Human Rights

Forced Labor
Suppliers will not use slave, prisoner or any other form of forced or involuntary labor. Suppliers must take reasonable measures to ensure that all of their employees understand the terms of their employment.

Child Labor
Suppliers will not use child labor. UBG has a zero tolerance policy regarding the employment of children where the age of employment is not in accordance with applicable laws.

Human Trafficking
Suppliers will not engage, directly or indirectly, in human trafficking. UBG prohibits human trafficking abuses.
Conditions of Employment
Suppliers will comply with applicable laws regulating work hours, wages and benefits. Employees must be paid in a timely fashion that meets or exceeds legal minimum standards.

Labor Brokers
If necessary for a supplier to use a labor broker, the supplier will ensure the broker employs ethical recruitment practices, complies with applicable laws, and does not withhold identity documents.

Harassment & Discrimination
Suppliers will not discriminate on the basis of gender, color, race, national origin, religion, sexual orientation, age, veteran status, disability or gender identity. Harassment or discrimination of any kind will not be tolerated.

Freedom of Association and Collective Bargaining
Suppliers will comply with applicable laws that recognize and respect the rights of employees to freedom of association and collective bargaining.

Health and Safety

Workplace
Suppliers will provide clean, healthy and safe environments for their employees that meet or exceed legal standards. Suppliers will have safety procedures for their employees and tracking tools that drive to a goal of zero workplace safety incidents. Supplier employees will have the right to refuse work and report any conditions that do not meet these criteria.

Environment

Continuous Improvement
Suppliers will increase efficiency throughout their companies and take measures to reduce their carbon footprint, energy use, water use, wastes, and other emissions.

Responsible Stewardship
Suppliers will look to conserve resources and protect the communities and environment that surround them. UBG encourages its suppliers to develop and diffuse environmentally friendly technologies and to increase the use of renewable energies.

Business Integrity

Anti-Corruption/Anti-Bribery
Suppliers will not tolerate corruption, bribery, embezzlement or fraud in any form. This includes giving or receiving anything of value, including money, gifts or unlawful incentives to improperly influence negotiations or any other dealings with governments and government officials, customers, or any other third parties.

Ethical Behavior
Suppliers will avoid conflicts of interest and operate honestly and ethically throughout the supply chain and in accordance with applicable law, including those laws pertaining to: anti-competitive business practices, respect for and protection of intellectual property, company and personal data, export controls and economic sanctions.

Reporting and Non-Retaliation
Suppliers will provide an adequate mechanism for their employees to report integrity concerns, safety issues and misconduct without fear of retaliation. Suppliers will also appropriately investigate reports and take corrective action, if needed. Suppliers will prohibit retaliation.

Stakeholder Engagement
Suppliers will communicate these or substantially similar codes to their suppliers and subcontractors. Suppliers will continuously improve their sustainability and stakeholder engagement progress. UBG also encourages suppliers to work closely with local communities to implement projects and strategies that improve the community and those who live there.
Suppliers will develop and implement appropriate internal business processes and policies to ensure compliance with applicable law and this Supplier Code of Conduct. Suppliers will be able to demonstrate compliance with this Code upon our request and will take any action to correct any non-compliance.

Reporting Integrity Concerns to UBG
Subject to any restriction posed by law, suppliers will promptly inform UBG of any concern related to issues governed by this Supplier Code of Conduct. UBG policy prohibits retaliation against any person reporting such a concern. To report a concern, suppliers can always speak directly to their UBG Purchasing and Supply Chain representative. In addition, employees, contractors, suppliers and others can report directly to the Director of UBG 24 hours a day, 7 days a week by phone, web, or email. Individuals filing reports can remain anonymous, as permitted by law.