Mitsubishi Electric Group
Supply Chain Code of Conduct

February 2024 (１ST Edition)
Mitsubishi Electric Corporation

Contents
Introduction ...................................................................................................... 1
I. Objective and Scope of this Code of Conduct ................................................ 2
II. Requests to business partners ...................................................................... 2
1. Understanding and respecting the Mitsubishi Electric Group Supply Chain Codeof Conduct
2. Initiative evaluation program for this Code of Conduct
3. Confirming agreement to this Code of Conduct

III. Contact......................................................................................................... 3
History of revisions ........................................................................................... 3

Introduction
The Mitsubishi Electric Group implements sustainability-oriented initiatives in all corporate activities in accordancewith its “Purpose,” “Our Values,” and “Commitment.” Furthermore, the company’s management policy is “TheMitsubishi Electric Group has positioned the realization of sustainability at the cornerstone of our management
based on the principle of “Provide solutions to social challenges through our businesses.” We will pursue
initiatives for achieving a sustainable society to incorporate the expectations, requests, and opinions from society
into activities, and to minimize the negative impact on society and the environment.
In addition, as globalization progress, not only companies but their supply chains are required to take social
responsibility in terms of promotion of sustainability initiatives.
In such a circumstance, the Mitsubishi Electric Group has created Mitsubishi Electric Group Supply Chain Code of
Conduct to promote its sustainability initiatives further along with our business partners. To comply withinternational standards in the sustainable initiatives, current Mitsubishi Electric Group CSR Procurement
Guidelines is repealed, and the new Code of Conduct is adopted. We would like to ask our business partners toapprove the items in this Code of Conduct and promote sustainability initiatives in a diligent manner.
1. Purpose

We, the Mitsubishi Electric Group, will contribute to the realization of a vibrant and sustainable
society through continuous technological innovation and ceaseless creativity.
2. Our Values
Trust
We develop relationships based on strong mutual trust with all stakeholders including society, customers,
shareholders, suppliers, and employees working together.
Quality
We ensure the satisfaction of society and customers by providing products and services of the best quality.
Technology
We provide society with new value by enhancing technology and onsite capabilities.
Ethics and Compliance
We act with high ethical standards and comply with laws and social norms.
Humanity
We prioritize health and safety, promote diversity, and respect personalities and human rights.
Environment
We strive to protect and improve the global environment, doing so in harmony with nature.
Society
We contribute to the development of a better society as a corporate citizen.

3. Commitment
Changes for the Better“Changes for the Better” represents the Mitsubishi Electric Group’s attitude to “always strive to achieve something
better,” as we continue to change and grow. Each one of us shares a strong will and passion to continuously aim forchange, reinforcing our commitment to creating “an even better tomorrow.”

1

I. Objective and Scope of this Code of Conduct
The Mitsubishi Electric Group aims to become a “global environmentally advanced company” that contributes tothe realization of a prosperous society that is compatible with sustainability, security, safety, and comfort, by
pursuing sustainable growth throughout the group and enhancing corporate value. In order for an organization to
fulfill its social responsibilities such as respect for human rights, consideration for safety and health, andcompliance with laws and regulations, not only in-house but also in the supply chain, appropriate measures
including promotion of “sustainability initiatives” must be addressed. The Mitsubishi Electric Group regularly
investigates and evaluates our business partners’ sustainability activity efforts and requests corrective measures
for items with a low evaluation. We would like to ask our suppliers for their support and cooperation as we aim tofurther promote our activities in partnership with our business partners.
This Code of Conduct is designed to promote and enhance our business partners’ sustainable activities, based on
the RBA Code of Conduct (Version 8.0) that was formulated and published by the RBA (Responsible Business
Alliance).
The items relating to human rights in this Code of Conduct are based on international human rights standards
including the “ILO Declaration of Basic Principles and Rights in Labor” and the “Universal Declaration of Human
Rights” which are both in accordance with the “Guidelines on Business and Human Rights Principles” and“Sustainable Development Goals (SDGs)” adopted by the United Nations. We ask our suppliers including theirbusiness partners for their understanding and support for the items in this Guideline. In accordance with the spiritof the Mitsubishi Electric Group’s “Purpose” and “Our Values,” the Mitsubishi Electric Group’s human rights policy
was established in September 2017, and our business activities shall never have any negative impact on humanrights. We will increase our sensitivity to human rights and take appropriate measures to prevent such problems.
We would like to ask our business partners to understand and approve items defined in this Code of Conduct, andto promote your sustainability activities in an aggressive manner. Please be advised that this Code of Conduct will
be reviewed and revised according to the demands of the international community and will undergo changes
according to the times.

II. Requests to business partners
1. Understanding and respecting the Mitsubishi Electric Group Supply Chain Code of
Conduct
Basic policy of the Mitsubishi Electric Group is to prioritize procurement from business partners with acomprehensively high evaluation during business partner selection and evaluation. With the progress ofglobalization, the supply chain of the Mitsubishi Electric Group has expanded to various countries and we
recognize that our supply chain may have issues concerning aspects such as labor laws and environment. In orderto promote initiatives aimed at reducing risks in these areas, we ask our business partners to understandMitsubishi Electric Group Supply Chain Code of Conduct as well as to share this information within their supply
chain.

2. Initiative evaluation program for this Code of Conduct
The Mitsubishi Electric Group has set priority issues in this Code of Conduct.
In accordance with this Code of Conduct, we request our suppliers to survey (through site surveys, review of
relevant documents, and interviews with relevant personnel) and promptly report any issues arising at theircompany and to work towards prevention and early detection/handling of compliance issues. We urge our
suppliers to thoroughly disseminate this Guideline within their company and to their suppliers and to protect
whistleblowers who report violations.

2

・ To ensure the progress for the sustainability initiatives at our business partners, we may ask you to participate
in surveys or allow us to visit you for check-up. We appreciate your corporation.

・ After we have received your answers for the survey form, we will inform you of the evaluation results for eachpriority issue. Evaluation rankings are shown in Table 1.
[Table 1] Evaluation results for sustainability initiatives
Low riskMedium risk
High risk
Very Good
Good
Needs Improvement
・ Business partners with total evaluation results of High risk will be marked as subjects for follow-up forcorrection to complete required correction within one year as a general rule. In addition, we request you totake corrective measures for items with High risks even if the total evaluation result is Medium risk or above.
The Group will take actions for correction while communicating our business partners. We will continue ourbusiness with our business partners while appropriate implementation of corrective measures is in place.
Please be advised, however, when intentional concealment and/or significant deviation from this Code of
Conduct is found, we will terminate the business trade.

3. Confirming agreement to this Code of Conduct
If our initiatives and purpose described in this Code of Conduct is approved, we would request to complete yourconsent confirmation, which will be sent to you later (As a general rule, we ask new business partners to completeit).

III. Contact
For Inquiries Concerning this Code of Conduct:
Corporate Purchasing Div., Mitsubishi Electric Corporation
E-mail： Pud.Greenprocurement@mf.MitsubishiElectric.co.jp

History of revisions
1st Edition Published in February 2024
<Revisions from First Edition>
No

Chapter

SectionPage
numberLinenumberRevisions3

Version 8.0 (2024)

RESPONSIBLE BUSINESS ALLIANCE CODE OF CONDUCTThe Responsible Business Alliance (RBA) Code of Conduct establishes standards to ensure thatworking conditions in supply chains are safe, and that business is conducted responsibly, ethically,
and with respect for human rights and the environment.
The Code may be voluntarily adopted by any business and subsequently applied by that businessto its direct and indirect supply chain and subcontractors, including providers of contract labor.
To adopt the Code and become a participant (“Participant”), a business shall declare its support for
the Code and conduct due diligence in line with the Code and its standards through the establishmentof an effective management system.
Participants must regard the Code as a total supply chain initiative. At a minimum, Participants shallalso require their next tier suppliers to acknowledge and implement the Code.
Fundamental to adopting the Code is the understanding that a business, in all of its activities, must
operate in full compliance with applicable laws, rules, and regulations 1. In alignment withinternationally recognized standards as listed under the References of this document, and drawing
upon best practices in global supply chains, elements of this Code may go beyond legal
compliance in order to advance social and environmental responsibility and business ethics. In nocase can complying with the Code violate applicable laws. If, however, there are differing standards
between the RBA Code and applicable laws, the RBA defines conformance as meeting the strictest
requirements.
The provisions of this Code are derived from and respect internationally recognized standards
including:•OECD Guidelines for Multinational Enterprises•

UN Guiding Principles on Business and Human Rights•

ILO Declaration on Fundamental Principles and Rights at Work•ILO Fundamental Conventions•

UN Universal Declaration of Human Rights

The Code is made up of five sections:•

Sections A, B, and C: Standards for Labor, Health and Safety, and the Environment,
respectively.

•

Section D: Standards relating to business ethics.

•

Section E: Elements of an acceptable system to manage conformity to this Code.

The RBA is committed to obtaining regular input from stakeholders in the continued development
and implementation of the Code of Conduct.
1

The Code is not intended to create new and additional third-party rights, including for workers.

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A.

LABOR

Participants commit to respect the human rights of workers, and to treat them with dignity. Thisapplies to direct and indirect suppliers, as well as all workers including temporary, migrant, student,
contract, direct employees, and any other type of worker.
The labor standards are as follows:1)

Prohibition of Forced Labor

2)

Young Workers

Forced labor in any form, including but not limited to, bonded (including debt bondage) or
indentured labor, involuntary or exploitative prison labor, slavery or trafficking of persons is not
permitted. This includes transporting, harboring, recruiting, transferring, or receiving persons bymeans of threat, force, coercion, abduction or fraud for labor or services. There shall be no
unreasonable restrictions on workers’ freedom of movement in the facility in addition to
unreasonable restrictions on entering or exiting company- provided facilities including, if applicable,
workers’ dormitories or living quarters. As part of the hiring process, all workers must be provided
with a written employment agreement in their native language, or in a language the worker canunderstand, that contains a description of terms and conditions of employment. Foreign migrant
workers must receive the employment agreement prior to the worker departing from his or her
country of origin and there shall be no substitution or change(s) allowed in the employment
agreement upon arrival in the receiving country unless these changes are made to meet local law
and provide equal or better terms. All work shall be voluntary, and workers shall be free to leave
work at any time or terminate their employment without penalty if reasonable notice is given, whichshall be clearly stated in workers’ contracts. Participants shall maintain documentation on all leaving
workers. Employers, agents, and sub-agents’ may not hold or otherwise destroy, conceal, or
confiscate identity or immigration documents, such as government-issued identification, passports,
or work permits. Notwithstanding the foregoing, employers can only hold documentation if
necessary to comply with the local law. In this case, at no time shall workers be denied access totheir documents. Workers shall not be required to pay employers’ agents or sub-agents’ recruitment
fees or other related fees for their employment. If any such fees are found to have been paid byworkers, such fees shall be repaid to the worker.

Child labor shall not be used in any stage of manufacturing. The term “child” refers to any person
under the age of 15, or under the age for completing compulsory education, or under the minimum
age for employment in the country, whichever is greatest. Workers under the age of 18 (Young
Workers) shall not perform work that is likely to jeopardize their health or safety, including night
shifts and overtime. Participants shall ensure proper management of student workers through proper
maintenance of student records, rigorous due diligence of educational partners, and protection of
students’ rights in accordance with applicable laws and regulations. Participants shall implement anappropriate mechanism to verify the age of workers. The use of legitimate workplace learning
programs, which comply with all laws and regulations, is supported. Participants shall provide
appropriate support and training to all student workers. In the absence of local law, the wage rate forstudent workers, interns, and apprentices shall be at least the same wage rate as other entry-level
workers performing equal or similar tasks. If child labor is identified, assistance/remediation shall be
provided.

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3)

Working Hours

4)

Wages and Benefits

5)

Non-Discrimination/Non-Harassment/Humane Treatment

6)

Freedom of Association and Collective Bargaining

Working hours shall not exceed the maximum set by local law. Further, a workweek shall not be
more than 60 hours per week, including overtime, except in emergency or unusual situations. All
overtime shall be voluntary. Workers shall be allowed at least one day off every seven days.

Compensation paid to workers shall comply with all applicable wage laws, including those relating tominimum wages, overtime hours and legally mandated benefits. All workers shall receive equal pay
for equal work and qualification. Workers shall be compensated for overtime at pay rates greaterthan regular hourly rates. Deductions from wages as a disciplinary measure shall not be permitted.
For each pay period, workers shall be provided with a timely and understandable wage statementthat includes sufficient information to verify accurate compensation for work performed. All use of
temporary, dispatch and outsourced labor shall be within the limits of the local law.

Participants shall commit to a workplace free of harassment and unlawful discrimination. There
shall be no harsh or inhumane treatment including violence, gender-based violence, sexual
harassment, sexual abuse, corporal punishment, mental or physical coercion, bullying, public
shaming, or verbal abuse of workers; nor is there to be the threat of any such treatment.
Companies shall not engage in discrimination or harassment based on race, color, age, gender,
sexual orientation, gender identity or expression, ethnicity or national origin, disability, pregnancy,
religion, political affiliation, union membership, covered veteran status, protected genetic
information or marital status in hiring and employment practices such as wages, promotions,rewards, and access to training. Disciplinary policies and procedures in support of theserequirements shall be clearly defined and communicated to workers. Workers shall be provided
with reasonable accommodation for religious practices and disability. In addition, workers or
potential workers should not be subjected to medical tests, including pregnancy or virginity tests,
or physical exams that could be used in a discriminatory way. This was drafted in consideration of
ILO Discrimination (Employment and Occupation) Convention (No.111).

Open communication and direct engagement between workers and management are the most effective
ways to resolve workplace and compensation issues. Workers and/or their representatives shall be able
to openly communicate and share ideas and concerns with management regarding working conditions
and management practices without fear of discrimination, reprisal, intimidation, or harassment. Inalignment with these principles, participants shall respect the right of all workers to form and join tradeunions of their own choosing, to bargain collectively, and to engage in peaceful assembly as well as
respect the right of workers to refrain from such activities. Where the right of freedom of association andcollective bargaining is restricted by applicable laws and regulations, workers shall be allowed to electand join alternate lawful forms of worker representations.

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B.

HEALTH AND SAFETY

Participants recognize that in addition to minimizing the incidence of work-related injuries andillnesses, a safe and healthy working environment enhances the quality of products andservices, consistency of production and worker retention and morale. Participants also
recognize that ongoing worker input and education are essential to identifying and solving
health and safety issues in the workplace.
The health and safety standards are as follows:1)

Occupational Health and Safety

2)

Emergency Preparedness

3)

Occupational Injury and Illness

4)

Industrial Hygiene

Worker potential for exposure to health and safety hazards (chemical, electrical and other energy
sources, fire, vehicles, and fall hazards, etc.) shall be identified and assessed, mitigated using the
Hierarchy of Controls. Where hazards cannot be adequately controlled by these means, workers
shall be provided with appropriate, well-maintained, personal protective equipment, andeducational materials about risks to them associated with these hazards. Gender-responsive
measures shall be taken, such as not having pregnant women and nursing mothers in working
conditions, which could be hazardous to them or their child and to provide reasonableaccommodations for nursing mothers.

Potential emergency situations and events shall be identified and assessed, and their impact
minimized by implementing emergency plans and response procedures including emergency
reporting, employee notification and evacuation procedures, worker training, and drills.
Emergency drills shall be executed at least annually or as required by local law, whichever is more
stringent. Emergency plans shall also include appropriate fire detection and suppression
equipment, clear and unobstructed egress, adequate exit facilities, contact information for
emergency responders, and recovery plans. Such plans and procedures shall focus on minimizing
harm to life, the environment, and property.

Procedures and systems shall be in place to prevent, manage, track and report occupational injuries
and illnesses, including provisions to encourage worker reporting, classify and record injury andillness cases, provide necessary medical treatment, investigate cases and implement corrective
actions to eliminate their causes, and facilitate the return of workers to work. Participants shall allow
workers to remove themselves from imminent harm, and not return until the situation is mitigated,without fear of retaliation.

Worker exposure to chemical, biological, and physical agents shall be identified, evaluated, andcontrolled according to the Hierarchy of Controls. When hazards cannot be adequately controlled,workers shall be provided with and use appropriate, well-maintained, personal protective
equipment free of charge. Participants shall provide workers with safe and healthy working
environments, which shall be maintained through ongoing, systematic monitoring of workers’
health and working environments. Participants shall provide occupational health monitoring to

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routinely evaluate if workers’ health is being harmed from occupational exposures. Protective
occupational health programs shall be ongoing and include educational materials about the risks
associated with exposure to workplace hazards.

5)

Physically Demanding Work

6)

Machine Safeguarding

7)

Sanitation, Food, and Housing

8)

Health and Safety Communication

Worker exposure to the hazards of physically demanding tasks, including manual material
handling and heavy or repetitive lifting, prolonged standing, and highly repetitive or forcefulassembly tasks shall be identified, evaluated, and controlled.

Production and other machinery shall be evaluated for safety hazards. Physical guards,
interlocks, and barriers shall be provided and properly maintained where machinery presents
an injury hazard to workers.

Workers shall be provided with ready access to clean toilet facilities, potable water and sanitary
food preparation, storage, and eating facilities. Worker dormitories provided by the Participant or alabor agent shall be maintained to be clean and safe, and provided with appropriate emergency
egress, hot water for bathing and showering, adequate lighting, and adequate conditioned
ventilation, individually secured accommodations for storing personal and valuable items, andreasonable personal space along with reasonable entry and exit privileges.

Participants shall provide workers with appropriate workplace health and safety information and training
in the language of the worker or in a language the worker can understand for all identified workplace
hazards that workers are exposed to, including but not limited to mechanical, electrical, chemical, fire,
and physical hazards. Health and safety related information shall be clearly posted in the facility orplaced in a location identifiable and accessible by workers. Health information and training shall include
content on specific risks to relevant demographics, such as gender and age, if applicable. Training shallbe provided to all workers prior to the beginning of work and regularly thereafter. Workers shall be
encouraged to raise any health and safety concerns without retaliation.

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C.

ENVIRONMENT

Across all business functions, Participants recognize that environmental responsibility is integral toproducing world-class products. Participants shall identify the environmental impacts and minimize
adverse effects on the community, environment, and natural resources, while safeguarding thehealth and safety of the public.
The environmental standards are as follows:1)

Environmental Permits and Reporting

2)

Pollution Prevention and Resource Conservation

3)

Hazardous Substances

4)

Solid Waste

5)

Air Emissions

All required environmental permits (e.g. discharge monitoring), approvals, and registrations shallbe obtained, maintained, and kept current and their operational and reporting requirements shallbe followed.

Emissions and discharges of pollutants and generation of waste shall be minimized or eliminated at
the source or by practices such as adding pollution control equipment; modifying production,
maintenance, and facility processes; or by other means. The use of natural resources, including
water, fossil fuels, minerals, and virgin forest products, shall be conserved by practices such as
modifying production, maintenance and facility processes, materials substitution, re-use,conservation, recycling, or other means.

Chemicals, waste, and other materials posing a hazard to humans or the environment shallbe identified, labeled, and managed to ensure their safe handling, movement, storage, use,
recycling or reuse, and disposal. Hazardous waste data shall be tracked and documented.

Participants shall implement a systematic approach to identify, manage, reduce, and responsibly
dispose of or recycle solid waste (non-hazardous). Waste data shall be tracked and documented.

Air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting
substances, and combustion byproducts generated from operations shall be characterized,
routinely monitored, controlled, and treated as required prior to discharge. Ozone- depleting
substances shall be effectively managed in accordance with the Montreal Protocol andapplicable regulations. Participants shall conduct routine monitoring of the performance of
its air emission control systems.

6)

Materials Restrictions

Participants shall adhere to all applicable laws, regulations, and customer requirements
regarding the prohibition or restriction of specific substances in products and manufacturing,
including labeling for recycling and disposal.

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7)Water Management

8)

Energy Consumption and Greenhouse Gas Emissions

Participants shall implement a water management program that documents, characterizes, andmonitors water sources, use and discharge; seeks opportunities to conserve water; and controls
channels of contamination. All wastewater shall be characterized, monitored, controlled, and treatedas required prior to discharge or disposal. Participants shall conduct routine monitoring of theperformance of its wastewater treatment and containment systems to ensure optimal performanceand regulatory compliance.

Participants shall establish and report against an absolute corporate-wide greenhouse gas
reduction goal. Energy consumption and all Scopes 1, 2, and significant categories of Scope 3
greenhouse gas emissions shall be tracked, documented, and publicly reported. Participants shalllook for methods to improve energy efficiency and to minimize their energy consumption andgreenhouse gas emissions.

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D.

ETHICSTo meet social responsibilities and to achieve success in the marketplace, Participants and theiragents shall uphold the highest standards of ethics including the following:

1)

Business Integrity

2)

No Improper Advantage

3)

Disclosure of Information

4)Intellectual Property

5)

Fair Business, Advertising and Competition

6)

Protection of Identity and Non-Retaliation

The highest standards of integrity shall be upheld in all business interactions. Participants shall have azero-tolerance policy to prohibit any and all forms of bribery, corruption, extortion and embezzlement.

Bribes or other means of obtaining undue or improper advantage shall not be promised, offered,authorized, given, or accepted. This prohibition covers promising, offering, authorizing, giving or
accepting anything of value, either directly or indirectly through a third party, in order to obtain or
retain business, direct business to any person, or otherwise gain an improper advantage. Monitoring,record keeping, and enforcement procedures shall be implemented to ensure compliance with anticorruption laws.

All business dealings shall be transparently performed and accurately reflected on the Participant’sbusiness books and records. Information regarding participant’s labor, health and safety,
environmental practices, business activities, structure, financial situation, and performance shall be
disclosed in accordance with applicable regulations and prevailing industry practices. Falsification ofrecords or misrepresentation of conditions or practices in the supply chain are unacceptable.

Intellectual property rights shall be respected. Transfer of technology and know-how is to be done ina manner that protects intellectual property rights, and customer and supplier information shall besafeguarded.

Standards of fair business, advertising, and competition shall be upheld.

Programs that ensure the confidentiality, anonymity, and protection of supplier and employee
whistleblowers 2 shall be maintained, unless prohibited by law. Participants shall have acommunicated process for their personnel to be able to raise any concerns without fear of
retaliation.

2

Whistleblower definition: Any person who makes a disclosure about improper conduct by an employee or officer of a company, or by a public

official or official body.

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7)

Responsible Sourcing of Minerals

8)

Privacy

Participants shall adopt a policy and exercise due diligence on the source and chain of custody ofthe tantalum, tin, tungsten, gold, and cobalt in the products they manufacture to reasonably assurethat they are sourced in a way consistent with the Organisation for Economic Co-operation andDevelopment (OECD) Guidance for Responsible Supply Chains of Minerals from Conflict- Affected
and High-Risk Areas or an equivalent and recognized due diligence framework.

Participants shall commit to protecting the reasonable privacy expectations of personal informationof everyone they do business with, including suppliers, customers, consumers, and employees.
Participants shall comply with privacy and information security laws and regulatory requirements
when personal information is collected, stored, processed, transmitted, and shared.

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E.

MANAGEMENT SYSTEMS

Participants shall adopt or establish a management system with a scope that is related to thecontent of this Code. The management system shall be designed to ensure: (a) compliance withapplicable laws, regulations and customer requirements related to the participant’s operations andproducts; (b) conformance with this Code; and (c) identification and mitigation of operational risks
related to this Code. It shall also facilitate continual improvement.
The management system shall contain the following elements:

1)

Company Commitment

2)

Management Accountability and Responsibility

3)

Legal and Customer Requirements

4)

Risk Assessment and Risk Management

5)

Improvement Objectives

Participants shall establish human rights, health and safety, environmental and ethics policy
statements affirming Participant’s commitment to due diligence and continual improvement,
endorsed by executive management. Policy statements shall be made public andcommunicated to workers in a language they understand via accessible channels..

Participants shall clearly identify senior executive and company representative(s) responsible for
ensuring implementation of the management systems and associated programs. Senior
management reviews the status of the management systems on a regular basis.

Participants shall adopt or establish a process to identify, monitor and understandapplicable laws, regulations, and customer requirements, including the requirements of thisCode.

Participants shall adopt or establish a process to identify the legal compliance, environmental,
health and safety 3, labor practice and ethics risks, including the risks of severe human rights andenvironmental impacts, associated with Participant’s operations. Participants shall determine therelative significance for each risk and implement appropriate procedural and physical controls tocontrol the identified risks and ensure regulatory compliance.

Participants shall establish written performance objectives, targets and implementation plans toimprove the Participant’s social, environmental, and health and safety performance, including aperiodic assessment of Participant’s performance in achieving those objectives.

3

Areas to be included in a risk assessment for environmental health and safety are production areas, warehouse and storage facilities,
plant/facilities support equipment, laboratories and test areas, sanitation facilities (bathrooms), kitchen/cafeteria and worker
housing/dormitories.

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6)

Training

7)

Communication

8)

Worker/Stakeholder Engagement and Access To Remedy

9)

Audits and Assessments

10)

Corrective Action Process

11)

Documentation and Records

12)

Supplier Responsibility

Participants shall establish programs for training managers and workers to implement
Participant’s policies, procedures, and improvement objectives and to meet applicable legal andregulatory requirements.

Participants shall establish process for communicating clear and accurate information about
Participant’s policies, practices, expectations, and performance to workers, suppliers, and customers.

Participants shall establish processes for ongoing two-way communication with workers, theirrepresentatives, and other stakeholders where relevant or necessary. The process shall aim to
obtain feedback on operational practices and conditions covered by this Code, and to foster
continuous improvement. Workers shall be given a safe environment to provide grievance andfeedback without fear of reprisal or retaliation.

Participants shall conduct periodic self-evaluations to ensure conformity to legal and regulatory
requirements, the content of the Code, and customer contractual requirements related to social andenvironmental responsibility.

Participants shall establish a process for timely correction of deficiencies identified by internal orexternal assessments, inspections, investigations, and reviews.

Participants shall create and maintain documents and records to ensure regulatory compliance andconformity to company requirements along with appropriate confidentiality to protect privacy.

Participants shall establish a process to communicate Code requirements to suppliers and to monitor
supplier compliance to the Code.

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REFERENCES
The following references were used in preparing this Code and may be useful sources ofadditional information. The following references may or may not be endorsed by eachParticipant:Standards and Conventions:•ILO Fundamental ConventionsoFreedom of Association and Protection of the Right to Organise
Convention, 1948 (No.87)

oRight to Organise and Collective Bargaining Convention, 1949 (No.98)

oForced Labour Convention, 1930 (No.29)

oAbolition of Forced Labour Convention, 1957 (No.105)oMinimum Age Convention, 1973 (No.138)oWorst Forms of Child Labour Convention, 1999 (No.182)

oEqual Remuneration Convention, 1999 (No.100)oDiscrimination (Employment and Occupation) Convention, 1958 (No.111)

oOccupational Safety and Health Convention, 1981 (No.155), and thePromotional Framework, 2006 (No.187)•

OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from
Conflict-Affected and High-Risk Areas•

OECD Guidelines for Multinational Enterprises•

United Nations (UN) Guiding Principles on Business and Human Rights•

Universal Declaration of Human Rights•

United Nations Convention Against Corruption•

United Nations Convention on the Rights of the Child•

United Nations Convention on the Elimination of All Forms of Discrimination Against
Women

•

United Nations Global Compact

Responsible Business Alliance Code of Conduct v8.0

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Dodd-Frank Wall Street Reform and Consumer Protection Act•

Eco Management & Audit System•

Ethical Trading Initiative•

ILO Code of Practice in Safety and Health•

ISO 14001 and related standards – Environmental management•

ISO 45001:2018 - Occupational health and safety management systems•

National Fire Protection Association•

Social Accountability International (SAI)o•

SA 8000

United States Federal Acquisition Regulation

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DOCUMENT HISTORY
Version 1.0 – Released October 2004.
Version 1.1 – Released May 2005. Converted document to RBA format, minor page layout
revisions; no content changes.
Version 2.0 – Released October 2005 with revisions to multiple provisions.
Version 3.0 – Released June 2009 with revisions to multiple provisions.
Version 4.0 – Released April 2012 with revisions to multiple provisions.
Version 5.0 – Released November 2014 with revisions to multiple provisions.
Version 5.1 – Released March 2015 with revision to A1 to take effect January 1, 2016.
Version 6.0 – Released January 2018 with revisions to multiple provisions.
Version 7.0 – Released January 2021 with revisions to multiple provisions.
Version 8.0 – Released January 2024 with revisions to multiple provisions.

The RBA Code of Conduct was initially developed by a number of companies engaged in the
manufacture of electronics products between June and October 2004. Companies are invitedand encouraged to adopt this Code. You may obtain additional information from:https://www.responsiblebusiness.org

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