Vendor Code of Conduct
Version: 2.0; Status: Final; Current version effective since January 2025
Introduction
Room & Board places high importance on integrity as it develops long-standing relationships with its vendors, suppliers, distributors, and manufacturers. This Vendor Code of Conduct (the “Code”) sets out our minimum expectations with respect to compliance, safety, and quality standards. The Code also reflects our company values and demonstrates our commitment to best practices in the supply chain including corporate integrity, responsible product sourcing, and the safety and wellbeing of workers. As a retailer, we strive to meet or exceed laws, industry standards, and best practices. We purchase products from and do business with vendors who agree to meet or exceed such standards.
Laws and Regulations
Vendors must operate in full compliance with all applicable laws and regulations of the states, localities, regions, and countries in which they operate. This Code is not a restatement of applicable law or regulations, and if applicable law and/or regulation conflicts with this Code, our vendors should develop practices that provide protection to both workers and the environment and embody the same principles set forth in this Code.
Vendor Policies and Supply Chain Responsibility
Room & Board requires that its vendors work with their suppliers to ensure full compliance with all worker and environmental protection laws and regulations. All vendors must require their suppliers to provide access to accurate and detailed information pertaining to environmental, social, and governance (“ESG”) and sustainability aspects of such supplier. Additionally, Room & Board vendors are encouraged to develop a human rights policy, implement a sustainability or ESG program to measure and improve social and environmental impact, actively communicate ESG or sustainability principles to employees, contractors, consultants, suppliers, and customers, and train leaders with influence over ESG or sustainability performance to implement best practices for ESG or sustainability.
Labor and Human Rights
All labor must be voluntary. Vendors must not support or engage in slavery or human trafficking in any part of their supply chain. Room & Board’s vendors may not use the following types of labor:
- Forced or involuntary labor of any type, bonded labor, slavery, servitude, indentured labor, or trafficked labor. When employing migrant workers directly or indirectly, vendors must perform due diligence to ensure they are not using such practices. Workers must be allowed to leave work and freely terminate employment with reasonable notice. Workers must not be subject to inhumane or degrading treatment, corporal punishment, verbal abuse, or direct or indirect coercion. Disciplinary procedures must be available in writing and described verbally.
- Child labor under the age of 16, except as allowed by the laws of the country in which the labor is performed, provided those laws are in accordance with the International Labor Organization 1973 Minimum Age Convention. Vendors must deploy age verification procedures and carefully manage the dismissal of children to minimize their future risk of hazardous employment.
Vendors and their agents must practice responsible recruitment, when recruiting and hiring workers, specifically adopting the following: no recruitment fees charged to workers, plain-language contracts and employment expectations, freedom of movement, no retention of identity documents, transparency, freedom to terminate, and a defined dispute resolution process. Vendors must implement and maintain a reliable system to verify the eligibility of all workers. Room & Board also requires that its vendors implement procedures to manage the materials incorporated into their products, including all labor-related processes, to ensure compliance with laws on human trafficking and slavery.
Wages and Benefits
Room & Board believes in the right for every worker to receive just compensation for work performed, sufficient to provide a respectable living for the worker and their family. Vendors must seek employment arrangements that do not cause economic insecurity for workers. Vendors must pay workers at least the minimum compensation required by local law and provide all legally mandated benefits. Vendors must compensate workers to standards approved on the basis of collective bargaining, if applicable. Vendors shall ensure that workers of all genders and categories, such as migrant and local workers, receive the same compensation for equal jobs and skillsets. In addition to payment for regular hours of work, workers must be paid for overtime hours at such premium rate as is legally required, or, where such overtime laws do not exist, at least one and one-quarter (1.25) times the regular rate of pay. Wages are to be paid in a timely manner, on a regular basis, consistent with applicable law and in full legal tender. Wages shall reflect the skills and education of workers and shall refer to regular working hours. Vendors must provide accident insurance to their workers for work-related accidents and compensation for work-related accidents resulting in permanent disability, as required by law. Where such laws do not exist, such insurance or compensation shall be provided in a manner consistent with this Code.
Working Hours
Room & Board’s vendors will not exceed prevailing national, regional, or local work hour regulations. Workers shall not be required to work a regular schedule of more than 48 hours per week, with up to 12 hours of overtime beyond 48 hours allowed on a voluntary basis, or the maximum legally permitted number of regularly paid hours worked per week. Overtime pay shall be at least one and one-quarter (1.25) times the regular rate of pay, or at such rate as is required by applicable law, and vendors must ensure there is no increase in occupational hazards. Employees should be allowed at least one day off per seven-day week and resting breaks in every working day unless an exception defined by a collective agreement applies.
Nondiscrimination
Room & Board’s vendors must ensure employment - including hiring, compensation, benefits, advancement, termination and retirement - is based on ability and not on beliefs or any other personal characteristics such as color, race, caste, religion, age, nationality, social or ethnic origin, sexual orientation, sex or gender, gender identity or expression, HIV, marital status, pregnancy status, political affiliation, military service (veterans), union membership, disability or any other status or characteristic that is not related to the individual’s merit or the inherent requirements of the job, or is otherwise protected by applicable law. Vendors shall take adequate steps to ensure that workers do not face discrimination, harassment, or discipline based on the personal characteristics outlined above. For female employees, pregnancy tests must not be a condition of the employment. In addition, workers will not be forced to use contraception.
Freedom of Association
Room & Board’s vendors shall respect the legal rights of employees to join or to refrain from joining worker organizations, including trade unions. Vendors shall not discriminate or retaliate against employees based on their membership or lack thereof in any worker organization. Vendors must allow workers access to their representatives in the workplace. When operating in countries where trade union activity is not allowed, vendors shall allow workers to freely elect colleague representatives who can discuss workplace issues with management. As permitted by applicable law, vendors have the right to establish favorable employment conditions and to maintain effective employee communication programs as a means of promoting positive employee relations that make employees view third-party representation as unnecessary.
Health and Safety
Room & Board’s vendors will provide their employees with a safe and healthy workplace in compliance with all applicable laws and regulations. Where laws and regulations result in weak worker protection or carry weak enforcement, vendors must comply with international standards for worker protection. Consistent with these obligations, Room & Board’s vendors must develop and implement effective programs and policies that detect, assess, avoid, and respond to new or newly identified hazards in order to prevent accidents, injuries, and illnesses associated with work. General and industry-specific procedures and safeguards include those relating to: health and safety inspections; equipment maintenance; maintenance of facilities; worker training covering the hazards typically encountered in their scope of work; and documentation and recordkeeping. Vulnerable individuals such as young workers, pregnant individuals or those who have recently given birth, and persons with disabilities shall receive additional protection as appropriate and as required by law. Vendors shall provide or facilitate adequate occupational medical assistance in cases of worker injury or illness. Vendors shall ensure access to drinking water and clean eating, cooking, food storage, and break areas. Vendors must provide effective Personal Protective Equipment (PPE) to all workers at no cost. Where housing is provided to employees, vendors must provide the same standard of health and safety as the workplace.
Compliance with All Applicable Employment and Labor Laws
In addition to those laws and regulations specifically addressed in this Code, vendors agree that they are and shall continue to be in compliance with all applicable laws pertaining to labor, employment, and employment practices, including but not limited to laws governing wages and compensation; scheduling and time worked; overtime, break time/meal periods and employee classification, if applicable; labor practices and rights, labor organization and contractual obligations, if applicable; discrimination; harassment; immigration; safety obligations and workplace conditions; child labor; hiring and termination obligations; leave of absence or sick leave obligations; unemployment insurance; workers compensation; employment payroll or other taxes; employment records and retention of employment records; employee benefits, or any other law related to labor, employment or employment practices, as applicable.
Protection of the Environment and the Planet
Protection of the environment, nature, and the planet is core to Room & Board’s business practices and philosophies. Vendors must comply with all applicable environmental laws, regulations and standards, such as requirements regarding chemical and waste management and disposal, recycling, industrial wastewater treatment and discharge, air emissions controls, environmental permits and environmental reporting. Room & Board also encourages each vendor to find and implement additional improvements to reduce their carbon footprint and their overall impact on our environment and the planet. To do so, vendors should assess the environmental impact of their business practices and develop specific policies and goals to reduce or mitigate those impacts.
Ethical Business and Conflicts of Interest
Room & Board vendors must disclose any actual or potential conflict of interest and discuss it with Room & Board’s management when there is a possibility that a person or persons are in a position to derive personal benefit from actions or decisions made in their official capacity. Any activity that is approved by Room & Board, despite the actual or apparent conflict, must be documented. Vendors may not be involved in acts of corruption, embezzlement, extortion, or bribery, including giving or receiving improper monetary or other incentives. Vendors must comply with all anti-bribery laws, such as the Foreign Corrupt Practices Act (FCPA). Vendors must not falsify information or misrepresent certifications, standards, performance data, or other information that relates to compliance with this code. Vendors must use care and follow all information security laws and standards when collecting and using personal information of workers, customers, business partners, and consumers.
Communication
Room & Board vendors must prominently display, in the languages of workers and supervisors, the Room & Board Vendor Partner Code of Conduct and communicate it to workers and supervisors.
Consumer Product Compliance and Safety
Room & Board is committed to the compliance, safety, and quality of the consumer products we sell to our customers. Vendors must understand and comply with all applicable federal, state and local laws, regulations and industry standards for products they design and manufacture either directly or in partnership with Room & Board. Compliance obligations include all requirements including but not limited to design, labeling, instructions, warnings, registrations and testing associated with the specific product(s) produced. Room & Board has created a Vendor Product Compliance Manual that will be updated periodically. The Vendor Product Compliance Manual is not intended to be a comprehensive list of all regulations a vendor must consider in developing their product. Vendors must comply with the most current version of the Vendor Product Compliance Manual to be compliant with this Code.
Product Reporting and Consumer Complaints
As noted in the Vendor Product Compliance Manual, vendors must immediately notify Room & Board of any report made to a government agency regarding its products. Further, whether or not any report is made to any government agency, vendors must immediately report to Room & Board potential and confirmed product-related: safety issues; quality issues; defects; noncompliance with applicable laws or regulations and government investigations related to products.
Monitoring, Record Keeping and Compliance
Room & Board vendors must maintain documentation necessary to demonstrate compliance with this Code and must provide Room & Board with access to that documentation upon request. Room & Board reserves the right to monitor, review, and verify compliance with this Code. Room & Board reserves the right to make unannounced visits – by a Room & Board employee or by an approved third-party audit firm – to places of production of goods or materials supplied to Room & Board, including sub-suppliers in order to ensure compliance with this Code. Vendors should self-report any violations of this Code to Room & Board’s management. Vendors shall not retaliate or take disciplinary action against any worker who has, in good faith, reported violations or questionable behavior, or who has sought advice regarding this Code.