(卡尔. 文明. 代码§1714.43)
科赫工业公司. 及其附属机构(一起), “Koch”) are committed to conducting all business lawfully and with integrity. Koch’s commitment to and expectations for ensuring that our supply chain is maintained in a lawful and socially responsible way includes, 在其他方面, that our suppliers not use 力d labor in any of its forms, 包括贩卖人口和奴役, 生产他们提供给科赫公司的产品. Koch’s compliance and ethics expectations are set out in the Koch 的行为准则, in various supplier codes of conduct or compliance standards, and in training and other communications we provide to our own personnel engaged in supply chain activities, 我们的供应商和其他第三方.
这就是这种期望的一个例子, as found in one of our affiliate’s Code of 进行供应商, 状态:
Freely Chosen Employment: Suppliers shall not use 力d, 保税, 契约劳动或非自愿的监狱劳动. 不得使用奴役或贩卖. 这包括运输, 窝藏, recruiting or transferring or receiving vulnerable persons by means of threat, 力, 强迫, abduction or fraud for the purpose of exploitation. All work will be voluntary and all workers will be free to leave upon reasonable notice.
That same Code of 进行供应商 also addresses risks associated with the use of labor brokers in certain parts of our supply chain:
Suppliers shall ensure that third party agencies providing workers to the Supplier are compliant with the provisions of the Code and the laws of the sending and receiving countries, whichever is more stringent in protecting workers.
§5.1.1. 莫仕法典 进行供应商
供应商审计
Koch does not have a Koch-wide supplier audit program; however, 我们的某些分支机构, including the 莫仕 and 佐治亚-太平洋 groups of companies, 进行供应商审核. Supplier audit practices vary within our companies – for example, those companies that conduct audits may do so either internally or via independent, 外部审计师. The scope of the supplier audits cover the company’s standards and guidelines (including those regarding 力d labor), as well as broader social responsibility and sustainability policies. In the event an audit reveals supplier non-conformance with our standards and guidelines, 视情况而定, we would either require that suppliers establish corrective action plans and report on the implementation of such plans or we would terminate the relationship with that supplier.
直接供应商认证
While many of our commercial agreements require supplier compliance with applicable laws and regulations, Koch does not have a direct supplier certification process specifically focused on human trafficking and slavery. Koch companies do require that suppliers comply with our companies’ codes of conduct, and/or third party compliance standards and sustainability guidelines for suppliers, 禁止强迫劳动.
问责标准
Non-compliance with our standards regarding human trafficking and slavery – whether by a supplier or an employee – will result in corrective action, up to and including termination of the relationship, 视情况而定. Internal auditors and business representatives would work with suppliers, employees and possibly third-party resources to resolve any instances of non-compliance. All Koch companies promote a 的行为准则 identifying numerous avenues for reporting compliance concerns, including on an anonymous basis (where allowed by law). Such concerns are objectively investigated under the guidance and direction of our compliance or legal departments. Koch prohibits retaliation against anyone who, in good faith, raises a concern.
贩卖人口培训 & 奴隶制
虽然科赫没有全面的, mandatory training program focusing on human trafficking and slavery, a number of Koch affiliates provide training to those employees who are directly responsible for human resources, procurement and supply chain management on the subjects of human trafficking and slavery, particularly with respect to mitigating risks within the supply chain. Employees receive training on company policies and procedures designed to support a supply chain free of any type of coerced labor and on the methods available for reporting concerns. Koch companies train employees on the employee 的行为准则, codes of conduct or standards directed towards suppliers, 和/或供应商可持续性指导方针, all of which address prohibition of coerced labor. The training is periodically provided through a variety of delivery methods, 包括现场课堂培训, 小型团队会议和基于计算机的培训.
验证
Other than the steps and practices described above, 科赫公司没有独立的公司, comprehensive verification process for evaluating and addressing the risks of human trafficking and slavery.
This disclosure applies to the practices of 科赫工业公司. and its affiliates (specifically including Koch 公司 Public Sector, LLC; Koch 公司 Services, LLC; 科赫公司riculture Company; Koch Remediation & 环境服务, LLC; Market Based Management, LLC; and Koch Financial Corporation), except those affiliates that have posted their own disclosure statement. This disclosure does not apply to the practices of companies for which 科赫工业公司. 可能持有少数股东的权益.