Responsible Sourcing Policy

Published: 15th June 2024

1. Purpose & Scope

1.1 This policy sets out Four32’s expectations of its Suppliers regarding sustainable business practices.

1.2 This policy applies to all employees and sourcing decisions.

2. Approval & Responsibility

2.1 This policy has been approved by the Board of Directors, who have ultimate responsibility for this policy and for ensuring it is adequately communicated.

2.2 All Employees are responsible for observing and complying with the provisions of this policy and for avoiding any activity that might lead to, result in, or suggest a breach of this policy.

3. Policy Statement

3.1 It is the business’s policy to require high standards of sustainable business practices from its Suppliers.

3.2 The business expects Suppliers to aspire to sustainable operations and supply chains with high standards of environmental, social and ethical responsibility.

3.3 As a minimum, Suppliers are expected to comply with all relevant laws, respect human rights, and share the business’s social and environmental commitments.

4. Environmental

4.1 The business is committed to respecting and protecting the environment, minimising potential negative long-term impacts, and complying with environmental laws. The business expects the same approach from its Suppliers.

4.2 The business expects the following from its Suppliers:

(a) High Environmental Standards. Suppliers must conduct their business in a way which safeguards the natural environment.
(b) Environmental Compliance. Suppliers must comply with all applicable environmental laws and regulations (including those relating to regulated chemicals and substances), obtain and comply with all necessary environmental permits, and properly dispose of hazardous and regulated substances.
(c) Climate Change. Suppliers must proactively work to decarbonise and reduce emissions, including improving energy efficiency, using renewable energy where possible, and reducing or eliminating greenhouse gas emissions. Suppliers must measure their carbon footprint in line with international best practice and set targets to reduce Scope 1, 2 and 3 emissions to support a net-zero global economy by 2050. Suppliers must also work to ensure their products and/or services contribute towards decarbonisation in their industries.
(d) Water. Suppliers must understand and manage their impact on water and aim to reduce consumption where appropriate, in line with responsible water stewardship.
(e) Environmental Degradation. Suppliers must refrain from activities that cause short- or long-term harm to the planet, including avoiding or minimising water pollution, air pollution, land degradation, and natural resource depletion.
(f) Biodiversity. Suppliers must avoid damage to local biodiversity and ensure their operations do not contribute to deforestation.
(g) Waste & Resource Use. Suppliers must manage resources (including metals and plastics) responsibly, reduce waste to landfill via recycling and waste reduction initiatives, and adopt circular economy principles when designing and supplying products. Suppliers should seek to eliminate unnecessary packaging and use reusable packaging where possible.

4.3 Suppliers are expected to provide relevant data on their operations to enable the business to track, monitor, and improve its environmental performance.

5. Human Rights

5.1 The business is committed to respecting internationally recognised human rights standards, including the United Nations Universal Declaration of Human Rights, the 10 principles of the United Nations Global Compact, and the International Labour Organisation’s Declaration on Fundamental Principles and Rights at Work. The business expects the same approach from its Suppliers.

5.2 The business expects the following from its Suppliers:

(a) Forced Labour, Slavery & Human Trafficking. The business has a zero-tolerance approach to slavery and human trafficking and expects the same from Suppliers. Suppliers must not use forced, bonded, or involuntary labour, nor engage in or facilitate slavery or human trafficking. Suppliers must not charge recruitment fees, confiscate or deny access to identity documents, or restrict worker movement. Work must be voluntary and workers must be free to leave employment in line with their terms.
(b) Diversity, Equity & Inclusion. Suppliers must support a workplace free from bullying, harassment, victimisation and unlawful discrimination. Within local laws and practices, Suppliers must not unlawfully discriminate, nor engage in physical abuse, discipline, sexual harassment, or verbal abuse/intimidation.
(c) Freedom of Association, Collective Bargaining & Employment Terms. Suppliers must respect rights to join or not join unions and to bargain collectively where permitted, and comply with all laws relating to wages, pay, benefits and working hours.
(d) Health & Safety & Working Conditions. Suppliers must comply with applicable health and safety laws, provide a safe, clean and hygienic workplace, identify and assess hazards and risks associated with their products or services, and ensure adequate safeguards and working practices are in place to reduce or eliminate risk.
(e) Child Labour. The business does not tolerate child labour and will not work with Suppliers who use it. Suppliers must not employ anyone below the legal minimum employment age or the age of completion of compulsory education, except via legitimate work placement or experience schemes.

6. Ethical Conduct

6.1 The business is committed to operating to the highest ethical standards and expects the same from its Suppliers.

6.2 The business expects the following from its Suppliers:

(a) Legal Compliance. Suppliers must comply with all laws and regulations applicable to their operations, including data privacy and protection, trade compliance (export/import controls, embargoes, sanctions), and antitrust/competition laws. Suppliers must not fix prices, rig bids, allocate markets/customers, or share pricing information with competitors.
(b) Ethical Standards. Suppliers must maintain high standards of integrity, honesty, professionalism, fair dealing, and social responsibility. They must not engage in conduct that could harm the business’s reputation and must not facilitate financial crime, including money laundering or tax evasion.
(c) Bribery & Corruption. Suppliers must comply with all anti-bribery and anti-corruption legislation and must not engage in practices that are, or could be perceived as, corrupt or fraudulent. Suppliers must never pay or accept bribes, kickbacks, inducements, or facilitation payments (nor tolerate others doing so).
(d) Conflicts of Interest. Suppliers must avoid interactions with Employees that create, or could reasonably be perceived to create, inappropriate conflicts of interest.
(e) Ethical Sourcing. Suppliers must source ethically, including purchasing from responsible sub-suppliers, seeking local/regional sourcing where practicable, not knowingly using conflict minerals or commodities linked to deforestation, and carrying out appropriate due diligence.
(f) Speaking Up. Suppliers must encourage employees/workers to raise concerns without fear of retaliation and provide accessible grievance and whistleblowing mechanisms.

7. Non-Compliance by Suppliers

New Suppliers who are unable to comply with the expectations set out in this policy should not be engaged. Where an investigation concludes that an existing Supplier is breaching the requirements of this policy, steps must be taken to ensure the breach is not repeated and, where appropriate, the business should cease working with the Supplier as soon as practicable while avoiding disruption or damage to operations.