The following set of standards describes Crossroads Enterprise, Inc. expectations
for its suppliers in the area of environmental, health and safety (EHS), transportation,
and labor/human resources (labor).These standards apply to the selection and retention
of all suppliers that provide goods or services to Crossroads Enterprise, Inc. worldwide,
including raw material suppliers, semi-finished or finished goods suppliers, contractors,
contract manufacturers and service providers. While Crossroads Enterprise, Inc.
recognizes that there are different legal and cultural environments in which suppliers
operate throughout the world, these standards establish a framework that Crossroads
Enterprise, Inc. considers important to the management of manufacturing and distribution
operations to minimize the adverse impact to the environment, to a healthy and safe
workplace and to the maintenance of fair and reasonable labor practices.
Crossroads Enterprise, Inc. may in its sole discretion assess and monitor ongoing
performance and compliance with these standards, including but not limited to a
review of appropriate supplier documents, an on-site visit to determine whether
these EHS, transportation and labor standards are in place, review of past practices
of the supplier, and/or consideration of the local environment in which the supplier
will perform services. The following set of standards is not intended to limit Crossroads
Enterprise, Inc. discretion on information that might be requested from a supplier
in connection with any EHS, transportation or labor review conducted by Crossroads
Enterprise, Inc. On a periodic basis, suppliers may also be requested to certify
conformance to these standards. Crossroads Enterprise, Inc. reserves the right to
terminate any operation where conformance with these standards is not achieved and
maintained.
These standards are dynamic and evolving to address ongoing protection of employees
and to manage impacts to the environment and the community.
Compliance:
Crossroads Enterprise, Inc. suppliers must comply with all national and other applicable
laws and regulations relating to environmental, occupational safety and health,
transportation and labor and human resource practices. Suppliers will maintain compliance
systems and be able to demonstrate a satisfactory record of compliance with laws
and regulations in the conduct of their business.
Environmental, Health and Safety:
EHS Laws: Crossroads Enterprise, Inc. suppliers are expected to provide workers
with a safe and healthy work environment and to manage their operations to minimize
impact to the environment and community. Suppliers are expected to establish and
maintain a management system or program that encourages continual improvement in
EHS performance and includes the following elements:
- A process to protect employees from unsafe noise levels and to provide appropriate
lighting and temperatures in the workplace.
- A process to provide and maintain operating machinery and equipment with guarding
or other protective measures as necessary to prevent injury to workers.
- A process to identify, evaluate and control workplace exposures to chemical, biological
and physical agents to prevent worker illness and injury.
- A process to identify and control hazards in the workplace (examples include activities
such as regular inspections, hazard surveys, job hazard analyses, and equipment
hazard reviews).
- A process to determine the cause of incidents that result or could result in injury,
illness, property or environmental damage or business interruption.
- A process to encourage employee participation in health and safety programs and
to encourage employees to report workplace illness and injuries.
- A process to assess that sufficient and qualified resources are assigned to the
EHS program.
- A process for maintaining drums, storage tanks and other storage containers to prevent
water or soil contamination or accidental discharge and a process to remedy any
existing contamination.
- A process to ensure proper treatment of chemical or process wastewater prior to
discharge. A process to ensure safe handling and appropriate disposal or recycling
of waste.
- An EHS training program for new and existing employees.
- An emergency action program for each of its manufacturing locations covering events
such as fires, medical emergencies, weather/natural disasters, spills and air releases.
Transportation:
Transportation Laws. Crossroads Enterprise, Inc. suppliers are expected to comply
with all local, country and international laws and regulations governing the transportation
of goods and materials.
Transportation Practices. If handling Hazardous Materials* in the United States,
Suppliers are expected to be registered with the U. S. Department of Transportation
as a Hazardous Materials shipper and are expected to be trained, tested and certified
to package, mark, label and ship Hazardous Materials as required by law.
United States Department of Transportation: http://hazmat.dot.gov
If handling Dangerous Goods* outside the United States, suppliers are expected to
be trained in the following recognized regulations, as applicable, that pertain
to transportation safety:
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Air:
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International Civil Aviation Organization (ICAO) Technical Instructions
For the Safe Transport of Dangerous Goods by Air
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International Civil Aviation Organizations: http://www,icao.org
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Air:
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International Air Transport Association (IATA) Dangerous Goods Regulations
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International Air Transport Association: http://www.iata.org/index.htm
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Ocean
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International Maritime Dangerous Goods (IMDG) Code of the International Maritime Organization (IMO)
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Europe Road:
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European ADR/RID Agreement for the International Carriage of Dangerous Goods by Road
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European Agreement on International Carriage of Dangerous Goods by Road (ADR):
http://www.unece.org/trans/danger/publi/adr/adr_e.html
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*Hazardous material/dangerous good means a substance or material that has been determined by a regulatory agency (i.e. U. S. Department of Transportation, IMO, etc.) to be unreasonable risk to health, safety, and property when transported in commerce and which has been so designated. The terms hazardous material, regulated material and dangerous good are used by various regulatory agencies around the world.
Labor and Human Resources:
Labor Laws. Suppliers are expected to comply with all local country labor and human resource laws and regulations, including those related to wages, hours worked, working conditions and child labor.
Labor and Human Resource Practices. Suppliers are expected to adopt sound labor and human resource practices and treat their workers fairly. Specifically:
Employment Practices. Suppliers must hire and employ workers in compliance with applicable laws. Wages, benefits, and working hours are expected to be fair and reasonable in the local labor market.
Child Labor. Suppliers must comply with the applicable local laws with regard to the minimum hiring age for employees. If no such law exists or if the existing law permits the hiring of child labor younger than 18 years of age, the supplier may not employ child labor under 16 years of age to work on Crossroads Enterprise, Inc. projects. The supplier may hire child labor between 16 and 18 years of age to work on Crossroads Enterprise, Inc. projects only if the supplier implements and maintains, in addition to the general standards for environmental, health and safety identified below, all working conditions needed to adequately protect the safety and heath of each such child.
Forced Labor. Crossroads Enterprise, Inc. expects suppliers to not use labor that is a result of mental or physical coercion, physical punishment, slavery or other oppressive labor conditions.
Discrimination. Suppliers must respect the right of every person to participate in all aspects of employment without regard to their personal characteristics or beliefs (for example, their race, religion or sex). Suppliers’ policies and practices should result in employment decisions being made on the basis of workers’ ability to do the job, and not on their personal characteristics or beliefs.
Freedom of Association. Suppliers must respect workers’ right to associate freely, in compliance with existing local laws and without intimidation, reprisal or harassment.