Social Compliance Vendor Code of Conduct

Social Compliance Vendor Code of Conduct

PEI Operating LLC ("PEI") believes that every person has a right to decent and humane working conditions, and that protection of our environment must be a priority in our approach towards business. Accordingly, we have established the PEI Operating LLC Vendor Code of Conduct that clearly specifies the minimum working and environmental conditions that a vendor must meet prior to conducting business with PEI Operating LLC.

General Requirements

Vendors and their contractors shall operate in full compliance with the laws, regulations or other legal requirements of their respective country, including those governing compensation, working conditions and environmental protection. In addition, vendors and their subcontractors shall comply with the PEI Vendor Code of Conduct. If the national law and the PEI Vendor Code of Conduct address the same issue, the more stringent requirement applies. Failure to take satisfactory corrective action may result in termination of the relationship between PEI and the Vendor.

Child Labor

In no case, shall vendors employ any person under 15 years of age, or the age of completion of compulsory education, or under the minimum age for employment in the country of manufacture, whichever is greater. All other laws and regulations governing working conditions for children and young employees must be applied and vendors must comply with the requirements of local law.

Forced Labor, Slavery and Human Trafficking

Vendors shall not use forced or compulsory labor of any kind in any part of the supply chain, including prison labor, bonded labor or indentured labor. PEI will not partner with any vendor who uses forced labor. Slavery and human trafficking are prohibited throughout the supply chain.

Harassment & Abuse

Vendors shall not permit any physical, sexual, psychological, or verbal harassment or abuse of employees.

Freedom of Association / Collective Bargaining

Vendors shall recognize the right of employees to associate freely and bargain collectively. This includes the right of employees to join trade unions. Vendors shall not threaten, penalize or discriminate against or otherwise interfere with employees exercising these rights.


PEI recognizes and respects cultural differences. However, PEI believes that employees should be employed and promoted on the basis of their ability to do the job rather than on the basis of their age, race, caste, national origin, gender, marital status, sexual orientation, religion, disability, union membership and political affiliation. All vendors, at a minimum, must fully comply with all local laws regarding discrimination.

Women's Rights

All vendors will ensure that female workers receive equal treatment in all aspects of employment, including remuneration, benefits, treatment, performance review and promotion opportunities as male workers.

Pregnancy tests must not be required as a condition of employment or be demanded during employment. Vendors shall not prohibit female workers from becoming pregnant nor threaten female workers with adverse employment consequences. Appropriate accommodations and services should be afforded to pregnant workers, including hours of work and protection from hazardous work that may threaten their reproductive health and safety. Maternity leave must be provided as required by local and/or national laws. Female workers must be given an equivalent position and pay when returning from maternity.

Migrant Labor

Vendors must recognize the unique legal, social, economic, and cultural situations that migrant workers face and will ensure that such workers are treated with dignity, respect and in accordance with the same standards as applied to other workers. Vendors must ensure that all workers are informed in writing of the basic terms of their employment in their local language before leaving home. Workers must not be required to pay any fees in order to secure or maintain employment. Workers must receive a timely refund of fees and costs paid to obtain or maintain their employment. Vendors must provide workers with full freedom of movement and must not retain workers personal or travel documents.

Wages and Benefits

Vendors shall pay wages equivalent to at least the legally mandated minimum wage. All other benefits required by law or regulation shall also be provided, including paid holidays, vacations, social security and medical benefits. Vendors shall not make deductions for disciplinary purposes and shall provide written information to each employee specifying the wages and benefits provided for each pay period.

Working Hours and Overtime

Vendors shall comply with applicable laws regarding normal working hours where hours are less than 48 per week. Employees shall not be required to exceed 60 hours of work per week except in extraordinary circumstances. Employees shall be provided at least one day off in seven. Overtime shall be voluntary, must be compensated at the legally mandated rate of pay and shall be clearly documented on the written pay information provided to each employee.

Health and Safety

Vendors shall provide a safe and healthy working environment, taking into consideration any particular hazards posed by the specific operations involved. Vendors shall comply as a minimum requirement with prevailing national laws and regulations on health and safety issues. Vendors shall assure that employees are adequately trained on health and safety procedures and that necessary protective clothing and equipment is provided to and used by employees. Vendors who provide residential facilities for their employees must comply with local laws and regulations relating to health, safety and security.


PEI strictly prohibits unauthorized subcontracting. Vendors shall obtain PEI’s written approval of all proposed subcontractors prior to entering into any subcontracting arrangements. Subcontractors will be required to comply with PEI’s Vendor Code of Conduct.


Vendors are required to comply with all applicable anti-corruption laws including, without limitation, the U.S. Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act. Vendors, its owners, officers, directors, employees, or agents must not engage in any corrupt or unethical practices, including bribery or fraud.


Vendors shall comply with all applicable local customs laws, and with the customs laws in the country of importation with specific regard to illegal transshipments of Goods. Vendors shall maintain and must be able to provide chain of custody documents, upon request for all stages of mining, production, or manufacture of imported merchandise and components thereof.

Conflict Minerals and the Wall Street Reform and Consumer Protection Act (Dodd-Frank Act)

Vendors shall comply with all applicable local laws, and with the laws in the country of importation with specific regard to illegal use of minerals mined from the Democratic Republic of Congo and the surrounding countries. To comply with this obligation, Vendors shall conduct due diligence, maintain records, and provide PEI with verification for the source of the materials used in related products, as well as any additional relevant information at PEI’s request.


Vendors shall comply with applicable environmental laws and regulations. Vendors shall have an appropriate management system in place to assure that manufacturing processes meet our commitment to progressive environmental practices and the preservation of natural resources. Vendors should implement systems to minimize the negative impact of their operations on the environment including waste reduction and diversion, improve energy and water efficiency, reduce emissions and hazardous materials.


Vendors shall comply with USA Security Requirements and implement and maintain procedures to guard against the introduction of non-manifest cargo into outbound shipments (i.e. explosives, firearms, drugs, bio-hazards and other contraband).