code of conduct

The Beahead Code of Conduct establishes standards within the company to ensure that working conditions within our organization are safe, that workers are treated with respect and dignity, and that business operations are environmentally responsible and conducted ethically.

The Code may be applied to the company’s subcontractors, supply chain, including providers of contract labor, etc.

Fundamental to adopting the Code is the understanding that Beahead, in all of its activities, will operate in full compliance with the laws, rules and regulations of the countries in which it operates. The Code encourages Participants to go beyond legal compliance, drawing upon internationally recognized standards, in order to advance social and environmental responsibility and business ethics.

In alignment with the UN Guiding Principles on Business and Human Rights, the provisions in this Code are derived from key international human rights standards including the ILO Declaration on Fundamental Principles and Rights at Work and the UN Universal Declaration of Human Rights.

The Code is made up of five sections. Sections A, B, and C outline standards for Labor, Health and Safety, and the Environment, respectively. Section D adds standards relating to Business Ethics; Section E outlines the elements of an acceptable system to manage conformity to this Code.

1. Freely Chosen Employment: Forced, bonded (including debt bondage) or indentured labor, involuntary prison labor, slavery or trafficking of persons shall not be used. This includes transporting, harbouring, recruiting, transferring or receiving persons by means of threat, force, coercion, abduction or fraud for labor or services. There shall be no unreasonable restrictions on workers’ freedom of movement in the facility in addition to unreasonable restrictions on entering or exiting company-provided facilities. As part of the hiring process, workers must be provided with a written employment agreement in English that contains a description of terms and conditions of employment prior to the worker departing from his or her country of origin. All work must be voluntary and workers shall be free to leave work at any time or terminate their employment. Beahead and agents may not hold or otherwise destroy, conceal, confiscate or deny access by employees to employees’ identity or immigration documents, such as government-issued identification, passports or work permits, unless the holding of work permits is required by law. Workers shall not be required to pay Beahead or agents recruitment fees or other aggregate fees in excess of one month’s salary. All fees charged to workers must be disclosed and fees in excess of one month’s salary must be returned to the worker.
2. Young Workers: Child labor is not to be used in any stage of manufacturing (if any). The term “child” refers to any person under the age of 15, or under the age for completing compulsory education, or under the minimum age for employment in the country, whichever is greatest. The use of legitimate workplace learning programs, which comply with all laws and regulations, is supported. Workers under the age of 18 (Young Workers) shall not perform work that is likely to jeopardize their health or safety, including night shifts and overtime. Beahead shall ensure proper management of student workers through proper maintenance of student records, rigorous due diligence of educational partners, and protection of students’ rights in accordance with applicable law and regulations. Beahead shall provide appropriate support and training to all student workers. In the absence of local law, the wage rate for student workers, interns and apprentices shall be at least the same wage rate as other entry-level workers performing equal or similar tasks.
3. Working Hours: Studies of business practices clearly link worker strain to reduced productivity, increased turnover and increased injury and illness. Workweeks are not to exceed the maximum set by local law. Further, a workweek should not be more than 60 hours per week, including overtime, except in emergency or unusual situations. Workers shall be allowed at least one day off every seven days.
4. Wages and Benefits: Compensation paid to workers shall comply with all applicable wage laws, including those relating to minimum wages, overtime hours and legally mandated benefits. In compliance with local laws, workers shall be compensated for overtime at pay rates greater than regular hourly rates. Deductions from wages as a disciplinary measure shall not be permitted. For each pay period, workers shall be provided with a timely and understandable wage statement that includes sufficient information to verify accurate compensation for work performed. All use of temporary, dispatch and outsourced labor will be within the limits of the local law.
5. Humane Treatment: There is to be no harsh and inhumane treatment including any sexual harassment, sexual abuse, corporal punishment, mental or physical coercion or verbal abuse of workers; nor is there to be the threat of any such treatment. Disciplinary policies and procedures in support of these requirements are clearly defined and communicated to workers.
6. Non-Discrimination: Beahead is committed to a workforce free of harassment and unlawful discrimination. The company does not engage in discrimination based on race, colour, age, gender, sexual orientation, gender identity and expression, ethnicity or national origin, disability, pregnancy, religion, political affiliation, union membership, covered veteran status, protected genetic information or marital status in hiring and employment practices such as wages, promotions, rewards, and access to training. Workers shall be provided with reasonable accommodation for religious practices. In addition, workers or potential workers shall not be subjected to medical tests or physical exams that could be used in a discriminatory way.
7. Freedom of Association: In conformance with local law, Beahead shall respect the right of all workers to form and join trade unions of their own choosing, to bargain collectively and to engage in peaceful assembly as well as respect the right of workers to refrain from such activities. Workers and/or their representatives shall be able to openly communicate and share ideas and concerns with management regarding working conditions and management practices without fear of discrimination, reprisal, intimidation or harassment.

1. Occupational Safety: Worker exposure to potential safety hazards (e.g., electrical and other energy sources, fire, vehicles, and fall hazards) are controlled through proper design, engineering and administrative controls, preventative maintenance and safe work procedures (including lockout/tagout), and ongoing safety training. Where hazards cannot be adequately controlled by these means, workers are provided with appropriate, well-maintained, personal protective equipment and educational materials about risks to them associated with these hazards. Workers shall be encouraged to raise safety concerns.
2. Emergency Preparedness: Potential emergency situations and events are identified and assessed, and their impact minimized by implementing emergency plans and response procedures including: emergency reporting, employee notification and evacuation procedures, worker training and drills, appropriate fire detection and suppression equipment, adequate exit facilities and recovery plans. Such plans and procedures focus on minimizing harm to life, the environment and property.
3. Occupational Injury and Illness: Procedures and systems are put in place to prevent, manage, track and report occupational injury and illness including provisions to: encourage worker reporting; classify and record injury and illness cases; provide necessary medical treatment; investigate cases and implement corrective actions to eliminate their causes; and facilitate return of workers to work.
4. Industrial Hygiene: Worker exposure to chemical, biological and physical agents are identified, evaluated, and controlled. Engineering and administrative controls are used to control overexposures. When hazards cannot be adequately controlled by such means, worker health is protected by appropriate personal protective equipment programs.
5. Physically Demanding Work: Worker exposure to the hazards of physically demanding tasks, including manual material handling and heavy or repetitive lifting, prolonged standing and highly repetitive or forceful assembly tasks are identified, evaluated and controlled.
6. Machine Safeguarding: Production and other machinery are evaluated for safety hazards. Physical guards, interlocks and barriers are provided and properly maintained where machinery presents an injury hazard to workers.
7. Sanitation, Food, and Housing: Workers are to be provided with ready access to clean toilet facilities, potable water and sanitary food preparation, storage, and eating facilities. Worker dormitories (if any) provided by Beahead or a labor agent are to be maintained to be clean and safe, and provided with appropriate emergency egress, hot water for bathing and showering, adequate heat and ventilation, and reasonable personal space along with reasonable entry and exit privileges.
8. Health and Safety Communication: Beahead is committed to providing workers with appropriate workplace health and safety training in English. Health and safety related information are to be clearly posted in the facility.

1. Environmental Permits and Reporting: All required environmental permits (e.g. discharge monitoring), approvals and registrations are to be obtained, maintained and kept current and their operational and reporting requirements are to be followed.
2. Pollution Prevention and Resource Reduction: The use of resources and generation of waste of all types, including water and energy, are to be reduced or eliminated at the source or by practices such as modifying production, maintenance and facility processes, materials substitution, conservation, recycling and re-using materials.
3. Hazardous Substances: Chemicals and other materials posing a hazard if released to the environment are to be identified and managed to ensure their safe handling, movement, storage, use, recycling or reuse and disposal.
4. Wastewater and Solid Waste: Beahead is committed to implementing a systematic approach to identify, manage, reduce, and responsibly dispose of or recycle solid waste (non-hazardous). Wastewater generated from operations, industrial processes and sanitation facilities are to be characterized, monitored, controlled and treated as required prior to discharge or disposal. In addition, measures are to be implemented to reduce generation of wastewater. The company conducts routine monitoring of the performance of the wastewater treatment systems of facilities that the company’s employees reside in.
5. Air Emissions: Air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting chemicals and combustion by-products generated from operations are to be characterized, routinely monitored, controlled and treated as required prior to discharge. Beahead conducts routine monitoring of the performance of the air emission control systems of facilities that the company’s employees reside in.
6. Materials Restrictions: Beahead is committed to adhering to all applicable laws, regulations and customer requirements regarding prohibition or restriction of specific substances in products, including branding for recycling and disposal.
7. Storm Water Management: Beahead is committed to implementing a systematic approach to prevent contamination of storm water runoff. Beahead shall work with facilities that the company’s employees reside in to prevent illegal discharges and spills from entering storm drains.
8. Energy Consumption and Greenhouse Gas Emissions: Energy consumption and greenhouse gas emissions are to be tracked and documented, at the facility and/or corporate level. Beahead is committed to finding for cost effective methods to improve energy efficiency and to minimize energy consumption and greenhouse gas emissions.

1. Business Integrity:

   The highest standards of integrity are to be upheld in all business interactions. Beahead follows a zero tolerance policy to prohibit any and all forms of bribery, corruption, extortion and embezzlement. All business dealings shall be transparently performed and accurately reflected on Beahead’s business books and records.

   Monitoring and enforcement procedures are implemented to ensure compliance with anti-corruption laws.

2. No Improper Advantage: Bribes or other means of obtaining undue or improper advantage are not to be promised, offered, authorized, given or accepted. This prohibition covers promising, offering, authorizing, giving or accepting anything of value, either directly or indirectly through a third party, in order to obtain or retain business, direct business to any person, or otherwise gain an improper advantage.
3. Disclosure of Information: Information regarding participant labor, health and safety, environmental practices, business activities, structure, financial situation and performance is disclosed in accordance with applicable regulations and prevailing industry practices. Falsification of records or misrepresentation of conditions or practices are unacceptable to Beahead and its management.
4. Intellectual Property: Intellectual property rights are to be respected; transfer of technology and knowhow is to be done in a manner that protects intellectual property rights; and, customer information is to be safeguarded.
5. Fair Business, Advertising and Competition: Standards of fair business, advertising and competition are to be upheld. Appropriate means to safeguard customer information are to be made available.
6. Protection of Identity and Non-Retaliation: Programs that ensure the confidentiality, anonymity and protection of supplier and employee whistle-blowers are maintained by Beahead across all its offices, unless prohibited by law. The company has a communicated process for its personnel to be able to raise any concerns without fear of retaliation.
7. Privacy: Beahead is committed to protecting the reasonable privacy expectations of personal information of everyone the company does business with, including suppliers, customers, consumers and employees. The company complies with privacy and information security laws and regulatory requirements when personal information is collected, stored, processed, transmitted, and shared.

1. Company Commitment: Beahead is committed to social and environmental policy compliance and continual improvement.
2. Management Accountability and Responsibility: Beahead has clearly identified senior executive and company representative[s] responsible for ensuring implementation of the management systems and associated programs. Senior management reviews the status of the management system on a regular basis.
3. Legal and Customer Requirements: A process has been established to identify, monitor and understand applicable laws, regulations and customer requirements, including the requirements of this Code.
4. Risk Assessment and Risk Management: A process has been established to identify the legal compliance, environmental, health and safety and labor practice and ethics risks associated with Participant’s operations. Determination of the relative significance for each risk and implementation of appropriate procedural and physical controls to control the identified risks and ensure regulatory compliance.
5. Improvement Objectives: Performance objectives, targets and implementation plans to improve Beahead’s social and environmental performance, including a periodic assessment of the company’s performance in achieving those objectives.
6. Training: Programs have been formulated for training managers and workers to implement Beahead’s policies, procedures and improvement objectives and to meet applicable legal and regulatory requirements.
7. Communication: A process has been established for communicating clear and accurate information about Beahead’s policies, practices, expectations and performance to workers, suppliers and customers.
8. Worker Feedback and Participation: Ongoing processes have been put in place to assess employees’ understanding of and obtain feedback on practices and conditions covered by this Code and to foster continuous improvement.
9. Audits and Assessments: Periodic self-evaluations are conducted to ensure conformity to legal and regulatory requirements, the content of the Code and customer contractual requirements related to social and environmental responsibility.
10. Corrective Action Process: A process has been established for timely correction of deficiencies identified by internal or external assessments, inspections, investigations and reviews.
11. Documentation and Records: Documents and records are created and maintained to ensure regulatory compliance and conformity to company requirements along with appropriate confidentiality to protect privacy.
12. Supplier Responsibility: A process has been established to communicate Code requirements to suppliers and to monitor supplier compliance to the Code.