Working in partnership with our suppliers

Introduction

With respect for universal human rights of individuals, Chicken of the Sea strives to provide safe and fair treatment to all employees/workers.

To achieve this, our suppliers play a critical role in helping us to source responsibly. We apply the same principles and benchmarks to our suppliers as to our own company. This Code of Conduct is our way of informing our suppliers of what we expect today and in the future.

Chicken of the Sea’s Code of Conduct embodies our commitment to conduct business with integrity, openness, and respect for universal human rights and core labor principles throughout our operations. This Code of Conduct provides the framework through which we set out our responsible sourcing ambitions and approach. We will only work with suppliers who share our values and work to comply with our Code of Conduct. They must also agree to ensure transparency, to remedy any shortcomings, and to drive continuous improvement under the Fundamental Principles that create the foundations to this Policy.

Our Code of Conduct specifies requirements and provides benchmarks for each component of the Fundamental Principles.

The Fundamental Principles

Across Chicken of the Sea we’ve set industry leading benchmarks for responsible sourcing to deliver on our commitment to sustainable growth. We have embedded these standards into every element of our business, and we want to invite our suppliers to partner with us in achieving equally robust sustainability principles. Through our parent company, Thai Union, we are members of the UN Global Compact, and are committed to the implementation, disclosure, and promotion of its ten universal principles.

The Fundamental Principles that create the foundation of our Code of Conduct are grounded in internationally recognized standards and are embedded throughout our operations.

  1. Business is conducted lawfully and with integrity.
  2. Work is conducted on the basis of freely agreed and documented terms of employment with legal compliance.
  3. All workers are treated equally and with respect and dignity.
  4. Work is conducted on a voluntary basis with no forced and compulsory labor.
  5. All workers are of an appropriate age.
  6. All workers are paid fair wages.
  7. Working hours for all workers are reasonable.
  8. All workers are free to exercise their right to form and/or join trade unions and to bargain collectively where permitted by law.
  9. Workers’ health and safety are protected at work.
  10. Workers have access to fair procedures.
  11. Business is conducted in a manner which embraces sustainability and reduces environmental impact.
  12. Monitoring of progress and compliance.

Implementation Guidelines

Chicken of the Sea strives to conduct its business with integrity and respect for others. Our reputation is an asset, as valuable as our people and our brands. We expect the highest standards of behavior from all our workers and those with whom we do business. By becoming a supplier, you are stating that you share our Fundamental Principles.

While we expect that all Chicken of the Sea suppliers will uphold the expectations outlined in this document, significant suppliers—those that are directly involved in the procurement, processing, and packaging of our products—will face higher scrutiny. This scrutiny includes formal, written acknowledgment of the Code of Conduct, disclosure of any violations or non-compliance with the Code, cooperation with inquiries for more information, and willingness to be audited against this Code.

A. Mandatory requirements for doing business with Chicken of the Sea

In this section, we describe the Mandatory Requirements for our suppliers to establish and maintain a business relationship with Chicken of the Sea.

We require all suppliers who work with or for Chicken of the Sea to respect and confirm that all their activities comply with these Mandatory Requirements.

1. Business is conducted lawfully and with integrity.

Bribery

There is a prohibition of any and all forms of bribery, corruption, extortion or embezzlement and there are adequate procedures in place to prevent bribery in all commercial dealings undertaken by the supplier.

Conflicts of Interest

All conflicts of interest in any business dealings with Chicken of the Sea, of which the supplier is aware, will be declared to Chicken of the Sea to allow us the opportunity to take appropriate action. Any ownership or beneficial interest in a supplier’s business by a government official, representative of a political party or a Chicken of the Sea employee is declared to Chicken of the Sea prior to any business relationship with Chicken of the Sea being entered into.

Gifts, Hospitality and Entertainment

Any business entertaining or hospitality with Chicken of the Sea is kept reasonable in nature, entirely for the purpose of maintaining good business relations and not intended to influence in any way Chicken of the Sea’s decisions about how it awards future business. Gift giving between supplier’s employees and Chicken of the Sea’s employees is avoided. Official company to company gift exchanges are acceptable but must be transparent and properly recorded.

Competition and Competitor Information

All information about Chicken of the Sea’s competitors is obtained legitimately and will only be used for legitimate purposes in compliance with all relevant anti-trust and other laws and regulations. No attempt is made at any time to divulge to Chicken of the Sea any information about its competitors that is confidential to them and not in the public domain.

Financial Records, Money Laundering and Insider Trading

All business and commercial dealings are transparently performed and accurately recorded in the supplier’s books and records. There is no actual or attempted participation in money laundering. No confidential information in the supplier’s possession regarding Chicken of the Sea is used to either engage in or support insider trading.

Safeguarding Information and Property

Chicken of the Sea’s confidential information, know-how and intellectual property is respected and safeguarded. All information provided by Chicken of the Sea is only used for its intended and designated purpose. All and any personal information about individuals, such as Chicken of the Sea’s consumers or employees are handled with full respect for the protection of their privacy and for all relevant privacy laws and regulations.

Product Quality and Responsible Innovation

Products and services are delivered to meet the specifications and quality and safety criteria specified in the relevant contract documents and are safe for their intended use. Research and development are conducted responsibly and based on good clinical practice, and generally accepted scientific, technological and ethical principles.

Compliance with Laws

All laws and regulations are complied with in the countries in which the supplier operates. All other applicable international laws and regulations are complied with including those relating to international trade (such as those relating to sanctions, export controls and reporting obligations), data protection and anti-trust/competition laws.

Reporting Concerns and Non-retaliation

Employees are provided with means by which to raise their concerns about any of these requirements and all employees who speak out about an issue are protected from retaliation.

1.1 Clear and effective guidelines and policies are in place describing business integrity expectations relating to anti-bribery, gifts and hospitality. They comply with competition laws and conflicts of interest.

1.2 Training and risk assessment mechanisms for compliance issues are in place. Non-compliance is subject to sanctioning and remedial procedures.

1.3 Adequate financial transaction policies and procedures are maintained to ensure proper recording of all financial transactions, as well as to identify possible money laundering. No undisclosed or unrecorded account, fund or asset will be established or maintained.

1.4 Adequate procedures and mechanisms are in place to ensure that all confidential information, whether business or product related, is safely stored with limited access rights on a need-to-know basis only.

1.5 Adequate procedures are in place to ensure that any product quality or safety concerns originating from the supplier or its supply chain are immediately notified to Chicken of the Sea.

1.6 Adequate procedures are in place to ensure that all applicable laws and regulations are complied with by the supplier and its employees.

1.7 Employees have a channel through which they can raise concerns without fear of retaliation.


2. Work is conducted on the basis of freely agreed and documented terms of employment with legal compliance.

Policies are adopted and adhered to that respect workers, permanent and temporary and outsourced workers and, at a minimum, safeguard their rights under their employment contract, local, national labor and social security laws and regulations, and applicable collective agreements.

2.1 The key components of the employer/ worker relationship such as hours, overtime, pay, benefits, leave, disciplinary and grievance systems are (i) freely agreed by both parties (ii) documented in writing and (iii) signed by the employer and worker.

2.2 The terms and conditions are clearly understood by the worker and are explained verbally if required in a language she or he can understand.

2.3 Changes are agreed in writing by both employer and worker.


3. All workers are treated equally and with respect and dignity

All workers are treated with respect and dignity. No worker is subject to any physical, sexual, psychological, verbal harassment, abuse or other form of intimidation. There is no discrimination in employment, including hiring, compensation, advancement, discipline, termination or retirement. Discrimination based on caste, national origin, ethnicity, religion, age, disability, gender, marital status, sexual orientation, union membership, political affiliation, health, disability or pregnancy is prevented. In particular, attention is paid to the rights of workers most vulnerable to discrimination.

3.1 Policies that prohibit discrimination of any form on the basis of caste, national origin, ethnicity, religion, age, disability, gender, marital status, sexual orientation, union membership, political affiliation, health, disability or pregnancy are in place, and procedures for informing employees of their rights.

3.2 Pregnancy testing or other forms of health screening that might result in discrimination are not tolerated.


4. Work is conducted on a voluntary basis with no forced and compulsory labor

Forced labor, whether in the form of indentured labor, bonded labor or other forms, is not acceptable. Mental and physical coercion, slavery and human trafficking are prohibited.

4.1 There are hiring policies, procedures and trained staff to ensure that workers are entering into employment freely and equally and that they are never prevented from leaving if they so wish.

4.2 Workers have freedom of movement and are not confined to the supplier’s premises.

4.3 Workers are not required to surrender their identification papers. Where the retention of identification papers is legally required, arrangements are made to ensure that workers can access their identification papers, are not prevented from leaving the workplace and that their papers are returned immediately upon cessation of employment.

4.4 Suppliers shall ensure that contracts are in a language understood by the worker.


5. All workers are of an appropriate age

No child labor as specified by labor law in that country is or shall be engaged or employed in any of the activities under direct supervision of a supplier. Suppliers shall ensure that employees with the age younger than 18 years old shall not work in dangerous work areas, and working time shall not be over than 8 hours a day and shall not work at night shift (10.00 pm -6.00 am).

5.1 An employment policy is in place specifying the minimum age for employment, together with effective procedures and means of age verification (such as an identity card or a government-issued passport) to implement this policy.

5.2 In all circumstances the health and safety of young workers is considered and protected. This protection should preclude them from certain types of work such as hazardous or night work and requires extra care and commitment.


6. All workers are paid fair wages

Workers are provided with a total compensation package that includes wages, overtime pay, benefits and paid leave which meets or exceed the country legal minimum standards and compensation terms established by legally binding collective bargaining agreements are implemented and adhered to.

6.1 Workers receive a pay slip for each pay period clearly indicating the components of the compensation, including exact amounts for wages, benefits, incentives/bonuses and any deductions. The pay slip shall be made in the language(s) understood by every worker.

6.2 Wages are paid on time and in full.

6.3 All work is compensated according to at least the legal minimum standards or the appropriate prevailing industry standards.

6.4 The compensation terms established by legally binding collective bargaining agreements are implemented and adhered to.

6.5 All legally mandated deductions’ such as taxes or social insurance, are deposited each pay period to the legally stipulated accounts or agencies and as required by law.

6.6 Other than legally mandated deductions, all other deductions from wages are made only with the express and written consent of the workers.


7. Working hours for all workers are reasonable

Workers are not required to work more than the regular and overtime hours allowed by the labor law of the country where the workers are employed. All overtime work by workers is on a voluntary basis.

7.1 Clear policies are implemented regarding regular and overtime hours of work, with defined procedures for deciding on overtime and securing worker consent.

7.2 Workers are entitled to at least 24 consecutive hours of rest in every seven-day period. If workers are required to work on a rest day due to a genuine need for continuity of production or service, workers must receive an equivalent period of compensatory rest immediately following.

7.3 If the employment contract allows for contractual overtime, workers expressly agree to it. All overtime work by workers is on a voluntary basis.

7.4 All overtime work is paid at least to the rate defined by law.


8. All workers are free to exercise their right to form and/or join trade and to bargain collectively where permitted by law.

The rights of workers to freedom of association and collective bargaining are recognized and respected. Workers are not intimidated or harassed in the exercise of their right to join any organization.

8.1 Managers, supervisors and guards are trained to respect each workers’ right to associate freely.

8.2 Workers know and understand their rights, feel confident to exercise them and that no other worker or manager will impede them in the enjoyment of that right.


9. Workers’ health and safety are protected at work

A healthy and safe workplace is provided to prevent accidents and injury arising out of, linked with, or occurring in the course of work or as a result of the employer’s operations.

Suppliers shall ensure that pregnant employees who have notified the company of their pregnancy shall not work in dangerous work areas. Pregnant employees shall not work more than 8 hours/day and shall not work in a night shift (10.00 pm - 06.00 am). Suppliers shall not lay-off, demote or reduce benefits as a result of pregnancy.

9.1 Suppliers shall progressively identify and eliminate or control hazards that present a risk to employees and other persons present on its sites and to the environment.

9.2 Clear and effective policies and procedures are in place for occupational health and safety and are updated periodically.

9.3 Occupational health and safety policies and procedures are widely communicated.

9.4 All workers and other people who enter business premises are properly informed about the inherent dangers of the workplace and are provided with adequate knowledge and personal protective equipment to avoid such dangers.

9.5 All personnel who enter the premises or deal with products are properly informed about the appropriate actions to take should a health and safety incident occur.

9.6 Appropriate personal protective equipment is supplied to all personnel at the employer’s expense.

9.7 Employees receive the training necessary to perform their tasks safely.

9.8 Safe and healthy working and, where provided, living conditions are provided. At a minimum, potable drinking water, adequate, clean restrooms, adequate ventilation, fire exits and essential safety equipment, an emergency aid kit, access to emergency medical care, hygienic dining area and appropriately-lit work stations must be provided.


10. Workers have access to fair procedures

Workers are provided with transparent, fair and confidential procedures that result in swift, unbiased and fair resolution of difficulties which may arise as part of their working relationship.

10.1 Procedures (i) provide effective, accessible channels for workers to complain, make suggestions and lodge grievances and (ii) require the matter to be fully investigated, and result in swift, unbiased and fair resolution.

10.2 Grievance mechanism channels are widely communicated and guarantee the confidentiality of any complainant (if so desired) and prohibit retaliation.


11. Business is conducted in a manner which embraces sustainability and reduces environmental impact

Operations, sourcing, manufacture, distribution of products and the supply of services are conducted with the aim to protect and preserve the environment and comply with environmental legislation and regulations.

11.1 All necessary legal permits are held for its operations.

11.2 Training is provided to all personnel to ensure knowledge of and compliance with all necessary legal permits.

11.3 An effective environmental management plan should be in place to manage legal compliance as well as, but not limited to, the use of hazardous chemicals; waste, wastewater and air pollution generation; water and energy consumption.


12. Monitoring of progress and compliance

The supplier will authorize Chicken of the Sea and its designated agents to engage in monitoring activities to confirm compliance with this Code of Conduct including unannounced on-site inspections of manufacturing facilities and employer-provided housing; reviews of books and records relating to employment matters; and private interviews with employees. Manufacturers will maintain on site all documentation that may be needed to demonstrate compliance with the Code of Conduct.


B Reporting on breaches

These provisions apply to all suppliers contracted by Chicken of the Sea. Suppliers shall ensure that these provisions are also applied to/by sub-suppliers or outsourcing companies if the product(s) sold/services provided to Chicken of the Sea require(s) services outsourced or carried-out by suppliers of the Supplier.

1. Any failure to comply with this Policy (including any failure by an employee of Chicken of the Sea or anyone acting on behalf of Chicken of the Sea to so comply), of which the supplier is aware, should be immediately reported to Chicken of the Sea. The failure to do so will be a breach of this Code of Conduct.

2. We strongly support a culture of speaking up for both suppliers and their workers without any fear of retaliation against those who report actual or suspected breaches.

3. Chicken of the Sea will investigate any reported non-conformity made in good faith and discuss findings with the supplier. The supplier shall assist with any such investigation and provide access to any information reasonably requested.

4. If remediation is required, the supplier will be expected to inform Chicken of the Sea and implement a corrective action plan and timeline to effectively and promptly resolve the failure.

5. Suppliers, their employees or contractors may report actual or suspected breaches of this Code of Conduct to Chicken of the Sea by phone or online. Reports can be submitted confidentially and anonymously (where permitted by law).


The channels for reporting on breaches are as follows:

CONTACT

Chicken of the Sea

9330 Scranton Road, Suite 500 San Diego, CA 92121

(858) 558-9662

Project ISSARA

Information for migrant workers on labor rights, government registration, processes, or to report a case or request assistance to the 24 hour nation-wide worker hotline in Thailand:

Myanmar language: +66-80-456-5560

Lao and Thai language: +66-86-967-2891

Khmer language: +66-86-968-6085

Web: www.projectissara.org

6. Failure to comply with this Code of Conduct or recommended remedial action will result in supplier contract termination and legal actions, without recourse.


Acknowledgment and Acceptance

This is to certify that I have fully read and understood the Chicken of the Sea Business Ethics and Labor Code of Conduct. As an authorized representative of my company, I hereby commit myself and my company to serve this Code of Conduct and to progress towards full compliance with all of its principles.

Supplier: _______________________

Address: _______________________

Representative: _______________________

Signature: _______________________

Date: _______________________