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Supplier Code Of Conduct

Corporate integrity, responsible product sourcing, and the safety and wellbeing of workers across the global supply chain are of paramount importance to D&H Distributing Co., D&H Canada ULC, and all of the related entities (hereinafter referred to as "D&H"). These principles apply to all aspects of D&H's business, and encompass all manufacturers, distributors, vendors, and other suppliers (each a "Supplier" and collectively "Suppliers") that supply the products that D&H sells.

These principles are reflected in this Supplier Code of Conduct ("Code of Conduct"), which establishes the standards that D&H expects its Suppliers to adhere to, regarding:

  • Supplier's treatment of workers;
  • workplace safety;
  • the impact of Supplier's activities on the environment; and
  • Supplier's ethical business practices.


This Code of Conduct applies to all Suppliers that provide products to D&H for resale. Supplier is responsible for compliance with the standards set out in this Code of Conduct ("Standards") throughout its operations and throughout its entire supply chain.

Without limiting Supplier's obligations hereunder, Supplier shall comply with the Standards in:

  • all of its facilities; and
  • all of its operations, including with respect to manufacturing, distribution, packaging, sales, marketing, product safety and certification, intellectual property, labor, immigration, health, worker safety, and the environment.

Without limiting Supplier's obligations hereunder, Supplier is responsible for compliance with the Standards by all of its suppliers, vendors, agents, and subcontractors and their respective facilities ("Partner(s)").

Slavery and Human Trafficking

All labor must be voluntary. Supplier shall not support or engage in slavery or human trafficking in any part of its supply chain.

Without limiting Supplier's obligations hereunder, Supplier shall not, and shall ensure that its Partners do not, support or engage in, or require any:

  • compelled, involuntary, or forced labor;
  • labor to be performed by children;
  • bonded labor; and
  • indentured labor.

Compliance and Documentation

Supplier shall:

  • Implement and maintain a reliable system to verify the eligibility of all workers, including:
    • age eligibility; and
    • legal status of foreign workers.
  • Implement and maintain a reliable recordkeeping system regarding the eligibility of all workers.

Hazardous Work

Without limiting Supplier's obligations hereunder, Supplier shall not, and shall ensure that its Partners do not, support or engage in, or require any hazardous labor to be perfomed by any person under the age of 18. Hazardous labor involves any work, that by its nature or the circumstances in which the work is undertaken, involves the substantial risk of harm to the safety or health of the worker or coworkers if adequate protections are not taken.

Identification Papers

Without limiting Supplier's obligations hereunder, Supplier shall not require any worker to surrender control over original:

  • identification papers or documents giving a foreign worker the right to work in the country;
  • identification papers or documents, such as a passport, giving a foreign worker the right to enter or leave the country; or
  • documents, such as a birth certificate, evidencing the worker's age.

Financial Obligations

Without limiting Supplier's obligations hereunder, Supplier shall not, whether or not as a condition to the right to work, require any worker (or worker's spouse or family member) to, directly or indirectly:

  • pay recruitment or other fees or other amounts (monetary or in-kind);
  • incur debt;
  • make financial guarantees; or
  • incur any other financial obligation.

Freedom of Movement

Without limiting Supplier's obligations hereunder, Supplier shall ensure that workers have the right to freedom of movement without:

  • delay or hindrance; or
  • the threat or imposition of any discipline, penalty, retaliation, or fine or other monetary obligation.

Worker freedom of movement rights include each worker's right to leave the facilities without retaliation:

  • at the end of each workday;
  • based on reasonable health and safety-related justifications; and
  • based on any reasonable circumstances, such as personal or family emergencies.

Freedom to Terminate Employment

Without limiting Supplier's obligations hereunder, Supplier shall allow workers to terminate their employment or work arrangement:

  • without restriction; and
  • without the threat or imposition of any discipline, penalty, retaliation, or fine or other monetary obligation.

Compensation and Benefits

Supplier must compensate all workers with wages, including overtime premiums, and benefits that, at a minimum, meet legally mandated wages and benefits under applicable law.

Supplier shall make wage payments on legal, regularly scheduled intervals and provide benefits on a timely basis.

Supplier's obligation to compensate and provide benefits applies to all workers at all times, including during periods of training, apprenticeship, and probation.


Supplier shall:

  • provide proof of payment to its workers showing hours worked, wage amounts and rates (regular, overtime, and bonus), and deductions;
  • ensure that proof of payment is accurate, is clearly calculated, and enables workers to quickly verify the amount of payment and method of calculation; and
  • maintain proper documentation of wage payments for their internal records.


Supplier shall not make any deductions from wages, except income tax withholding and those that are legally allowed.

Work Hours

Supplier shall:

  • comply with all applicable working hour laws and regulations, including those relating to minimum wages, regulated hours of work, daily and weekly rest periods, and annual holidays and legally mandated benefits.
  • Documentation

    Supplier shall:

    • use an industry-accepted time-keeping system to track worker work hours; and
    • develop work-hour policies to ensure compliance with this Code of Conduct and applicable law.

    No Discrimination, Abuse, OR Harassment

    Supplier shall not discriminate in hiring, compensation, training, advancement or promotion, termination, retirement, or any other employment practice based on race, color, national origin, gender, gender identity, sexual orientation, military status, religion, age, marital status, pregnancy status, disability, or any other characteristic other than the worker's ability to perform the job.

    Supplier shall treat workers with respect and dignity.

    Supplier shall not subject workers to corporal punishment, or physical, verbal, sexual, or psychological abuse or harassment. Supplier must not condone or tolerate such behavior by its Partners.

    Health and Safety

    Supplier shall provide a safe, healthy, and sanitary working environment. Supplier shall implement procedures and safeguards to prevent workplace hazards, and work-related accidents and injuries, including procedures and safeguards to prevent industry-specific workplace hazards, and work-related accidents and injuries, that are not specifically addressed in these Standards.

    General and industry-specific procedures and safeguards include those relating to:

    • health and safety inspections;
    • equipment maintenance;
    • maintenance of facilities;
    • worker training covering the hazards typically encountered in their scope of work;
    • fire prevention; and
    • documentation and recordkeeping.

    Supplier shall provide workers adequate and appropriate personal protective equipment to protect workers against hazards typically encountered in the scope of work.


    Supplier shall:

    • ensure that all facilities meet all applicable building codes and industry design and construction standards;
    • obtain and maintain all construction approvals required by law;
    • obtain and maintain all zoning and use permits required by law;
    • without limiting Supplier's obligations hereunder, ensure that all facilities have:
      • an adequate evacuation plan;
      • adequate, well-lit (including emergency lighting), clearly marked, and unobstructed emergency exit routes, including exits doors, aisles, and stairwells;
      • a sufficient number of emergency exit doors, which are located on all sides of each building, are unlocked (from the inside), and are readily opened from the occupied side and swing in the direction of emergency travel;
      • visible and accurate evacuation maps posted in the local language;
      • adequate ventilation and air circulation;
      • adequate lighting;
      • adequate first aid kits and stations;
      • adequate fire safety, prevention, alarm, and suppression systems;
      • adequate access to potable water; and
      • adequate access to private toilet facilities.
    • post safety rules, inspection results, incident reports, and permits, in each case, as required by law.

    If Supplier provides dining facilities for its workers, it shall provide safe, healthy, and sanitary facilities (including food preparation and storage areas) that comply with all the Standards set out in the Health and Safety section of this Code of Conduct. Without limiting Supplier's obligations hereunder, Supplier shall obtain and maintain all food preperation permits and health certificates if required by law.

    Intellectual Property & Confidential Information

    Supplier will respect intellectual-property rights. Supplier will transfer technology and know-how in a manner that protects intellectual property rights and conforms to the most stringent information protection requirements under the applicable agreements between D&H and Supplier.

    Supplier will use appropriate means to safeguard customer information, in accordance with the most stringent information-protection requirements under the applicable agreements between D&H and Supplier.

    Environmental Protection

    Operation of Supplier's Facilities

    • waste disposal;
    • emissions;
    • discharges; and
    • hazardous and toxic material handling.

    Inputs and Components

    Supplier must ensure that the goods that it manufactures (including the inputs and components that it incorporates into its goods) comply with all environmental laws and treaties. Supplier must ensure that it will only use packaging materials that comply with all environmental laws and treaties.

    Gifts and Entertainment

    Supplier must maintain the highest ethical standards. Supplier is discouraged from providing gifts to D&H employees, because even a well-intentioned gift might be construed as a bribe, kickback, improper inducement or any other illegal or improper payment. As a Supplier who is engaging, or contemplating engagement in business transactions with D&H, D&H strongly prefers that you refrain from offering or providing any gift, entertainment or reimbursement of expenses of more than modest value to any D&H employee. It is particularly important that any such item not exceed customary courtesies for that time and location. Moreover, Supplier will avoid providing gifts to any D&H employee when the circumstances create or appear to create a conflict of interest. For example, Supplier shall not offer anything of value during a bid process or contract negotiation.

    In addition, under no event should Supplier offer or provide, directly or indirectly, any material, equipment or services to any individual in a position to make or influence any business or governmental decision affecting D&H. Supplier must comply with the Foreign Corrupt Practices Act of 1977 (FCPA).

    Reporting Violations

    Supplier shall self-report any violations of the Code of Conduct. Supplier can also submit questions and comments regarding the Code of Conduct by electronic mail, to D&H's Legal Department at

    Supplier shall not retaliate or take disciplinary action against any worker who has, in good faith, reported violations or questionable behavior, or who has sought advice regarding this Code of Conduct.

    Compliance With Laws

    Supplier shall comply with all applicable national and local laws and regulations, including laws and regulations relating to the Standards. Where this Code of Conduct requires Supplier to meet a higher standard than set out by law or regulation, Supplier shall meet such higher standards. Supplier acknowledges that these Standards set out audit standards that D&H may use to determine whether Supplier is meeting the requirements set out in this Code of Conduct.

    Supplier acknowledges that D&H may in its discretion conduct inspections of the facilities to confirm Supplier's compliance with this Code of Conduct. D&H has no obligation to conduct inspections.


    D&H may immediately terminate its business relationship (including any purchase orders and contractual agreements) with Supplier if Supplier fails to comply with this Code of Conduct.