CODE OF CONDUCT

SANALUX Project Management LLC

 

Global Sourcing & Operating Guidelines

SANALUX Project Management LLC seeks to conduct its business in a responsible manner. In 2018, SANALUX Project Management LLC established this comprehensive Code of Conduct.

Business Partners

Our Code of Conduct helps us to select business partners who follow workplace standards and business practices that are consistent with our company’s policies. These requirements are applied to every contractor who manufactures or finishes products for SANALUX Project Management LLC Trained inspectors closely audit and monitor compliance for its worldwide suppliers.

Partnerships That Work

For SANALUX Project Management LLC, implementing our guidelines is a comprehensive and resource-intensive effort. Our goal is to achieve positive results and effect change in partnership with our contractors, rather than to punish contractors for transgressions. Through our guidelines, we seek long-term solutions that will benefit the individuals who make our products and will improve the quality of life in the communities in which they live.

The SANALUX Project Management LLC Code of Conduct include two parts:

  1. the Business Partner Terms of Engagement, which deal with issues that are substantially controllable by SANALUX Project Management LLC’s individual business partners.
  2. The Country Assessment Guidelines, which address larger, external issues beyond the control of individual business partners (e.g., health and safety issues and political, economic, and social conditions). These help us assess the risk of doing business in a particular country.

These standards are an integral part of our business. Company employees have the authority and the responsibility to take any steps necessary to ensure compliance with all standards and policies. Our employees and our business partners understand that our guidelines are no less important than meeting our quality standards or delivery times.

 

Terms of Engagement

 

  1. Ethical Standards

We will seek to identify and utilize business partners who aspire as individuals and in the conduct of all their businesses to a set of ethical standards compatible with our own.

 

  1. Legal Requirements

We expect our business partners to be law abiding as individuals and to comply with legal requirements relevant to the conduct of all their businesses.

 

  1. Environmental Requirements

We will only do business with partners who share our commitment to the environment and who conduct their business in a way that is consistent with SANALUX Project Management LLC’s ethic Philosophy.

 

  1. Community Involvement

We will favor business partners who share our commitment to contribute to improving community conditions.

 

  1. Employment Standards

We will only do business with partners whose workers are in all cases present voluntarily, not put at risk of physical harm, fairly compensated, allowed the right of free association and not exploited in any way. In addition, the following specific guidelines will be followed:

Wages and Benefits: We will only do business with partners who provide wages and benefits that comply with any applicable law and match the prevailing local manufacturing or finishing industry practices.

Working Hours: While permitting flexibility in scheduling, we will identify prevailing local work hours and seek business partners who do not exceed them except for appropriately compensated overtime. While we favour partners who utilize less than sixty-hour workweeks, we will not use contractors who, on a regular basis, require in excess of a sixty-hour week. Employees should be allowed at least one day off in seven.

Prison Labour/Forced Labour: We will not utilize prison or forced labour in contracting relationships in the manufacture and finishing of our products. We will not utilize or purchase materials from a business partner utilizing prison or forced labour.

Health & Safety: We will only utilize business partners who provide workers with a safe and healthy work environment. Business partners who provide residential facilities for their workers must provide safe and healthy facilities.

Discrimination: While we recognize and respect cultural differences, we believe that workers should be employed based on their ability to do the job, rather than based on personal characteristics or beliefs. We will favour business partners who share this value.

Disciplinary Practices: We will not utilize business partners who use corporal punishment or other forms of mental or physical coercion.

Evaluation & Compliance

All new and existing factories involved in the manufacturing of products for SANALUX Project Management LLC must comply with our Terms of Engagement. These facilities are continuously evaluated to ensure compliance. We work on-site with our contractors to develop strong alliances dedicated to responsible business practices and continuous improvement.

If SANALUX Project Management LLC determines that a business partner is in violation of our Terms of Engagement, the company may withdraw production from that factory or require that a contractor implement a corrective action plan within a specified time. If a contractor fails to meet the corrective action plan commitment, SANALUX Project Management LLC will terminate the business relationship.

Our Commitment

SANALUX Project Management LLC is committed to continuous improvement in the implementation of our Code of Conduct. As these standards are applied throughout the world, we will continue to take into consideration all pertinent information that helps us better address issues of concern, meet new challenges, and, improve our guidelines.

 

Abu Dhabi, December 2018
The Management of SANALUX Project Management LLC