1.0 Introduction
This document reflects CWM’s policies on human rights, corporate social responsibility, ethics, and compliance with applicable laws and regulations. It reflects our internal values and the expectations of our management, associates, suppliers and customers. At CWM, business relationships are more productive and effective when built on trust, mutual respect, and shared values.
2.0 Health and Safety
CWM requires that workers are ensured a safe and healthy workplace in accordance with all relevant laws and regulations. We have established and implemented comprehensive health and safety programs that cover incident reporting and investigation, chemical safety, ergonomics, and other relevant aspects to achieve this. These measures also extend to any employee housing and dining facilities provided.
3.0 Respect and Dignity
CWM ensures that our employees are treated with dignity and respect, both physically and psychologically. This includes refraining from any form of harsh or inhumane treatment, such as physical abuse, sexual harassment, corporal punishment, mental or physical coercion, or verbal abuse of workers. Additionally, CWM has clear disciplinary policies and procedures that support these requirements and communicate them effectively to our workers.
4.0 Forced or Involuntary Labor
CWM strictly prohibits engaging in any form of forced or involuntary Labor. This includes forced, bonded, or indentured Labor, involuntary prison labor, slavery, or trafficking of persons. CWM does not transport, harbor, recruit, transfer, or receive vulnerable individuals by means of threat, force, coercion, abduction, or fraud for the purpose of exploitation. All work must be voluntary, and workers must be free to leave work at any time or terminate their employment.
5.0 Child Labor
The employment of children is strictly forbidden in any stage of manufacturing. The term “child” pertains to anyone below 15 years old, or below 14 years old if it’s permitted by the country’s law, or below the minimum age for employment and compulsory education completion, whichever is the highest. However, legitimate workplace apprenticeship programs that adhere to all laws and regulations are encouraged.
6.0 Hours of Work
In normal circumstances, the duration of a workweek, including overtime, should be at most 60 hours, and employees must have at least one day off every seven days. It’s strictly prohibited to exceed the maximum number of work hours permitted by relevant laws and regulations, except in cases of emergencies or uncommon situations.
7.0 Wages and Benefits
CWM pays their workers at least the minimum wage mandated by applicable laws and regulations and provide all legally required benefits. Workers should be compensated with a premium rate for their overtime hours on top of their regular pay. Deductions from wages should not be utilized as a form of disciplinary action. Moreover, CWM must offer vacation time, leave periods, and holidays that comply with the relevant local laws and regulations.
8.0 Non-Discrimination
CWM is dedicated to creating a workplace free from unlawful discrimination and harassment. In recruitment and employment practices such as promotions, training, and rewards, CWM refrains from discriminatory actions based on race, color, age, gender, sexual orientation, ethnicity, disability, pregnancy, religion, political affiliation, union membership, or marital status. Moreover, workers or potential employees should not be subjected to medical tests that could potentially be used in a discriminatory manner.
9.0 Freedom of Association
The freedom of workers to associate freely, including the choice to join or not join labor unions, seek representation, and participate in workers’ councils, must be respected in accordance with local laws. Workers must be able to communicate openly with management and share grievances related to working conditions and management practices without fear of harassment, intimidation, or retaliation. Suppliers have the right to create favorable employment conditions and effective communication programs for employees to promote positive relationships and minimize the need for third-party representation.
10.0 Protection of the Environment
CWM prioritizes environmental protection. To meet the minimum requirements, CWM complies with all relevant environmental laws, regulations, and standards, including but not limited to chemical and waste management and disposal, recycling, industrial wastewater treatment and discharge, air emissions controls, environmental permits, and environmental reporting. CWM establishes and maintains an environmental management system that complies with ISO 14001 or an equivalent standard.
11.0 Conflict Minerals
CWM acknowledges the significant legal and non-legal risks associated with sourcing tin, tantalum, tungsten, and gold as stipulated in the Dodd-Frank Act Section 1502. When presented a PO, CWM assures Suppliers certify that it complies with the Act’s reporting requirements, irrespective of the country or countries in which it operates. If any of these minerals are present in products supplied to CWM, the Supplier must disclose this information to the CWM buyer. For these minerals, CWM expects the Supplier to conduct a reasonable inquiry into the country of origin and perform due diligence to establish the conflict status of the mine or smelter. This information must be provided to CWM. 12.0 Laws and Regulations
12.0 Laws and Regulations
CWM will comply with all applicable laws and regulations in all locations where they conduct business.
13.0 Anti-Corruption & Business Ethics
CWM conducts our business in accordance with the highest ethical standards. CWM strictly complies with all laws and regulations relating to bribery, corruption, and prohibited business practices. This includes:
- The laws and regulations of Canada, particularly the Corruption of Foreign Public Officials Act (CFPOA);
- The laws and regulations of the United States, particularly the Foreign Corrupt Practices Act (FCPA); and
- The anti-corruption laws and regulations of other countries in which CWM and CWM Suppliers operate.
Any arrangements involving payment, offer, or promise of improper benefits or advantages with an expectation of receiving something in return, commonly referred to as “quid pro quo,” are strictly prohibited, including any form of bribery. Additionally, facilitation payments, which are payments made to expedite routine government actions, are also strictly prohibited.
