Contents

Introduction. 2

1. No forced labor. 2
2. No child labor. 2
3. No discrimination. 3
4. Respect for freedom of association and collective bargaining. 3
5. No harsh or inhumane treatment. 3
6. Safe and hygienic working conditions. 3
7. Wages are paid. 4
8. Working hours are not excessive. 4
9. Regular employment. 5
10. Traceability of production. 5
11. Health and Safety of products. 5
12. Environmental awareness. 5
13. Confidentiality of information. 6
14. Code implementation. 6

14.1 Transparency. 6

14.2 Reference to national legislation, Conventions and Agreements. 6

14.3 Verification of compliance. 6

14.4 Committee of Ethics and Whistleblowing Channel 7

 

 

 

Introduction

The KH Recruiting LLC Code of Conduct for Manufacturers and Suppliers (hereinafter, the Code)

defines minimum standards of ethical and responsible behavior which must be met by the manufacturers and suppliers of the products commercialized by KH Recruiting LLC in the course of its business, in line with the corporate culture of KH Recruiting LLC Group (hereinafter KH Recruiting LLC), firmly based on the respect for Human and Labor Rights.

 

KH Recruiting LLC undertakes to allocate the appropriate resources so that manufacturers and

suppliers are acquainted with and understand this Code and are able to ensure its compliance.

 

The Code shall be applied to all manufacturers and suppliers that take part in the purchasing, manufacturing and finishing processes and fosters and is based upon the following general principles that define KH Recruiting LLC’s ethical behavior:

- All KH Recruiting LLC’s operations are developed under an ethical and responsible perspective.

- All persons, individuals or entities, who maintain, directly or indirectly, any kind of employment, economic, social and/or industrial relationship with KH Recruiting LLC, are treated fairly and with dignity.

- All KH Recruiting LLC’s activities are carried out in a manner that most respects the environment.

- All manufacturers and suppliers (production centers that are not property of KH Recruiting LLC) fully adhere to these commitments and undertake to ensure that the standards which are set forth in the Code are met.

1. No forced labor

KH Recruiting LLC shall not allow any form of forced or involuntary labor in their manufacturers

and suppliers. They may not require their employees to make any kind of “deposits”, nor are they entitled to retain employees’ identity documents.

 

Manufacturers shall acknowledge the right of their employees to leave their employer after reasonable notice.

 

2. No child labor

Manufacturers and suppliers shall not employ minors. KH Recruiting LLC defines minors as those persons who have not yet reached their 16th birthday. In cases where local legislation stipulates a higher minimum age, the higher limit shall apply.

 

Persons with the ages between of 16 and 18 years will be considered young workers.

 

Young workers shall not work during night hours or in hazardous conditions:

 

1. Aspects related to such limitations will be governed by Conventions 29 and 105 of International Labor Organization (ILO)
2. Aspects related to prohibition of child labor will be developed according to Conventions 138 and 182 of the International Labor Organization (ILO)

3. No discrimination

Manufacturers and suppliers shall not apply any type of discriminatory practice with regards the recruitment, compensation, access to training, promotion, termination of the employment agreement or retirement, based on race, caste, creed, nationality, religion, age, physical or mental disability, gender, marital status, sexual orientation and/or union membership or political affiliation.

 

Women and men workers shall be protected against discrimination on the basis of marital status.

 

Pregnancy tests or the use of contraception shall not be used as a condition of hiring or continued employment.

 

Women workers shall be protected against threats of dismissal or any other employment decision that negatively affects their employment status in order to prevent them from getting married or becoming pregnant.

 

Equal opportunities for women and men shall be provided in all aspects of training and personal and professional development.

 

 Workers with family responsibilities shall be protected against discrimination with regard to dismissal (see ILO Convention No. 156).

4. Respect for freedom of association and collective bargaining

Manufacturers and suppliers shall ensure that their employees, without distinction, have the right of association, union membership and collective bargaining. No retaliation may arise from the exercise of such right and no remuneration or payment whatsoever may be offered to the employees in order to hinder the exercise of such a right. Likewise, they shall adopt an open and collaborative attitude towards the activities of Trade Unions.

 

Workers’ representatives shall be protected from any type of discrimination and shall be free to carry out their representative functions in their workplace.

 

Where the rights to Freedom of Association and Collective Bargaining are restricted under law, the appropriate channels to ensure a reasonable and independent exercise of such rights must be designed.

 

5. No harsh or inhumane treatment

Manufacturers and suppliers shall treat their employees with dignity and respect. Under no circumstances shall physical punishment, sexual or racial harassment, verbal or power abuse or any other form of harassment or intimidation be permitted.

6. Safe and hygienic working conditions

Manufacturers and suppliers shall provide a safe and healthy workplace to their employees, ensuring minimum conditions of light, ventilation, hygiene, fire prevention, safety measures and access to a drinking water supply.

 

Workers shall have access to clean toilets facilities and drinking water. Where necessary, facilities for food storage shall be provided.  Accommodation, where provided, shall be clean and safe. 

 

Manufacturers and suppliers shall take the required steps to prevent accidents and injuries to health of their workers, by minimizing as much as possible the risks inherent to work

1. Aspects related to labor conditions for young workers will be governed by ILO. Recommendation 190.
2. Aspects related to labor practices will be developed according to ILO Convention 111.
3. Aspects related to freedom of association and collective bargaining will be developed according to ILO Conventions 87, 98 and 135.
4. Manufacturers and suppliers shall provide their workers with regular training in the matter of health and safety at work. The company shall keep an appropriate record of the training courses done. Likewise, they shall appoint a person in charge of health and safety within the Management, duly authorized and with the appropriate decision taking power

7. Wages are paid

Manufacturers and suppliers shall ensure that wages paid meet at least the minimum legal or collective bargain agreement, should this latter be higher. In any event, wages should always be enough to meet at least the basic needs of workers and their families and any other which might be considered as reasonable additional needs.

 

Manufacturers and suppliers shall not make any withholdings and/or deductions from wages for disciplinary purposes, nor for any reasons other than those provided in the applicable regulations, without the express authorization of workers. Likewise, they shall provide all workers with: written and understandable information about their wages conditions upon their recruitment, and detailed information about the particulars of their wages every time that these are paid.

 

Manufacturers and suppliers shall also ensure that wages and any other allowances or benefits are paid on time and are rendered in full compliance with all applicable laws and specifically, that payments are made in the manner that best suits the workers.

 

Women employees are entitled to maternity protection (leave and benefits as well as protection against discrimination) in accordance with the requirements of national laws and regulations or ILO Conventions Nos. 183, 103, and 3), whichever is higher.

 

Childcare benefits and special leave or working time arrangements for workers with family responsibilities shall apply to both men and women.

 

8. Working hours are not excessive

Manufacturers and suppliers shall adjust the length of the working day to the provisions of the applicable laws or of the collective bargain agreement applicable for the sector in question, if the latter affords greater protection for the workers.

 

Manufacturers and suppliers shall not require their employees to work, as a rule of thumb, in excess of 48 hours a week and workers shall be granted at least one day off for every 7 calendar day period on average.

 

Overtime shall be voluntary, shall not exceed 12 hours per week, shall not be demanded on a regular basis and shall always be compensated at a premium rate, pursuant to the provisions of the prevailing regulations in force.

9. Regular employment

Manufacturers and suppliers undertake that all the employment formulas they use are part of the applicable local laws. Thus, they shall not impair the rights of workers acknowledged under labor and social security laws and regulations by using schemes that have no real intention to promote regular employment in the framework of regular employment relationships.

 

1. Aspects related to labor conditions relation to work health and safety will be governed by ILO Convention 155.
2. Aspects related to payment of wages will be governed by ILO Conventions 26 and 131.
3. Working day related issued will be governed by ILO Conventions 1 and 14.

10. Traceability of production

Manufacturers and suppliers shall not assign any work to third parties without the prior written authorization of KH Recruiting LLC. Those who outsource any work shall be responsible for the enforcement of the Code by these third parties and their employees.

 

Likewise, manufacturers and suppliers shall apply the principles of this Code to any homeworker involved in their supply chain, and shall give transparency to the locations and working conditions of said homeworkers.

11. Health and Safety of products

Manufacturers and suppliers are responsible for all products supplied to KH Recruiting LLC to comply with KH Recruiting LLC health and safety product standards so that the commercialized products do not entail any risk to customers.

12. Environmental awareness

Manufacturers and suppliers shall be duly committed at all times to protect the environment and shall comply with the standards and requirements of the applicable local and international Laws and Regulations.

 

Likewise, they commit to comply with environmental standards established by KH Recruiting LLC

including, if applicable, the necessary measures to reduce and compensate such impact in order to apply said standards.

13. Confidentiality of information

Manufacturers and suppliers shall preserve the integrity and confidentiality of the information they may receive as a consequence of their commercial relationship with KH Recruiting LLC.

 

The obligation of confidentiality will remain once the relation with KH Recruiting LLC is terminated and it will include the obligation to return any material related to the company held by the manufacturer or supplier.

14. Code implementation

Manufacturers and suppliers shall implement and maintain programs to set in motion this Code. They shall appoint a senior member of Management who shall be responsible for the implementation and enforcement of this Code.

 

Manufacturers and suppliers shall communicate the Code to all employees and those in any way involved in the KH Recruiting LLC Supply Chain.

 

A copy of the Code, translated into the local language, shall be displayed in accessible locations to all workers.

14.1 Transparency

Manufacturers and suppliers shall carry out their activities in an honest, upright and transparent way, keeping for these purposes an appropriate accounting records system that facilitates the traceability of their decisions, as a preventive measure versus any type of corruption, bribe and extortion that might arise.  Manufacturers and suppliers shall not offer, grant, request or accept any gifts or donations to/from KH Recruiting LLC buyers which might infringe the provisions of the “KH Recruiting LLC Code of Conduct and Responsible Practices”.

 

Manufacturers and suppliers shall not manipulate or influence their workers, nor shall they forge any files or records in order to alter the verification process regarding compliance with this Code.

 

Manufacturers and suppliers shall neither offer nor accept remuneration of any kind which seeks, or may be perceived to seek, to affect the impartial judgment or the objectivity of such parties appointed by KH Recruiting LLC to carry out inspections and compliance audits in connection with this Code.

14.2 Reference to national legislation, Conventions and Agreements

The provisions of this Code constitute only minimum standards.  Should national regulations or any other applicable Law or any other commitments undertaken or applicable, including collective bargaining agreements, govern the same issue, the provision which offers greater protection for workers shall apply. 

KH Recruiting LLC assumes, as part of its internal norms, the content of national and international Agreements and Conventions to which it has adhered, and that they are applied in its relationship with manufacturers and suppliers, committing to their promotion and compliance.

14.3 Verification of compliance

Manufacturers and suppliers shall authorize KH Recruiting LLC and/or any third parties the former might appoint, to monitor the appropriate enforcement of the Code. For these purposes, they shall provide the required means and the appropriate access to the facilities and documentation required to ensure this verification.

 

14.4 Committee of Ethics and Whistleblowing Channel

This Code is aligned with the principles and values that are included in the KH Recruiting LLC Code of Conduct and Responsible Practices, which regulates a Committee of Ethics and Whistleblowing Channel to ensure its enforcement.

 

In this sense, and in order to ensure the enforcement of the Code of Conduct for Manufacturers and Suppliers, the Committee of Ethics can act at its own initiative or following a formal complaint made in good faith by a manufacturer, supplier or other interested third party that might have any direct relationship or commercial or professional interest with KH Recruiting LLC.

 

To this end, any notices given pursuant to the provisions of this Code, either reports of any breach or enquiries regarding the Code’s interpretation or application can be addressed directly to the Committee of Ethics via:

 

Email:  KHRecruitingLLC@gmail.com
Phone: (224) 522-8734