BULK BARN FOODS LIMITED
THIRD PARTY
CODE OF CONDUCT
FOR BUSINESS PARTNERS
Published: January 8, 2024
TABLE OF CONTENTS
The content of this Code will be included in contractual terms and conditions. Equivalent or similar wording may be used as long as that wording does not reduce the intention of this Code.
Article 1: Scope and Objective
1.1
Bulk Barn Foods Limited (“Bulk Barn”) is committed to carrying out its activities lawfully and ethically and seeks to form fair and ethical relationships with all of its Business Partners, including suppliers, distributors, service providers and all other third parties that Bulk Barn does business with, collectively known for the purposes of this document as “Business Partners”.
This Third Party Code of Conduct (“Code”) has been established to convey Bulk Barn’s expectations concerning the ethical conduct expected of all Business Partners and extends to the suppliers of Bulk Barn’s Business Partners across the supply chain.
1.2
This Code applies to all Bulk Barn Business Partners.
1.3
Acceptance and adherence to this Code (or provision of equivalent principles) is mandatory for all Business Partners. Bulk Barn requires its Business Partners to share Bulk Barn’s commitment to comply with the standards set out in this Code, across the supply chain, to the extent those standards are applicable to our business relationship.
1.4
Acceptance and adherence to this Code is understood to be confirmed by the Business Partner’s agreement to undertake business with Bulk Barn (unless equivalent principles have been provided).
Article 2: Compliance with Laws
2.1
Business Partners working with Bulk Barn are required to comply with all applicable laws, rules and regulations, including but not limited to anti-bribery, anti-corruption, business conduct, import and export restrictions, competition, product quality, product and food safety, occupational health and safety, privacy and data protection, labour and employment, human rights, and any other laws that are otherwise applicable to products or services provided by such Business Partners to Bulk Barn in all locations where such Business Partners conduct business operations.
Article 3: Business Partner Selection Process and Conflicts of Interest
3.1
Bulk Barn reserves the right to conduct integrity screening on Business Partners, as part of its selection process.
3.2
Business Partners are required to declare any potential conflict of interest prior to the start of the selection process.
Article 4: Anti-Bribery and Corruption, Money Laundering, Competition Law and International Trade Sanction
4.1
Business Partners shall abide by all applicable anti-corruption, money laundering, competition laws and trade sanctions.
4.2
Business Partners shall not engage in any form of bribery or corruption in order to obtain an unfair or improper advantage, whether actual or perceived.
4.3
Business Partners shall not participate in activities which could be seen as violating or impeding competition.
4.4
Business Partners shall not have dealings with restricted parties and shall comply with all applicable international trade sanction laws.
Article 5: Confidentiality/Proprietary Information
5.1
Business Partners must respect Bulk Barn’s intellectual property, trade secrets and other confidential proprietary and sensitive information and may not use or disclose any such information except in accordance with their contract with Bulk Barn, or with Bulk Barn’s prior written consent. Any information or data regarding Bulk Barn must be treated with confidentiality at all times unless that information becomes publicly available through no fault of the Business Partner. Business Partners may only disclose Bulk Barn’s confidential information within their organizations on a strict “need to know” basis, to those bound by confidentiality obligations, for the purpose intended by Bulk Barn. Business Partners may not disclose Bulk Barn’s confidential information to persons outside of their organizations. Business Partners are also prohibited from using Bulk Barn’s confidential information for their own benefit or for the benefit of any other person or entity other than Bulk Barn.
Article 6: Data Privacy
6.1
Business Partners must respect the privacy of Bulk Barn employees, customers, suppliers and other Business Partners, and must take all reasonable and appropriate steps to safeguard personal information provided pursuant to their business relationship with Bulk Barn. Bulk Barn requires Business Partners to collect, process, use, store and retain personal information obtained by Bulk Barn, or about Bulk Barn employees, customers, suppliers, and other Business Partners, only as necessary and in compliance with all applicable data privacy and protection laws.
If a Business Partner collects, processes, uses, stores or retains personal information at Bulk Barn’s request or on Bulk Barn’s behalf, such Business Partner will be required to agree to certain contractual obligations with Bulk Barn to ensure that it complies with Bulk Barn’s standards regarding the protection of such personal information.
Article 7: Expenses
7.1
Bulk Barn will not reimburse expenses incurred by a Business Partner unless expressly identified as reimbursable in a written agreement with Bulk Barn or otherwise approved by Bulk Barn in writing prior to the expense being incurred. Any expense to be reimbursed by Bulk Barn must be supported by detailed documentation including valid invoices or receipts.
Article 8: Gifts and Hospitality
8.1
Business Partners are prohibited from offering gifts above a nominal value to Bulk Barn employees or other relevant stakeholders when working on behalf of Bulk Barn. Any gifts offered must be of a purely nominal value, be permitted by law and the policies of Bulk Barn, must not be offensive, indecent, pornographic or reflect poorly or embarrass Bulk Barn or its employees, and must not be intended (or be perceived to be made) to influence a business decision. Hospitality offered must be linked to a legitimate business purpose, must be of an appropriate value, be permitted by law and the policies of Bulk Barn, must not be offensive, indecent, pornographic or reflect poorly or embarrass Bulk Barn or its employees, and must not be intended (or be perceived to be made) to influence a business decision. No gifts or hospitality may be offered during contractual negotiations.
Article 9: Human Rights and Labour Standards
9.1
Bulk Barn strongly opposes the use of illegal child labour, forced, bonded or indentured labour, human exploitation, and all other forms of unacceptable treatment of workers.
Business Partners are expected to protect and promote the human rights of their workers and those within their supply chains. Workers should not be subject to coercion, fraud, deception, workplace harassment, violence or unlawful discrimination.
Business Partners are expected to employ responsible recruitment practices that protect vulnerable and migrant workers from exploitation. This means, as a minimum, that the charging of recruitment fees to workers and/or the withholding of identification documents and work permits is strictly prohibited.
Employment of workers under the age of 16 should be prohibited, unless local laws allow for the minimum age to be 14. No workers should be subjected to working conditions that could be hazardous to their health or safety. Workers under the age of 18 should not be subjected to working conditions that compromise their education.
We expect Business Partners to be fair employers, treat their workers with dignity, respect and equality and to respect and comply with Canadian and International labour standards including, without limitation, legislation prohibiting forced labour, bonded and indentured labour, child labour, slavery and human trafficking. Business Partners are expected to have systems in place to monitor compliance with the foregoing requirements both within their own operations and within their supply chains.
Article 10: Health, Safety and The Environment
10.1
Business Partners are required to abide by all applicable laws relating to health, safety and the environment in their work for Bulk Barn. We expect Business Partners to ensure that adequate measures are put in place to protect the health and safety of their employees and the workers in their supply chains, and to mitigate the environmental impact of their business operations in so far as possible. Any person providing on-site services in a Bulk Barn facility is required to adhere to Bulk Barn’s occupational health and safety standards.
Article 11: Quality Standards
11.1
Bulk Barn will only do business with Business Partners that produce, package, store, ship or otherwise handle product in accordance with good manufacturing practices, product and food safety standards (as applicable), and distribution and professional service practices prevailing in their respective industries.
Article 12: Audit
12.1
Bulk Barn reserves the right to confirm Business Partner adherence to the principles set out in this Code through self-assessment questionnaires, on-site or desktop audits. If on-site audits are required, the Business Partner will be given sufficient notice and the audit will not unnecessarily disrupt their operations.
Article 13: Business Partner Responsibility for Compliance
13.1
Business Partners are responsible for ensuring that their employees, agents or subcontractors working on Bulk Barn business understand and comply with this Code. Failure to adhere to this Code or any applicable law is grounds for Bulk Barn to terminate the business relationship.
We consider it to be the responsibility of Bulk Barn’s Business Partners to comply with the principles articulated in this Code across their supply chains and to carry out all relevant follow-up and due diligence of their own suppliers. It is Bulk Barn’s expectation that practices adopted by Business Partners in furtherance of compliance with the Code will be verifiable and evidence or attestation of compliance will be provided to Bulk Barn upon request.
13.2
Bulk Barn expects its Business Partners to have reasonable and appropriate systems in place to investigate and remediate allegations of wrongdoing and whistleblower complaints, to the extent permitted by applicable local law. Business Partners are required to promptly notify Bulk Barn upon becoming aware of any potential violations of applicable law or this Code, or of any other allegations of wrongdoing related to Bulk Barn’s business.
13.3
Business Partners must immediately notify Bulk Barn upon becoming aware of any negative or adverse publicity concerning their business or any product or service they provide to Bulk Barn, or any event or circumstances related to such Business Partner or its business that could be reasonably expected to cause negative or adverse publicity concerning Bulk Barn.
13.4
Bulk Barn reserves the right to amend this Code at any time.
Any questions regarding this Code can be directed to vendorcompliance@bulkbarn.ca.