Spring Step Shoes Suppliers Code of Conduct

Spring Step Shoes is committed to conducting business in an ethical and honest manner, and in a way that promotes corporate social and environmental responsibility. This includes responsible supplier selection by conducting business with suppliers who share Spring Step Shoes commitment to integrity. We understand that the business practices and actions of a supplier may impact or reflect upon Spring Step Shoes. Therefore, Spring Step Shoes requires its suppliers (Suppliers), their employees, agents and sub-suppliers to operate in accordance with the principles and ethical standards contained in the Spring Step Shoes Suppliers Code of Conduct.

The Suppliers Code presents detailed standards and expectations for each Supplier concerning labor and human rights, health and safety, environmental protection, business ethics, and management practices.

Spring Step Shoes Suppliers shall conduct their business activities in full compliance with the applicable laws and regulations of the United States and any other applicable laws. Suppliers must ensure that products, services and shipments are in compliance with all applicable international trade compliance laws, rules and regulations.

Suppliers are to provide safe working conditions, treat workers with respect and dignity, act fairly and ethically, and use environmentally responsible practices wherever possible in the course of making or providing products for Spring Step Shoes. Supplier compliance with this Suppliers Code will be assessed, and any violations of this Code may jeopardize the Supplier’s business relationship with Spring Step Shoes. Potential consequences for violation include termination.

 

HUMAN RIGHTS AND LABOR

All workers deserve a fair and ethical workplace. Workers must be treated with dignity and respect, and Suppliers shall maintain the highest standards of human rights. Accordingly, all Suppliers and other participants in Spring Step Shoes’ supply chain are expected to comply following labor standards:

  • Child Labor Avoidance

Suppliers shall not use any child labor. The term “child” refers to any person employed under the applicable minimum age for completion of required school education, or under the minimum age for employment in any particular country, whichever is greatest. Workers under the age of 18 shall not perform work that is likely to jeopardize the health, safety or morals of young workers. Suppliers shall not require juvenile workers to work overtime or perform night work. Suppliers shall also comply with all other applicable laws and regulations regarding the employment of minors.

  • Voluntary Labor

Suppliers shall only use voluntary labor and shall not engage in any form of human trafficking or use any type of forced labor including slave, bonded, involuntary or prison labor. All work must be voluntary and workers shall be free to leave work at any time or terminate their employment. Suppliers shall ensure that workers’ contracts clearly express the conditions of employment in a language understood by the workers. Suppliers shall ensure that any third-party recruitment agencies used comply with the provisions of this Code and applicable laws.

  • Discrimination

Suppliers must be committed to a workforce free of harassment and unlawful discrimination. Suppliers shall employ workers on the basis of their ability to do the job and shall not engage in discrimination against any worker on the basis of race, sexual orientation, gender identity, color, age, gender, maternity, national origin, disability, religion, ethnicity, marital status, political affiliation, or union membership, in hiring and other employment practices such as promotions, rewards and access to training.

  • Wages and Benefits

Workers should have the ability to earn fair wages, as determined by applicable local law. Suppliers must comply with all applicable wage and hour laws and regulations, including those relating to minimum wage, overtime, and other elements of compensation, and must provide all legally mandated benefits. Workers shall be paid at least the minimum legal wage or a wage that meets local industry standards, whichever is greater. Supplier shall compensate workers for overtime hours at the legal premium rate. Suppliers shall communicate pay structure and pay periods to all workers. Suppliers shall pay accurate wages in a timely manner, and wage deductions shall not be used as a disciplinary measure. Suppliers are fully responsible for the quality, performance, behavior, supervision and protection of their personnel.

  • Working Hours

Suppliers must maintain work hours in compliance with all applicable laws and regulations. Further, a workweek shall be restricted to a maximum of 60 hours, including overtime, except in emergencies or unusual situations, and workers shall take at least one day off every seven days. Suppliers shall follow all applicable laws and regulations with respect to working hours and days of rest, and all overtime must be voluntary.

  • Humane Treatment

Suppliers shall treat each worker with dignity and respect. Suppliers shall commit to a workplace free of harassment and abuse, and will not engage in, or threaten workers with, harsh or inhumane treatment, including sexual harassment, psychological harassment, sexual abuse, corporal punishment, mental or physical coercion or verbal abuse. Worker dormitories provided by Suppliers or labor agent shall be clean and safe and provide reasonable living space with adequate heat and ventilation along with reasonable entry and exit privileges.

 

HEALTH AND SAFETY

  • Safe work environment

Suppliers must be committed to the safety and health of their employees and shall provide and maintain a safe work environment by minimizing physical and chemical hazards through proper design, engineering and administrative controls, preventative maintenance, safe work procedures and ongoing safety training. Suppliers are responsible for assuring that all workers are qualified to perform their work functions safely. Suppliers shall provide workers with appropriate workplace health and safety training in their primary language and health and safety related information shall be clearly posted in the facility.

  • Incident reporting

Suppliers must have procedures and systems in place that allow workers to report health and safety incidents, as well as a system to investigate, classify, track, and manage such reports. Such procedures and systems must implement all applicable laws and regulations, and include provisions to encourage worker reporting and implement corrective actions. Supplier corrective action plans should alleviate risks, provide necessary medical treatment, and assist workers’ return to work.

  • Hazards of physically demanding tasks

Suppliers shall identify, evaluate, and control worker exposure to the hazard of physically demanding tasks, including manual material handling, heavy or repetitive lifting, prolonged standing, and highly repetitive or forceful assembly tasks. Suppliers shall integrate this process into the qualification of all new or modified production lines, equipment, tools, and workstations. Suppliers shall also evaluate production and other machinery for safety hazards and shall properly maintain physical guards, interlocks, and barriers where machinery presents an injury hazard to workers.

  • Personal Protective Equipment

Workers shall have the right to refuse unsafe work and to report unhealthy working conditions.

Workers shall not be disciplined for raising safety concerns. Suppliers shall provide workers with appropriate, well maintained personal protective equipment and instruction on its proper use.

  • Emergency Preparedness

Suppliers must have procedures in place for handling emergencies such as fire, spills, and natural disasters. For each potential emergency situation or event, Suppliers shall develop and implement legally compliant emergency plans and response procedures that minimize harm to life, environment, and property, and shall include:

  • Emergency preparedness, reporting and notification;
  • Evacuation procedures;
  • Training and drills;
  • Appropriate hazard detection and suppression equipment;
  • Adequate exit facilities from job sites.

 

 ENVIRONMENT

Suppliers shall develop, implement, and maintain environmentally responsible business practices, such as seeking ways to conserve natural resources and energy, reduce waste and the use of hazardous substances, and minimize adverse impacts on the environment.

  • Compliance with Environmental Laws

Suppliers must comply with all applicable environmental laws and requirements, including those relating to obtaining, maintaining and adhering to environmental permits and approvals for the conduct of regulated activities; the management and disposal of hazardous materials; releases of contaminants to the air, soil and water; the protection of natural resources, wildlife and wetlands; the prohibition or restriction of specific substances; and the recycling of materials and environmental claims.

  • Environmental Permits

Suppliers shall obtain, keep current, and comply with all required environmental permits, and shall comply with the reporting requirements of applicable permits and regulations.

  • Hazardous Materials

Suppliers shall implement a systematic approach to identify, manage, reduce, and responsibly dispose of or recycle hazardous substances and other materials posing a hazard if released into the environment to ensure their safe handling, movement, storage, use, recycling or reuse and disposal. Further, Suppliers shall comply with regulated substance specifications and any applicable laws and regulations prohibiting or restricting the use or handling of specific substances.

 

ETHICS AND STANDARD OF CONDUCT

Suppliers are expected to conduct business with integrity, mutual respect, and to maintain the highest standards of ethics and behavior in every aspect of their businesses, including relationships, practices, sourcing, and operations.

  • Business Integrity

Suppliers shall not engage in, and have a zero tolerance policy regarding corruption, misrepresentation, extortion, embezzlement, kickbacks, bribery and any other type of corrupt actions to obtain or retain business or to obtain an unfair or improper advantage. Suppliers shall abide by the Foreign Corrupt Practices Act (FCPA), and all applicable anti-corruption laws and regulations of the countries in which they operate,. Suppliers shall implement monitoring and enforcement procedures to ensure compliance with anti-corruption laws. Suppliers must immediately report to Spring Step Shoes any circumstance where an officer, director, employee, representative or agent of Spring Step Shoes or any of its subsidiaries has made any improper request or demand of the Supplier that could violate any law. All business dealings, structure, financial situation, and performance should be transparently performed and accurately reflected on Suppliers’ business books and records in accordance with applicable laws and regulations as well as prevailing industry business practices.

 

COMPLIANCE WITH SUPPLIERS CODE OF CONDUCT

Suppliers shall establish and maintain a management system that ensures compliance with this Suppliers Code and applicable laws, identifies and mitigates related operational risks, and facilitates continuous improvement and prompt corrective action. The management system must be designed to ensure ongoing compliance with applicable laws, regulations, requirements related to Supplier operations and products; as well as compliance with this Suppliers Code of Conduct evidenced by documentation and records. Suppliers must ensure that this Code is appropriately communicated to all of its officers, directors, employees, representatives, agents and sub-suppliers.

  • Audits and Assessments

Suppliers must complete annual self-evaluations of their facilities and operations, and the facilities and operations of their sub-suppliers to ensure compliance with this Code and legal and regulatory requirements. Suppliers are required to respond and certify their compliance with the Code and all applicable laws. Spring Step Shoes reserves the right to investigate instances of non-compliance with this Supplier Code or laws on human trafficking and slavery, which may include a supplier site audit.

  • Documentation and Records

Suppliers shall have processes to identify, understand, and implement applicable laws and regulations and requirements of this Code. Suppliers shall maintain documents and records to ensure regulatory compliance.

  • Corrective Action Process

Suppliers shall have a process for timely correction of any deficiencies or violations identified by an audit, assessment, inspection, investigation, or review.

  • Reporting Violations

Suppliers shall promptly report questionable behavior, concerns, or potential or actual violations of this Suppliers Code of Conduct and implement a corrective action plan to eliminate the non- compliance within a specified time period. This Supplier Code of Conduct is intended to facilitate improved communications by informing current and potential Suppliers of Spring Step Shoes standards, and ethical expectations of our Suppliers. Suppliers with questions regarding this Code should contact Spring Step Shoes at service@springstepshoes.com.