forbidden for suppliers to employ children or minors below 15 years of age. Employees under the age of 18 shall not carry out hazardous work, heavy work or work night shifts.
Forced labour
All work shall be voluntary and any form of forced or involuntary labour is strictly prohibited. No one shall be subject to working under the threat of penalty and no one shall be required to deposit identity papers with their employer or recruitment agents at the start of or during their employment.
Discrimination
Equality and diversity shall be promoted in remuneration plans, recruitment processes, promotions, trainings and parental leave. All forms of discrimination is prohibited, on grounds such as ethnicity, gender, sexual orientation, marital, social or parental status, religion, political grounds, nationality, disability, age or union affiliation.
Harassment and abuse
All employees shall be treated with dignity and respect. Nobody shall be subject to corporal punishment, unlawful detentions, physical, sexual, psychological or verbal harassment or abuse. Using deductions from wages as a disciplinary measure is not permitted.
Conflict minerals
Suppliers delivering products to JM containing tin, tungsten, tantalum and/or gold shall have a clear policy on conflict minerals and conduct due diligence to reasonably assure that the above mentioned minerals sourced do not directly or indirectly finance or benefit armed groups in the Democratic Republic of the Congo or an adjoining country.
Labour Rights
Working contracts
Contracts shall, at a minimum state working hours, salary, overtime compensation, frequency of payment and notice period. These obligations shall not be avoided through the use of home workers or apprenticeships.
Working hours
A normal workweek shall not exceed 48 hours. Overtime shall be voluntary and shall not exceed 12 hours per week, unless regulated otherwise by a collective bargaining agreement. All employees are entitled to at least one full day off in every seven days. Employees shall be entitled to paid sick leave and at least three weeks of paid annual leave. Paid maternity leave shall be a minimum of 14 weeks.
Wages
Employees have the right to equal pay for equal work. Suppliers shall ensure that all employees are given a fair wage, i.e. a living wage. The wage shall be enough to cover basic needs for the employee and its family and provide some discretionary income. Overtime compensation shall be paid at a premium rate. The employer shall provide all employees with adequate insurance, benefits and a written pay slip monthly stating the salary, hours worked, as well as legal deductions and overtime compensation, if any.
Working environment
Suppliers shall ensure that the work premises are clean and safe, that employees have ready access to safe drinking water, lockable and gender separated toilets and a sanitary place for food storage. The premises shall be well lit, ventilated and kept at acceptable temperatures and noise levels. If accommodation is provided, the supplier shall offer each employee a clean and healthy bed with gender-separated sleeping areas with toilets and showers and meet the health and safety standards specified in this Code.
Health and safety
The supplier shall have a well-developed risk assessment in place where occupational hazards have been listed and preventative measures have been taken. Adequate personal protective equipment shall be identified and provided to employees free of charge.
The supplier shall ensure that the fire safety in its operations and ensure that there are adequate number of fire extinguishers, clear evacuation routes, emergency preparedness plans and first aid kits at the workplace. Safety instructions, evacuation drills, fire safety, first aid training and work specific training shall be documented and provided regularly in a language understandable to the employees. Injuries and accidents occurring at work shall be logged, investigated and preventative measures shall be introduced.
Environment
Precautionary approach
Suppliers shall apply a precautionary approach towards environmental and climate challenges. Suppliers shall promote the development and use of environmentally friendly technologies and conduct business with as little impact on the environment and public health as possible. Biodiversity should not be decreased due to the company’s operations.
Reduction targets
The supplier shall have an environmental policy and program in place with measureable targets and objectives, including a risk assessment to prevent, mitigate and control the impacts of their operations.
Energy and water
Suppliers shall use energy and water responsibly and strive towards reducing their consumption by setting reduction targets and monitoring energy and water use regularly. Renewable energy sources shall be prioritized and water shall be treated and reused when possible.
Emissions and waste
Suppliers shall strive to minimize greenhouse gas emissions by identifying, managing, monitoring, and controlling air emissions from their operations. This also includes choosing means of transportation with the least negative environmental impact. Supplier shall monitor, control, and treat wastewater and solid waste generated from operations, industrial processes, and sanitation facilities before discharge or disposal.
Chemicals and hazardous substances
Chemicals and hazardous substances shall be eliminated when possible or kept to an absolute minimum. When chemical or hazardous substances are used, suppliers shall ensure safe handling, storage and disposal of the substances. All substances shall be marked with Material Safety Data Sheets (MSDS) to ensure the protection of employees and the environment. Substances regulated under the European Union directives REACH and RoHS are to be respected.
Anti-corruption
Business Integrity
Suppliers shall uphold the highest ethical standards when doing business. Corruption in all its forms including but not limited to bribery, facilitation payments and nepotism is strictly prohibited. Suppliers shall be committed to preventing, detecting and remedying financial crime, including but not limited to extortion, money laundering and fraud.
Bribery and gifts
It is never allowed for suppliers directly or indirectly to demand, offer, ask for, give or accept a gift or undue advantage in exchange of a personal advantage from any party.
Conflict of Interests
Business decisions shall not be motivated or influenced by personal relationships or interests. The supplier shall not enter into a financial or any other relationship with a party that creates or gives the appearance of a conflict of interest. Such situations must be disclosed and approved by JM.
Fair competition
Suppliers shall comply with all competition and anti-trust laws. This includes agreeing to not enter into discussions or agreements with competitors regarding price fixing, market sharing, bid rigging or other similar activities.
Scope
This Code applies to all of JM’s suppliers, sub-contractors and business partners, hereinafter referred to as “the supplier/suppliers”, providing products and/or services to JM. The Code also applies to the suppliers’ employees, whether directly or indirectly contracted, permanently or temporarily employed, subcontracted or supervised. The suppliers’ employees are hereinafter referred to as “employees”.
Compliance
As a part of JM’s supply chain process the supplier shall, upon request, participate in a self-assessment process, during which the supplier shall cooperate. JM also reserves the right to conduct audits and site visits to observe the suppliers’ and sub-suppliers operations and sustainability performance. The audits, whether performed by JM or a third party, will be treated with confidentiality and not be revealed to any other external party. In cases where deviations towards the Code are found, the supplier will be asked to provide a corrective action plan for JM to approve. The supplier is responsible for ensuring that suppliers in their supply chain adhere to the principles set out in this Code. Such parties may also be asked to participate in self-assessments and audits arranged by JM.
Breaches
Any breach or suspected breach towards the principles in this Code shall be informed to JM without any delay. The Supplier shall maintain procedures to ensure the protection of whistle-blowers, in accordance with local laws and regulations, and to prohibit retaliation against workers who file reports in good faith. Any material breach towards the Code gives JM the right to immediately terminate the contract with the supplier. Suppliers and employees can report breaches anonymously directly to JM. Reports are made to Seccredo, an independent security company via: web-based notification system, or by phone +46 703 00 36 63.