Supplier Code of Conduct

Iron 's supplier code of conduct describes our corporate responsibility requirements for its suppliers. These requirements are consistent with the core tenets of the International Labour Organization's fundamental conventions and the United Nations Universal Declaration of Human Rights.

It is Iron 's policy to conduct business in compliance with law and widely accepted norms of fairness and human decency, and we require our suppliers to act similarly. As a condition of doing business with Iron , we expect suppliers to conform to these requirements and expect their sources in the supply chain to do so as well. We will assess conformance to these requirements and will consider a supplier's progress in meeting these requirements and their ongoing performance in making sourcing decisions.

Suppliers are expected to correct non-conformance issues identified during assessments. We want to work with our suppliers to improve conditions, because the situation for workers can deteriorate if we simply terminate contracts. If a supplier refuses or is unable to correct the non-conformance to our satisfaction, we will terminate the relationship as a last resort.

Our requirements for supplier business conduct are:

1. (1) Compliance

   Suppliers will maintain compliance systems and be able to demonstrate a satisfactory record of compliance with the law in their business conduct.

2. (2) Anti-corruption

   Suppliers will conduct their businesses without engaging in corrupt practices, including public or private bribery or kickbacks. Suppliers will maintain integrity, transparency and accuracy in corporate record keeping.

3. (3) No unfair business practices

   Suppliers will act with integrity and lawfully in the proper handling of competitive data, proprietary information and other intellectual property, and comply with legal requirements regarding fair competition, antitrust, and accurate and truthful marketing.

4. (4) Anti-discrimination

   Suppliers will employ workers on the basis of their ability to do the job, rather than on the basis of their personal characteristics, conditions or beliefs.

5. (5) No harsh or inhumane treatment

   Suppliers will prohibit the physical abuse and harassment of employees, as well as the threat of either.

6. (6) Freely chosen employment

   Suppliers will not use forced, prison or indentured labor, including debt bondage. Suppliers will ensure that terms of employment are voluntary. If a supplier recruits contract or migrant workers, the supplier will pay agency recruitment fees and will ensure there are no unreasonable employment or relocation expenses. Suppliers will not require any worker to remain in employment for any period of time against his or her will, or adopt practices that restrict worker's ability to terminate employment. Workers will not be required to lodge "deposits" or hand over government-issued identification, passports or work permits as a condition of employment, unless required by law.

7. (7) No child labor

   Suppliers will ensure that their hiring practices are in conformance with International Labor Organization (ILO) Conventions for minimum age (Convention 138) and child labor (Convention 182). Suppliers are encouraged to develop lawful workplace apprenticeship programs for the educational benefit of their workers, provided that all participants meet the minimum age requirements. Workers under the age of 18 should not perform hazardous work and should be restricted from night work if it interferes with educational needs.

8. (8) Freedom of association and collective bargaining

   Suppliers will recognize the right of workers to join or to refrain from joining associations of their own choosing and the right to collective bargaining, unless otherwise prohibited by law. In all cases, worker rights to open communication, direct engagement, and humane and equitable treatment must be respected.

9. (9) Fair working hours

   While it is understood that overtime is often required, suppliers will manage operations in compliance with the law and ensure that overtime does not exceed levels that create inhumane working conditions. Suppliers will not require, on a regularly scheduled basis, work in excess of 60 hours per week or in excess of six consecutive days without a rest day.

10. (10) Wages and benefits

    Wages and benefits paid will meet, at a minimum, applicable legal requirements. In any event, wages and benefits should be enough to meet basic needs. For each pay period, the supplier will provide workers with an understandable wage statement that includes sufficient information to verify accurate compensation for work performed. Suppliers will not permit deductions from wages as a disciplinary measure.

11. (11) Safe and healthy working conditions

    Suppliers will operate a safe and healthy work environment. Suppliers that provide housing or eating facilities will operate and maintain them in a safe, sanitary and dignified manner.

12. (12) Environmental sustainability

    Environmental Management System: Suppliers of goods will have an Environmental Management System (EMS) in accordance with ISO 14001 or equivalent. The EMS must be implemented and functioning. Third-party registration is highly recommended but not required. Environmentally Preferred Products: Iron values environmentally preferred products. We work with and encourage our suppliers to create products that are energy efficient, highly recyclable and contain significant amounts of recycled materials and low amounts of hazardous materials. To enable us to evaluate supplier components and products for environmental performance, suppliers must provide material disclosures as outlined in our controlled and reportable materials disclosure process. Ozone-Depleting Substances: It is Iron’s policy to eliminate from its products any components — including components provided by our suppliers — that contain or that are manufactured with a process that uses any Class I ozone-depleting substance. As outlined in the Internal Revenue Service's Publication 510, the U.S. government imposes an environmental tax on the sale or use of ozone-depleting chemicals and imported products containing or manufactured with these chemicals. Suppliers need to provide certification that products imported into the U.S. do not contain or are not manufactured with a process that uses any Class I ozone-depleting chemicals.

13. (13) Management system

    Suppliers shall adopt or establish a management system that supports the content of this code. The management system will be designed to ensure (a) compliance with applicable laws, regulations and customer requirements related to supplier's operations and products; (b) conformance with this code; and (c) identification and mitigation of operational risks related to the areas covered by this code. The management system should also drive continual improvement.