Vendor Code of Conduct
Room & Board places high importance on integrity as it develops long-standing relationships with its vendor partners. This Vendor Code of Conduct (the “Code”) reflects our company values and demonstrates our commitment to best practices in supply chain transparency. We have confidence that our vendor partners will continue to operate according to this Code of Conduct.
Laws and Regulations
Vendor partners 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 vendor partners 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 vendor partners work with their suppliers to ensure full compliance with all worker and environmental protection laws and regulations. All vendor partners 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 vendor partners 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
Room & Board’s vendor partners 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, vendor partners 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. Vendor partners must deploy age verification procedures and carefully manage the dismissal of children to minimize their future risk of hazardous employment.
Vendor partners 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.
Room & Board also requires that its vendor partners 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.
Wage 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. Vendor partners must seek employment arrangements that do not cause economic insecurity for workers. Our vendor partners must pay workers at least the minimum compensation required by local law and provide all legally mandated benefits. Vendor partners must compensate workers to standards approved on the basis of collective bargaining, if applicable. Vendor partners 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. Vendor partners 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.
Room & Board’s vendor partners 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. 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 vendor partners 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.
Room & Board’s vendor partners 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, 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. Vendor partners shall take adequate steps to ensure that workers do not face 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 vendor partners shall respect the legal rights of employees to join or to refrain from joining worker organizations, including trade unions. Vendor partners shall not discriminate against employees based on their membership or lack thereof in any worker organization. Vendor partners must allow workers access to their representatives in the workplace. When operating in countries where trade union activity is not allowed, vendor partners shall allow workers to freely elect colleague representatives who can discuss workplace issues with management. As permitted by applicable law, vendor partners 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 vendor partners 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, vendor partners must comply with international standards for worker protection. Consistent with these obligations, Room & Board’s vendor partners must develop and implement effective programs that detect, assess, avoid, and respond to new or newly identified hazards in order to prevent accidents, injuries, and illnesses associated with work. 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. Vendor partners shall provide or facilitate adequate occupational medical assistance in cases of worker injury or illness. Vendor partners shall ensure access to drinking water and clean eating, cooking, food storage, and break areas. Vendor partners must provide effective Personal Protective Equipment (PPE) to all workers at no cost. Where housing is provided to employees, vendor partners 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, Vendor Partners 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. Vendor partners 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 partner to find and implement additional improvements to reduce their carbon footprint and their overall impact on our environment and the planet. To do so, vendor partners 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 vendor partners 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.
Vendor partners may not be involved in acts of corruption, embezzlement, extortion, or bribery, including giving or receiving improper monetary or other incentives.
Vendor partners must not falsify information or misrepresent certifications, standards, performance data, or other information that relates to compliance with this code. Vendor partners must use care and follow all information security laws and standards when collecting and using personal information of workers, customers, business partners, and consumers.
Room & Board vendor partners 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.
Monitoring, Record Keeping and Compliance
Room & Board vendor partners must maintain documentation necessary to demonstrate compliance with Room & Board Vendor Partner Code of Conduct 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 Vendor Code of Conduct.
Room & Board vendor partners are expected to take necessary corrective actions to promptly remediate any noncompliance with this Vendor Partner Code of Conduct. Room & Board reserves the right to terminate its business relationship with any vendor partner who is unwilling to comply with this code.