FOZ One is committed to respecting human rights, the environment, and ethical business practices. The FOZ One Ethical and Environmental Code of Conduct (“EECoC”) sets out the minimum standards that FOZ One expects its manufacturing operations and all our Business Partners to meet or exceed.
FOZ One has adopted the International Social Compliance Standard & other interested parties’ Code of Conduct as a part of its Supplier Code of Conduct for FOZ One and its suppliers. FOZ One expects all suppliers to operate in alignment with FOZ One’s Supplier Code, which outlines standards for responsible practices in Labor, Health and Safety, Environmental Protection, and Ethics. In addition to meeting the requirements of the International Social Compliance Standard, this standard also includes expectations specific to FOZ One’s suppliers. The International Social Compliance Standard and Code of Conduct are also outlined in the appendix.
FOZ One must comply with all applicable local, national, and international laws and regulations. Where the obligations in the EECoC impose higher standards than those specified by the relevant laws and regulations, then the obligations in the EECoC will prevail.
2.1 This EECoC applies to FOZ One’s manufacturing operations and FOZ One’s Business Partners.
2.2 FOZ One must always comply with this EECOC across all parts of their business operations. FOZ One must ensure that any subcontractors appointed to produce FOZ One products or provide services for FOZ One must comply with the EECoC as if they were a ‘Business Partner’, and they must also take a proactive approach to ensure that the EECoC’s standards are implemented and maintained within their supply chain.
3.1 ISO 14001:2015 Clause 6.1.3
3.2 Environmental Quality Act and its Regulations
3.3 Occupational Safety and Health Act and its Regulations
3.4 Employment Act and its Regulation
3.5 Customer’s Social Compliance Code of Conduct or guideline
3.6 RBA Code of Conduct Version 8.0
Appendix 1: Grievance procedure flowchart
Appendix 2: Business Partner’s Do’s & Don’ts on Environmental, Safety, and Health
Appendix 3: FOZ One’s Commitment towards the RBA Code of Conduct
Management: To develop a strategic initiative for this policy
CSER Committee: To implement and ensure compliance with this policy within the organization
Head of Department: To implement and communicate this policy with their subordinates
Employee: To understand and comply with the guidelines set out in this policy
6.1 “Business Partners” means any person (including a company, other legal entity, or individual) working with or on behalf of FOZ One. This may include suppliers, manufacturers, logistics providers, distributors, and other service providers.
6.2 “Child” or “Children” refers to any person under the age of 15, or under the age of completion of compulsory schooling, or under the minimum age for regular or full-time employment in the country, whichever is greatest.
6.3 “Conflict-Affected and High-Risk Areas (CAHRA)” are defined by the OECD Due Diligence Guidance and they are identified by the presence of armed conflict, widespread violence or other risks of harm to people.
6.4 “Hazardous Work” means work likely to jeopardize the health or safety of Workers including underground work, underwater work, work at dangerous heights or in confined spaces; work in unhealthy environments (such as environments that expose Workers to extreme temperatures, loud noise, excessive dust); work with dangerous machinery, chemicals/radioactive substance handling, vibration equipment or electricity; handling heavy loads; working overtime or at night.
6.5 “High-Risk Material” means any raw material, processed commodity or product that presents any environmental (resource consumption, emissions, waste) or social (human rights, labour practices, health & safety) risk due to country of origin, method of extraction/processing, type of material, or as identified by FOZ One.
6.6 “Juvenile Workers” means a Worker who is not a Child but is younger than 18 years of age.
6.7 “Migrant Workers” means a Worker whose nationality and permanent residence is different from the country in which the FOZ One or Business Partner facility at which they are working is located.
6.8 “Sustainability Practices” means governance, policies and mechanisms in place regarding human rights, labour practices, ethics, responsible sourcing, environmental performance, and health and safety.
6.9 “Third Party Employment Agency” A private, public or government agency, including subagents, carrying out operations on behalf of individuals or enterprises, whose role is to provide access to employment or career progression by filling employment vacancies.
6.10 “Workers” means any person working for or on behalf of an organization, including direct employees, temporary or seasonal workers and contract workers.
6.11 RBA – Responsible Business Alliance
6.12 VAP – Validated Assessment Program
6.13 Any words that follow the terms “include”, “including”, “such as”, or “for example” are intended to be non-exhaustive and they do not limit the generality of the words preceding those terms.
7.1 Labour Practices
i. No Forced Labour: Forced, bonded (including debt bondage) or indentured labour, involuntary or exploitative prison labour, slavery, or trafficking of persons is not permitted. This includes transporting, harboring, recruiting, transferring, or receiving persons by means of threat, force, coercion, abduction, fraud; or the making of payments to any person having control over another person for the purpose of their exploitation.
a. All work must be voluntary and Workers must be free to terminate their employment without penalty if reasonable notice is given, as per the Worker’s contract.
b. All Workers must be provided with a contract that clearly conveys the terms and conditions of employment in a language understood by the Workers.
c. Workers shall not be required to pay employers, agents, sub-agents or facilitators recruitment fees whatsoever or other related fees for their employment. Business Partners will identify (using an appropriate method of their own choosing) where Workers have paid fees and re-pay them to the Worker immediately.
d. All Migrant Workers must have full and unconditional access to their personal identification and immigration documents at all times.
e. There will be no unreasonable restrictions on Workers’ freedom of movement within the workplace or upon entering or exiting company-provided facilities including Worker accommodation.
f. Any Third-Party Employment Agencies that are used must comply with the provisions of the EECoC and all applicable laws and regulations.
g. Compliance with forced labour prevention legislation is mandatory and therefore labour and materials must not be sourced from regions prohibited by law.
h. FOZ One will ensure there is no forced labour in their supply chains by conducting appropriate due diligence.
ii. No Child Labour: Child labour is strictly prohibited. FOZ One must not allow, procure or facilitate any work from Children. FOZ One will ensure there is no Child labour in their supply chains by conducting appropriate due diligence.
The employment of Juvenile Workers is only permitted where all of the following conditions are satisfied:
a. An appropriate mechanism to verify the age of Workers has been implemented and the age of Juvenile Workers has been verified before they begin work.
b. Juvenile Workers must not carry out Hazardous Work.
c. Juvenile Workers must not work overtime or perform night-time work.
d. Any work conducted by a Juvenile Worker must not prevent participation in or attendance at any schooling to which they are enrolled.
e. The wage rate for Juvenile Workers must be at least the same wage rate as other entry-level Workers performing equal or similar tasks. Salary and compensation for such work must be paid directly to the Juvenile Worker.
iii. Working Hours, Wages, and Benefits:
a. Working hours shall not exceed relevant national limits in the country of employment. Workers in FOZ One manufacturing operations shall work to a maximum of 60 hours per week, inclusive of overtime.
b. Overtime must be voluntary and consensual. Workers must be compensated for overtime at rates of pay greater than regular hourly rates and always in compliance with all applicable laws and regulations.
c. All Workers must receive at least one rest day (24 consecutive hours) in every seven days.
d. Wages paid to Workers shall comply with all applicable laws and regulations, including those relating to minimum wages, overtime hours and legally mandated benefits. Wages shall be paid accurately and in a timely manner.
e. Workers shall be entitled to paid annual leave, public holidays, medical leave, and benefits in accordance with the requirements of all applicable laws and regulations.
f. The regular working week schedule and working hours must be stated clearly in Worker employment contracts and published clearly at the place of work.
g. An effective and anonymous feedback mechanism must be provided for Workers to report workplace grievances. Confidentiality will be protected, and retaliation is prohibited.
h. Workers shall be provided with reasonably accessible and clean toilet facilities, as well as safe drinking water.
iv. No Discrimination: FOZ One and our Business Partners shall not discriminate based on race, ethnicity, caste, national origin, age, religion, disability, gender, pregnancy, gender identity, marital status, sexual orientation, union membership, political affiliation or any status protected by law.
v. Freedom of Association: FOZ One and our Business Partners will not prevent Workers from free association. This includes the ability to form and join trade unions, to bargain collectively and to engage in peaceful assembly, or choose not to do so, without fear of discrimination or retaliation.
vi. Fair Working Practices: Every Worker shall be treated with dignity and respect. No Worker shall be subject to, or threatened by, any physical, sexual, psychological, or verbal harassment, abuse or humiliation. Disciplinary measures shall not include any financial penalties.
7.2 Environment
FOZ One and our Business Partners share a commitment to protect human health and the environment. Refer to Appendix 2 on Business Partner’s Environmental Do’s & Don’t.
i. Permits and Reporting: All required environmental permits, licenses, consents, approvals, and registrations are to be obtained, maintained, and kept current.
ii. Environmental Protection and Greenhouse Gas Emissions: Environmental impacts and Greenhouse Gas (GHG) emissions shall be identified, measured, managed, reduced, and responsibly controlled.
iii. Resource Conservation: The use of natural resources shall be identified, managed, reduced, and responsibly controlled. Conservation methods may include material usage reduction or substitution.
iv. Hazardous Substances: Chemicals, waste, and other materials posing a hazard to humans or the environment shall be identified, labelled, and managed to ensure safe handling and disposal following all applicable laws.
v. Restricted Substances: All applicable laws regarding the prohibition, restriction, or declaration of specific substances in products and manufacturing are to be adhered to.
vi. Waste: The generation of pollutants and waste is to be minimized or eliminated, and in any event, must be within legal limits.
vii. Air Emissions: Air emissions from operations shall be categorized, routinely monitored, controlled, and treated as required before discharge following all applicable laws.
viii. Water Management: A water management program that documents and monitors water sources, use, and discharge shall be implemented. All wastewater shall be treated as required prior to discharge.
7.3 Health and Safety
FOZ One and our Business Partners shall provide and maintain safe and hygienic working environments. Refer to Appendix 2 on Business Partner’s Health and Safety, Do & Don’t.
i. There must be policies and systems in place to detect, avoid, and respond to potential risks to the health and safety of Workers.
ii. Workers shall have access to appropriate workplace health and safety training in an appropriate language.
iii. All required health and safety permits, licenses, and consents shall be obtained, kept current, and complied with.
iv. Reasonable steps shall be taken to prepare for, prevent, and respond to the potential for an infectious disease exposure among Workers.
v. Potential emergencies shall be identified and assessed. Emergency plans and response procedures shall be developed and implemented.
7.4 Worker Accommodation
i. Any accommodation provided for Workers must be safe, clean, hygienic, and suitable for dormitory use.
ii. Accommodation must comply with all applicable laws and regulations and be fit for purpose, with access to safe drinking water and durable construction.
iii. Accommodation must have adequate fire safety and prevention measures, first aid access, and fire emergency procedures in place.
iv. Individual secure storage for Workers must be provided in the accommodation.
7.5 Responsible Sourcing of Materials
i. Components, materials, and minerals for use in FOZ One products must be sourced in an environmentally and socially responsible manner.
ii. FOZ One shall develop appropriate due diligence policies and management systems to identify relevant risks.
iii. Additional due diligence must be performed for the sourcing of High-Risk Materials and materials from Conflict-Affected and High-Risk Areas.
iv. Any applicable due diligence legislation and reporting requirements shall be complied with.
7.6 Ethical Business Practices
FOZ One is committed to operating its business with ethics, integrity, and in compliance with all applicable laws and regulations. FOZ One shall:
i. Operate with the highest standards of integrity and commit to being honest and transparent in all business dealings.
ii. Not tolerate, permit, or engage in bribery, corruption, or any illegal or unethical practices.
iii. Maintain complete and accurate records relating to its business activities.
iv. Comply with all trade and economic sanctions and embargo laws.
v. Not conduct unauthorized subcontracting to a third party.
vi. Comply with all applicable laws and FOZ One policies.
vii. Commit to protecting FOZ One’s intellectual property rights and maintaining confidentiality.
viii. Uphold standards of fair business, advertising, and competition.
ix. Commit to protecting the reasonable privacy expectations of individuals concerning their personal information.
7.7 Corrective Actions and Remediation
i. Where a non-compliance is identified, FOZ One and our Business Partners shall establish and/or participate in effective corrective action measures and remediation processes.
8.1 FOZ One and our Business Partners will integrate these standards into business operations. This EECoC shall be displayed in the language(s) of the Workers in all manufacturing facilities.
8.2 FOZ One will conduct risk assessments and assess compliance via audits. Business Partners must provide full cooperation, including access to all information and premises.
8.3 Where FOZ One and our Business Partner have entered into a legally binding Agreement, the terms of this EECoC shall apply in addition to the terms of the Agreement. Where the EECoC imposes a higher standard, it shall prevail.
8.4 Where non-compliance is identified, Business Partners shall work alongside FOZ One to implement corrective actions within agreed timeframes.
8.5 Business Partners are obliged to take a proactive approach to ensuring these standards are implemented within their supply chain.
8.6 FOZ One reserves the right to review Sustainability Practices when deciding to award future or continue existing business.
9.1 FOZ One and our Business Partners shall have programs in place to ensure that whistleblowers may raise concerns confidentially and without fear of retaliation.
9.2 Business Partners must promptly report suspected violations to the Legal Compliance and Ethics team via whistleblowingpolicy@fozgroup.com.
10.1 FOZ One shall ensure a periodic and continuous review and monitoring of the implementation of this Code of Conduct.
10.2 The internal audit department shall be responsible for a semi-annual review of social compliance and shall recommend areas of improvement.
10.3 FOZ One shall have the strategy, processes, and sufficient resources in place to meet social compliance responsibilities.
At FOZ One, we are committed to promoting a safe, healthy, and environmentally responsible work environment. We required all our business partners to adhere to the following Do’s & Don’t:
Do’s:
1.0 Do Ensure Adherence of Regulatory Compliance:
1.1 Ensure compliance with all relevant ESH regulations, including local and international laws.
1.2 Regularly verify compliance through audits and certifications (e.g., ISO 14001, ISO 45001).
2.0 Do Require Health and Safety Training:
2.1 Ensure that all workers receive proper health and safety training tailored to their roles.
2.2 Implement programs that promote safe working practices and emergency procedures.
3.0 Do Perform ESH Periodical Audits and Inspections:
3.1 Conduct frequent safety and environmental audits to identify risks.
4.0 Do Enforce the Use of PPE:
4.1 Ensure that appropriate PPE is provided to employees based on hazards.
4.2 Make it a requirement that all workers wear PPE when operating machinery.
5.0 Do Promote Good Waste Management:
5.1 Implement responsible waste disposal practices, such as recycling and minimizing hazardous waste.
5.2 Ensure that factory waste is disposed of under environmental standards.
5.3 Comply with the Environmental Quality (Scheduled waste) Regulation 2005.
6.0 Do Monitor Environmental Impact:
6.1 Track energy consumption, water usage, and emissions.
6.2 Establish clear goals to reduce the carbon footprint.
7.0 Do Ensure Hazardous Material Protocols:
7.1 Maintain clear protocols for the safe storage and disposal of hazardous materials.
7.2 Provide emergency procedures, including spill kits.
7.3 Comply with Classification, Packaging & Labeling of Hazardous Chemical Regulation 1997.
7.5 Provide a Chemical Safety Data Sheet (SDS).
8.0 Do Precautious During Repair/Maintenance:
8.1 Install fire extinguishers at job sites when performing hot work.
8.2 Do not discharge oil or polluted substances to the drain.
9.0 To Aware the Transporter Responsibilities:
9.1 Do not leave the engine running while parking in FOZ One premises.
9.2 Ensure there is no oil leakage from the vehicle.
10.0 Do Document and Communicate ESH:
10.1 Maintain up-to-date documentation on ESH policies and communicate them to workers.
Don’ts:
11.0 Don’t Tolerate Unsafe Working Conditions:
11.1 Never allow unsafe factory conditions or improperly maintained machinery.
12.0 Don’t Ignore Environmental Concerns:
12.1 Don’t overlook the environmental impact of operations.
12.2 Do not ignore sustainable practices in favour of short-term gains.
13.0 Don’t Allow Insufficient PPE:
13.1 Never allow workers to operate without proper PPE.
14.0 Don’t Overlook Emergency Preparedness:
14.1 Do not assume procedures are in place unless practiced.
14.2 Require contingency plans for chemical spills and accidents.
15.0 Don’t Fail to Address Worker Health Concerns:
15.1 Never ignore exposure to toxic chemicals or high noise levels.
16.0 Don’t Neglect Reporting:
16.1 Don’t neglect the documentation of safety and environmental incidents.
17.0 Don’t Accept Poor Maintenance:
17.1 Avoid working with partners who fail to maintain machinery.
18.0 Don’t ignore Worker Feedback:
18.1 Don’t dismiss feedback regarding safety or environmental issues.
18.2 Establish clear channels for reporting without fear of retaliation.
FOZ One has adopted the Responsible Business Alliance (RBA) Code of Conduct as its Supplier Code of Conduct. FOZ One expects all suppliers to operate in alignment with the RBA Code, which outlines standards for responsible practices in Labor, Health and Safety, Environmental Protection, and Ethics. The RBA Code of Conduct is available at www.responsiblebusiness.org/code-of-conduct/.
1. FOZ One supports the vision and mission of the RBA Code of Conduct.
2. FOZ One endorses the effort of the RBA VAP program to improve living and environmental conditions.
3. FOZ One pursues aligning RBA provisions with local laws to ensure safe working conditions.
4. FOZ One promotes the RBA Code as a requirement to suppliers.
5. FOZ One strives to conduct global business in a socially responsible manner.
6. FOZ One reinforces RBA objectives through an internal management system.
7. FOZ One is committed to auditing adherence to RBA standards.
8. Access the latest RBA code: https://www.responsiblebusiness.org/code-of-conduct/
9. Submit grievances or feedback via: https://www.responsiblebusiness.org/grievance/
