Supplier Codeof Conduct Guidebook
A practical guide on how to bringthe Mars Supplier Code of Conduct
to life in the workplace.

TABLE OF CONTENTS
SectionPage

INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  3
MANAGEMENT SYSTEMS. . . . . . . . . . . . . . . . . . . . . . 6
CHILD LABOR. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  13
COMPENSATION AND BENEFITS . . . . . . . . . . . . . .  17
DISCRIMINATION. . . . . . . . . . . . . . . . . . . . . . . . . . . .  21
ENVIRONMENT. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25
ETHICS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29
FORCED LABOR. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  33
FREEDOM OF ASSOCIATION. . . . . . . . . . . . . . . . . . 38
HEALTH & SAFETY . . . . . . . . . . . . . . . . . . . . . . . . . . . 42
ISSUE REPORTING . . . . . . . . . . . . . . . . . . . . . . . . . . . 46
WORK HOURS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50
ADDITIONAL RESOURCES (LINKS). . . . . . . . . . . . . 54

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Mars has been proudly family owned for over 100 years. It’s this independence that gives us thegift of freedom to think in generations, not quarters, so we can invest in the long-term future ofour business, our people and the planet — all guided by our enduring Principles.
We believe the world we want tomorrow starts with how we do business today. Our bold
ambitions must be matched with actions today from our more than 115,000 Associates in 80
countries around the world.
Our Sustainable in a Generation plan is a key way in which we are taking action. This plan sets out
our commitment as a business to grow in a sustainable way while delivering positive social andenvironmental impacts, and features ambitious goals informed by science and rooted in The Five
Principles.
Our Sustainable in a Generation Plan focuses particularly on the way in which we source our goods
and materials globally. We know that our most significant social and environmental impacts occur
in our supply chains, that’s why our first-tier suppliers around the world are important partners on
our sustainability journey.
A critical first step in this journey is ensuring our first-tier suppliers are also addressing sustainability
in their workplaces. Since 2011, we have made our social, environmental and ethical performance
expectations of our suppliers known through our Supplier Code of Conduct. In sharing our Code of
Conduct we align our suppliers with our standards and ensure that we work with partners thatshare our beliefs.
Our Supplier Code of Conduct also serves as the foundation of our Next Generation Supplier
program; a three element approach that ensures our suppliers understand and meet our code
expectations, while engaging with and supporting suppliers as they implement improvements totheir sustainable business practices and on-site working conditions.
When sharing our code we appreciate that our suppliers may need additional support andguidance; such as how to implement robust systems and processes that uphold our code
expectations, or improve existing processes to ensure they are most effective. To support withthese efforts, we have created this guidebook, which provides examples of effective management
systems that if implemented strengthen a company’s ability to operate in a sustainable way andprevent or resolve social, environmental and ethical issues at the workplace.
We hope that you find this guidebook a useful tool in understanding our code and implementing
improvements within your operations.

Thank you,
Mars Next Generation Supplier team.

Mars Supplier Code of Conduct Guidebook– 3 of 64

HOW TO USE THIS GUIDEBOOKWHAT IS THE PURPOSE
OF THIS GUIDEBOOK?

USING A MANAGEMENT SYSTEMAPPROACH TO ADDRESS COMMON RISKSThe Guide contains examples of management
systems that if applied can strengthen asuppliers ability to manage the risk of social,environmental & ethical issues occurring at theworkplace.

Each chapter contains five key sections which
list system elements and potential risk controls.
Implementing these can enable a supplier to beproactive, anticipate problems and identify andaddress the root causes of issues.

This guidebook does not constitute a new setof requirements, it is resource that suppliers
can leverage to gain a deeper understanding of
how to tackle sustainable challenges, and moreclosely align with the expectations contained
within our code.

These sections are as follows:•

Policies. Written commitment statements
for what the supplier wants to achieve.

•

Procedures. Who does what, and how, as
part of a supplier’s day-to-day operations.
The control aspect of a procedure is
specifically designed to address identified
risks.

•

Communication and Training. Individuals
with implementation roles need to be
trained on the procedures required toeffectively achieve the supplier’s policy
commitments.

•

Documentation & Records. Document
procedures that are performed
consistently, and formal records that candemonstrate compliance with both Mars
expectations and legal requirements.

•

Monitoring: Routinely observing orreviewing the effectiveness of a process orprocedure to identify actual or potential
risks to people, the environment and thebusiness.

•

Corrective Action and System Review:
Evaluating risks for root cause(s) and thentaking corrective and preventive action toaddress lower the risk and/or prevent a
recurrence.

The Guidebook is designed to serve as aresource tool for suppliers to:•

Evaluate the policies and procedures
they have in place.

•

Identify potential areas of risk.

•

Evaluate how the controls may or may
not be working and adjust them as
needed.

WHO IS THIS GUIDEBOOK FOR?
Both this guidebook and our Supplier Code of
Conduct have been created as a resource forour first-tier suppliers. This is defined as all third
parties with whom Mars has active commercial
relationships for the supply of goods or services.

HOW IS THIS GUIDEBOOK ORGANIZED?
Each chapter starts with a short introduction,
relevant definitions, and a description of thetypes of potential challenges suppliers may
encounter. The remainder of each chapter
describes various management systems andprocesses which can assist suppliers to identify
and assess the risk of issues, and help to alignwith the expectations contained in the Code of
Conduct.

Mars Supplier Code of Conduct Guidebook– 4 of 64

HOW TO USE THIS GUIDEBOOKWHAT IS THE ORIGIN OF THE EXPERTISE AND GUIDANCE CONTAINED WITHIN THISGUIDEBOOK?
This guidebook has been created with the support of our Global Strategic Human Rights partners
Verité and serves as a companion to our Supplier Code of Conduct.
Throughout the document a number of helpful definitions are provided that explain the various
terms used. Some of these definitions are universally applied and standardized, such as thedefinition for Child Labor as defined by the International Labor Organization. Where this type ofdefinition is used the relevant source is cited underneath.
Other terms which do not have a universally accepted definition have been defined by the authorsof this guidebook Verité and therefore do not include a separate citation. These definitions are
based upon Verité’s expertise and experience as a global thought leader on labor rights, in linewith their understanding of the way in which these terms are typically used, and the most effectivemeans of explaining them.

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MANAGEMENT SYSTEMSThe concept underlying a social, environmental and ethical management system is the same as anyother business management system: well-defined management processes linked together toenable an organization to implement its policies and reach its performance goals. While thecomponents of such systems can be described in different ways, probably the best and most wellknown model is “Plan-Do-Check-Act” or PDCA. This chapter describes how Mars suppliers canimplement a management system approach to achieve sustainable compliance with the
Responsible Supplier Code of Conduct, and reduce the risk of issues occurring.

MANAGEMENT SYSTEMS APPROACH:

HELPFUL DEFINITIONSThis chapter provides guidance on how todevelop and implement management
systems.

A management system is how a supplier getsthings done. It is made up of interdependent
policies, processes, and procedures organized
to enable a supplier to achieve its businessobjectives (quality products, on-time delivery,
profitability) and meet code of conduct
expectations.

Some examples of this practice include:•

Establish clear policy commitments tomeet legal and performance standardsaligned with customer Codes.

•

Understand the risks that could get in
the way of meeting these standards.

•

Establish processes and procedures toaddress the identified risks.

•

Assign responsibility for implementing
procedural and operational controls.

•

Train workers and managers on theirroles and responsibilities.

•

Routinely check to make sure thateverything is working is planned andaddress any identified problems.

•

Undertaking due diligence of suppliersof on-site services and workers toensure they follow Code and legal
requirements.

•

Perform reviews of overall systemeffectiveness.

Mars Supplier Code of Conduct Guidebook

A policy is a statement of commitment to what
the supplier believes in and how they intend
to uphold these beliefs. For example, “ourcompany will manage our workplace and supply
chain in full alignment with the UN Guiding
Principles on Business and Human Rights.”
A process is a major part of the system,
consisting of a set of actions that together
make up a business function. For example, therecruitment, selection and hiring process isdesigned to hire the right person for the job at
the right time.
Procedures are step-by-step descriptions of
how a job or task within a process is done; bywhom and when. For example, a procedure toverify the age of a job applicant is part of therecruitment process.
Finally, a risk control is an extra procedural
step or physical improvement made to reduceor eliminate the possibility of an unintended
outcome. For example, validating theauthenticity of an applicant’s proof of age
documentation controls for the risk of hiring an
underage worker.
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MANAGEMENT SYSTEMSEXAMPLES OF ISSUES SUPPLIERS
MAY ENCOUNTER
The following are examples of the types ofissues that suppliers may encounter in meeting
the Mars Code of Conduct expectations for
management systems:•

Failure to assign responsibility foroverall system effectiveness and for
implementation of specific procedures.

•

Failure to assess the performance ofvendors and service providers.

•Workers unaware of supplier policies
and or the protection afforded them byapplicable laws and regulations.

•

Actual or suspected infractions of laws
and regulations go undetected anduncorrected.

•

Appropriate actions not taken to preventthe recurrence of human rights, health &safety, environmental, or corruption andbribery issues.

•

Management is unaware of theperformance of the supplier relative tointernal standards, or customer and legal
requirements.

WHAT DOES A MANAGEMENTSYSTEM LOOK LIKE?
A well-designed management system is one
way to identify, evaluate and reduce humanrights, environmental and business ethics
risks. Whether formal or informal, a supplier’s
management system should support its
productivity and growth, ensure conformanceof its own operations and that of its suppliersand vendors to labor, environmental, health &safety and business ethics laws and customer
requirements, and is the key to a stable andsustainable workplace.

Mars Supplier Code of Conduct Guidebook

What is Supply Chain Due Diligence?
The most common way for an
organization to understand and addresshuman rights, environmental and ethics
issues in its supply chains is to undertake
supply chain due diligence. This risk
management process is designed to
identify, prevent, and mitigate adverse
human impacts and other risks in theoperations of suppliers and vendors in alltiers of the supply chain.
The process includes four key steps:
assessing actual and potential impacts;
integrating and acting on the findings;
tracking responses; and communicating
about how impacts are addressed.
For the best results, due diligenceshould be initiated as early as possible
in the development of a new business
relationship, given that risks can be mosteffectively addressed at the stage of
selecting vendors and suppliers and in
structuring contracts.
Mars encourages its first-tier suppliers
to implement this approach with their
suppliers and vendors, including those
providing on-site services and workers.

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MANAGEMENT SYSTEMS

There are many different system models inuse, but for the purposes of this guidebook
we will not prescribe a specific type, especiallyfor suppliers that have one in place already.
Instead, we will recommend a flexible Systems
Approach, using the simplicity of the mostwidely recognized system model, Plan-DoCheck-Act.

Businesses of all sizes should havea management system!
Although it need not be in written
form, its goals and procedures should
be broadly communicated to everyone
and regularly reinforced so that there isconsistency in the way things are done
- from day to day andmonth to month.

• Policy• Senior Management
System Review• System adjustments• Internal and Supply
Chain Requirements

ACT

what dowe needto change?

• Monitoring(self-audits,
supplier audits, etc.)

CHECK

are we on track?

• Worker Grievance• Corrective
and Preventive Action

Each of the following sections present the PDCA
system elements that a supplier should develop
or strengthen to reduce the risk of problems
arising. This is achieved by anticipating issues

Mars Supplier Code of Conduct Guidebook

PLAN
where arewe going?

DO• Risk Assessment• Improvement
Objectives• Procedures(controls)

how dowe get there?

 esponsibilities•R• Training & Communication(internal and supply chain)• Documentation

before they appear, as well as addressing or
eliminating issues that have arisen by tracking
them back to their root cause.

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PLAN

where are we going?

As stated in the PDCA diagram, the purposeof the “Plan” part of the cycle is to assess the
supplier’s goals in terms of human rights,
EHS and business ethics performance, and tounderstand the rules it should follow and thepotential obstacles in its path.
Policy: Policies are written commitment
statements for what the supplier wants toachieve related to labor, environment, health &safety, and business ethics.
To make sure everyone knows the goal, suppliers
should have written statements of commitment
to legal compliance and social responsibility
standards which are aligned with the Mars
Supplier Code of Conduct, and implement
continuous improvement.
This includes:

Commitment to Code and legal
compliance and continuous
improvement.

Endorsed by senior management.

Requirements: The next step in a management
system is to know what is expected. Suppliers
should track and understand applicable laws,
regulations and customer requirements, such as
the Mars Supplier Code of Conduct, and to keepthat information up to date.
Risk Assessment: Risks are conditions andpractices that can impair a supplier’s ability toachieve its policy commitments. For example,
a high rate of poverty in the community could
lead to underage job applicants. A supplierMars Supplier Code of Conduct Guidebook

EXAMPLE OF RISK AND CONTROLS
Process:
Recruitment, Selection and Hiring
Risk:
Unlawful Discrimination in hiring
Controls:
ǄǄ Non-discrimination policy
communicated to third party
recruitment agents
ǄǄ Job advertisements that list job
qualifications, not personal
characteristics, such as gender, race,
age, or sexual orientation.
ǄǄ Recruitment staff trained to use
objective interviewing techniques andobjective selection criteria.

should evaluate its operations in light of suchrisks and, at a minimum, evaluate operationsof those of its suppliers and vendors of on-site
services and workers for such risks and establish
process controls to mitigate them.
Improvement Objectives: In order to achieve
the policy commitment to continuous
improvement or to establish or improve
process controls, a supplier should establish
improvement objectives and targets, and to
track their achievement over time.

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DO

how do we get there?

This is the “how do we get there?” phase of the
management system. Working from the risk
assessment, and an understanding legal andcustomer requirements, a supplier should create
process controls and the organization structureneeded to implement them.
Procedures (Controls). Procedures describethe ‘what,’ ‘how’ and ‘who’ of how the supplierdoes things – the supplier’s business practices.
Procedural and physical controls need to be
put in place to mitigate risks and implement the
supplier’s policies. This includes:

 Creating new procedures or revisingexisting ones to prevent unintended
outcomes and Code noncompliance. For
example, a procedure to periodicallyinspect and maintain machine guarding toprevent injuries.



Installing physical controls to prevent
environmental impacts, such as secondary
containment in chemical storage areas toprevent groundwater contamination fromleaks of hazardous substances.

Responsibilities. Once a supplier has
established what it should do, it should assign
responsibility for effective implementation.
That begins with assigning a senior manager
with overall accountability for achieving the
supplier’s policy goals. Then implementationof specific system processes and procedures
can be assigned to responsible individuals,
such as implementing the timekeeping process,performing routine maintenance on air pollution
control equipment or assessing a supplier’s
performance against the Mars Supplier Code of
Conduct.
Training and Communication. Individuals with
implementation roles need to be trained toMars Supplier Code of Conduct Guidebook

What Makes a Good Procedure?
A procedure is a set of instructions to help
ensure that a given task or job is performed
consistently and according to standards.
A good procedure describes the tasks thatneed to be performed; how they are to bedone; by whom; and when or how often.
It can be a formal document or a simple listof instructions with illustrations, printed
on a card and mounted to a machine orworkstation.
know how to do their jobs effectively, and all
employees should be told who is responsible
for specific processes, so they know where to gowith their questions and concerns. They should
also receive regular communication about theirrights and responsibilities under the law.
It is important for suppliers and vendors providing
workers on-site to understand the requirementsof the Mars Code and how to implement or
improve their practices to align them with the Mars
Code. At a minimum, requirements should becommunicated in contracts, purchase requisitions
and service agreements. Compliance assistancein the form of training and consultation should be
provided as needed.
Documentation.
To make sure that procedures are performed
consistently, regardless of staff changes, it isimportant to document them, and to keepformal records of other items can help verify
procedures conform with the Mars Code andlegal requirements. This includes copies ofregulatory permits, self-inspections and audits,and other system records.
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CHECK
are we on track?

Checking is a way to make sure that processes
and procedures are on track and correct any
identified problems.
It involves using continuous monitoring (such asprocess KPIs and emissions monitoring), worker
feedback processes, incident investigations, androutine self-assessments and audit.

Worker Grievance. Obtaining and regularly
reviewing worker grievances and other feedback
is an essential tool for management to monitor
the impactof human resources processes. Every
supplier should have an easy to access, trusted,
and confidential way for employees to reportconcerns.

Monitoring means observing or reviewing the
progress or effectiveness of a process or control.
Examples include: Establishing KPIs for key processes for

Corrective and Preventive Action. Whenmonitoring identifies an actual or potential
uncontrolled risk, the supplier should evaluate
how and why it occurred, with the goal ofidentifying the root cause(s).

 Measuring training effectiveness both

The task then is to determine the appropriate
corrective and preventive actions that willaddress the immediate issue and prevent a
recurrence. Corrective and preventive actions
should be assigned to specific owners to becompleted within a designated timeframe.

which routine monitoring is essential. This
could include tracking the percentage ofcorrective actions completed on time or
the number of employees working morethan 60 hours per week.
immediately after training by testingknowledge and skills, and weeks ormonths later by assessing behavior
change.

 Utilizing continuous monitoring

equipment to monitor the level of airborne
contaminants in the workplace or thequality of discharged wastewater.

 Conducting routine self-assessment or

self-audits to examine if the management
system processes and procedures areachieving the desired results.

 Evaluating on-site labor supplier andvendor performance in meeting Mars
Code expectations.

Mars Supplier Code of Conduct Guidebook– 11 of 64

ACTwhat do we need to change?

In addition to being accountable for theachievement of the Supplier’s policy
commitments, the Supplier’s senior
management is also responsible for leading a
regular review of the management system.
This includes an evaluation of: Suitability of the current policy(ies).

Has anything changed internal orexternal to the supplier that would
require revising the policy?
 Achievement of objectives. Is the
supplier on track for, or have they
achieved their improvement objectives?
If now, why not, or if yes, should the
supplier go for further improvement?
 Status of corrective action plans. Has the
supplier and their on-site labor suppliersand vendors addressed all identified
issues? If not, does it require moreresources or other change in approach?
Are they seeing recurrences of the same
issue(s)?

 Self-assessment and audit findings.

Do the results of process and systemevaluations indicate that the supplier’s
risk controls are having an impact? If
not, where is further improvement
needed?
 Regulatory agency inspections. Do
governmental inspections validate thesupplier’s compliance efforts or are there
weaknesses the supplier should address?
 Employee engagement. Do the resultsof worker survey and interviews, anda review of grievance reports indicate
ongoing issues related to workplace
practices? If so, what should be done toaddress the issues?
Finally, the results of the Supplier’sManagement Review (minutes, action items,etc.) should serve as the basis for the next
year’s “Plan” cycle.

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Mars Supplier Code of Conduct Guidebook– 12 of 64

CHILD LABORMANAGEMENT SYSTEMS APPROACH:This chapter provides guidance on how
to develop and implement management
systems related to Child Labor.

HELPFUL DEFINITIONS
A child is an individual below the age of 18.
The minimum age for employment as definedby the International Labour Organization(ILO) is the age for completion of compulsory
schooling or 15 years, whichever is higher.
Some countries with developing economies
have specified a minimum age of 14.
Child labor is work performed by children that:• is mentally, physically, socially or morally
harmful to children, and• interferes with their schooling
A young worker is a child between theminimum age for work and age 18.
An intern is a student worker in a shortduration, structured program undergoingsupervised practical training to explore job
options and learn skills or competencies in theirfield of study.
An apprentice is a worker in a training programthat combines vocational education withwork-based learning to obtain intermediate
occupational skill or licensing.

A student worker is a worker, regardless of age,
who is enrolled in a program at an educational
institution and employed by supplier for a work
placement to support learning that is arrangedby the educational institution.
As defined by the International Labor
Organization Convention C1821, the worst formsof child labor include:• All forms of forced and bonded labor andhuman trafficking.
• Hazardous work which, by its nature, islikely to harm the health, safety or morals ofchildren.

EXAMPLES OF ISSUES SUPPLIERS MAY
ENCOUNTER•

Inadequate process for verifying the ageof job applicants.

•

Young workers are assigned to work atnight, at hazardous jobs, or overtime work.

•

Student workers are not in jobs that
support their course of study.

•

Remediation of a child found working in
the workplace includes only removal of thechild, resulting in greater risks to the child.

•Children employed by on-site services
providers.

1) https://www.ilo.org/dyn/normlex/en/f?p=NORMLEXP

Mars Supplier Code of Conduct Guidebook– 13 of 64

CHILD LABORUSE A MANAGEMENT SYSTEMS APPROACH
TO ADDRESS COMMON RISKS
Implementing the following management
system elements may enable suppliers to better
address the risk of child labor within
the workplace, and help to meet the
expectations contained in the Mars Supplier
Code of Conduct: A clear and detailed policy prohibiting
child labor.

 Procedures and accountability forestablishing and maintaining compliancewith laws and regulations related to childlabor and the young workers.

 Training for management and workers

on the child labor policy and procedures,
including verifying the age of job
applicants.

 Documentation of procedures to protect
the young workers.

 Ways to monitor that underage job

candidates are not hired and the young
workers are not assigned to dangerous
work or overtime.

 Periodic management level review of how

effectively the overall system is performing.

The following sections provide a list of systemprocesses, starting with the clear policies thatare the foundation of Planning.
(Source: Global Estimates of Child Labour, ILO 2017)

POLICIES
Supplier’s company policies may include: Only individuals above the minimum ageof employment will be hired.

Mars Supplier Code of Conduct Guidebook Compliance with applicable childlabor laws concerning wages, working
conditions, and hours of work.

 Young workers will not be assigned tonight work, overtime work, or any workthat is mentally, physically, socially or
morally dangerous.

 Working hours and job responsibilities

will not interfere with a child’s educational
requirements.

 Measures will be taken to prevent harm tochildren from activities in the workplace,
housing or transport.

 If a child is found in the workplace, thesituation will be remediated with the bestinterests of the child and his or her family
in mind.

PROCEDURES
The following procedures are examples ofpractices which would enable a supplier toimplement the policies noted above: An objective procedure to verify the ageof all job applicants.

 Procedure to objectively verify the ageof all job applicants using governmentrecognized documents wherever possible.

 Methods to verify the authenticity of
proof-of-age documentation.

 A way to classify jobs in the workplacewith health and safety hazards that are notsuitable for the young workers.

 A procedure to ensure that student

workers are only assigned to jobs that
support their course of study.

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CHILD LABOR

 Process to ensure that young workers areprovided with regular health examinations
and other legally-required protections.

 Ways to ensure that young workers

and children are protected from harm,
exploitation or abuse by worker activities
in the workplace, or in supplier-provided
housing or transport.

 Establish a process to remediate casesof children discovered working in theworkplace that provides for the welfare of
the child.

COMMUNICATION& TRAINING
To ensure that policies and procedures arefollowed, suppliers should assign responsibilities
for implementation of their policies andprocedures and train responsible staff on theirroles. Examples include: Train supervisors and managers on

the supplier’s child labor policies andprocedures, including safeguardingchildren from harm, exploitation orabuse, and what to do if they learn of anunderage worker in the workplace.

 Communicate the supplier’s child labor

policy and performance requirements toon-site contractors and service providers.

Available e-Learning Courses
on Child Labor Prevention
A variety of e-learning courses andclassroom presentation materials areavailable online for suppliers. One of
the more in-depth offerings, called“Eliminating Child Labour,” is provided by
the International Labor Organization (ILO)
and can be found at:
www.ilo.org/legacy/english/ipec/
elearning_labourinspectors_and_clmonitors/module_1/multiscreen.html

 Provide initial and periodic training

for recruitment and hiring staff on the
supplier’s policies and procedures,and legal requirements on child labor
prevention.

 Communicate the supplier’s child labor
policy to any third parties that provide
recruitment services on the supplier’s
behalf.

 Make sure that job descriptions and job

advertisements state the minimum hiringage.

 Display supplier policy and local laws

and regulations on child labor in thelanguage(s) that all workers understand.

Mars Supplier Code of Conduct Guidebook

DOCUMENTATION& RECORDS
It is recommended that key procedures are
documented whenever possible to ensure they
are followed consistently. The following are
examples: Copies of proof of age documents
provided by job applicants.

 An inventory of jobs and tasks that cannot

be assigned to the young workers because
of inherent health and safety hazards.

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CHILD LABOR A register of young workers.
 Young worker health examination records.
 Records of actions taken upon the Assess the frequency and nature of the Copies of job advertisements and Regularly review the young worker job

discovery of an underage worker.

employment contracts that specify theminimum age of hire and any restrictions
in working hours and job tasks for the
young workers.

 Records of self-assessments andother evaluations of conformanceto the supplier’s child labor policies
and procedures and compliance withapplicable legal requirements.

MONITORING
To evaluate and improve the impact of the
program, suppliers should routinely evaluate
how well their policies and procedures are being
implemented. Monitoring can take the following
forms:

 Regular verification of the validity andcompleteness of proof of age records toverify that procedures are being properly
followed or a need to make process
improvements.

 Conversations with recruitment staff

members to ensure they understand how
to verify the age of job applicants andidentify falsified documents.

young worker complaints and grievances
related to their treatment in the workplace,and company-provided accommodation
or transport.
assignments to check that restrictions on
the job type and working hours meet
supplier requirements.

 Perform random age verification checks,

as needed, to ensure the effectiveness ofrecruitment procedures.

 ORRECTIVE ACTIONC& SYSTEM REVIEWFor continuous improvement of procedures, thesupplier should undertake immediate corrective
and preventive actions, as well as periodic
system reviews. This process includes:

 Conducting root cause analysis of any
issues uncovered during monitoring.

 Setting improvement targets anddeveloping both corrective and preventive
actions (modified procedures) to addresseach identified root cause.

 Assigning task owners, milestones, andcompletion dates.

 Monitoring that changes in procedures

have been made and that they produce
the desired result.

 Conducting ongoing periodic senior

management reviews for overall systemeffectiveness.

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Mars Supplier Code of Conduct Guidebook– 16 of 64

COMPENSATION AND BENEFITSMANAGEMENT SYSTEMS APPROACH:This chapter provides guidance on how todevelop and implement management systems
related to Compensation and Benefits.

RELEVANT DEFINITIONSRegular or base wage is what is paid to workers
for their regular work hours. This rate is usuallya legal minimum wage set by the government
or an industry benchmark wage and should bespecified in the workers’ employment contracts.
Hourly rate is the amount of money paid forevery hour worked. It is the monthly wage
divided by the number of regular work hours.
Piece rate is the rate paid for a set number ofunits of work produced or harvested. Regardlessof the methods used, workers’ income should
not fall below the legal minimum wage or local
industry benchmark.
Regular work hours are hours worked during
the normal workday. Local law will usually set thelimit of regular hours between 40 and 48 per
week.
Overtime hours are those exceeding the regular
work day or work week.

•••

Disciplinary wage deductions and fines.
Information on pay slips does not match
payroll records.
Legally required allowances, bonuses orbenefits not paid.

USE A MANAGEMENT SYSTEMS APPROACH
TO ADDRESS COMMON RISKS
Implementing the following management
system elements may enable suppliers to ensure
workers are fairly compensated, and help tomeet the expectations contained in the Mars
Supplier Code of Conduct: A clear and detailed commitment topaying legal wages and benefits in the
supplier’s policy

 Procedures and accountability forestablishing and maintaining compliancewith laws and regulations related tocompensation and benefits.

 Training for management and workers

on the compensation and benefits
policy and procedures, including on theimplementation tasks associated withspecific jobs.

 Documentation of all wage and social
benefits payments.

EXAMPLES OF ISSUES SUPPLIERS MAY
ENCOUNTER:•••

Overtime is not paid at the rate specified
by applicable law.
Piece rate workers do not receive at least
minimum wage, regardless of hours
worked.
Unauthorized or illegal withholdings fromwages.

Mars Supplier Code of Conduct Guidebook

 Ways to monitor that all employees arebeing paid at least the legal minimum orindustry benchmark wage and legallymandated social benefits.

 Periodic management level review of how

effectively the overall system is performing

The following sections provide a list ofsuggested system processes, starting with
policies that are the foundation of Planning.

– 17 of 64

COMPENSATION AND BENEFITSPOLICIES
Supplier’s company policies may include: Workers are paid at least the minimum or Regular monitoring of the practices of any
third party that is responsible for paying
contract worker salaries and benefits.

 A process that limits the length of time

workers can be kept on trainee, apprenticeor probationary status before they arepromoted and paid the wages andbenefits of regular workers.

industry benchmark wage.

 Piece rate workers are paid at least thelegal minimum wage for all the hours theywork, regardless of production quotas.

 A process that ensures workers are paidon time (not more than one week after theend of the pay period) and in full.

 Work performed beyond regular hours, on
rest days and legal holidays is paid at therequired legal rate.

 Payment methods that include cash, check,or direct deposit into the worker’s bankaccount. If bank accounts are set up by thefactory for workers, only the workers may
access and control the accounts.

 Legally required overtime pay, benefits

and social insurance are included as partof workers’ total compensation package.

 Paid annual leave, sick leave, maternity

leave, legal holidays and any other legallyrequired leave is provided.

 Methods to ensure that regular andprobationary workers receive the same
compensation and benefits, whererequired by law.

 Workers are paid on time and in full eachpay period.

 Wage deductions for disciplinary reasons

are not allowed, including production
errors, not following work procedures, orloss or damage of materials or equipment.

PROCEDURES
The following procedures are examples ofpractices which if implemented may enable a
supplier to deploy the policies noted above A payroll system that is both accurate and Methods to ensure workers receive legallyrequired social security, insurance ormedical benefits.

A clearly defined and communicated formula forwage calculation for all types of work, including:•••

Overtime wages for extra hours worked on
regular work days.
Special overtime wages (higher premium)for work on a rest day, vacation day or legal
holiday.
Piece work rates, including how production
quotas were determined.

transparent.

 Methods to ensure that hourly and piece

rate workers’ employment agreements
clearly state the wage rates they will earn forregular and overtime work, the pay period
and frequency of payments, and any legallyrequired benefits and deductions.

 A way to make sure all workers receive

understandable pay slips that detail hours
worked, regular and overtime wages,
benefits, and deductions.

Mars Supplier Code of Conduct Guidebook

Suggested Practice
The pay slip provides the worker with arecord and “receipt” of payment for work
performed over a specified period.
It should specify the hours worked, basewage rate, overtime hours and overtime
premium rate, and piece rate, if applicable.

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COMPENSATION AND BENEFITSCOMMUNICATION& TRAININGDOCUMENTATION& RECORDS

To ensure that policies and procedures arefollowed, suppliers are encouraged to assign
responsibilities for implementation and train
responsible staff on their roles. Examples ofsuch practices include:

It is recommended that procedures are
documented whenever possible to ensure they
are followed consistently. The following are
examples of such practice: Provide initial and periodic training forcomputer-generated) based on an
accurate electronic recording of hours
worked for all workers.

managers and supervisors and newly
hired workers on the supplier’s policies
and procedures, and legal requirements
on wages and benefits.

 Train workers on how their wages arecalculated, including wage rates, benefits
and legally-required deductions.

 Payroll and time records (preferably Pay slips showing timely wage payment
provided to workers in their native
language that contain at least thefollowing details:

 Communicate the pay and benefits□ Pay period

 Display supplier policy and local laws and□ Regular hours

structure to all workers before they begin
work and whenever changes are made.
regulations on wages and benefits in thelanguage(s) that all workers understand.

 Communicate Code expectations

for compensation and benefits to allproviders of contract labor and on-site
services contractors.

worked□ Overtime

hours worked□ Regular wages□ Overtime
wages

Suggested PracticeTrain supervisors and HR staff tounderstand pay equals time worked. Thismeans any supplier-required activity, suchas briefings, daily meetings, trainings, orwork team meetings, should be paid equal
to the time of the mandatory attended
activity. And if the activity occurs outside
regular working hours, that it is paid at theovertime rate.

□ Benefits(for example:
accrued leave time,sick time used, etc.)□ Bonuses□ Gross earnings□ Deductions(for example: social
insurance and otheragreed amounts)□ Net wages

 Copies of receipts from government

agencies and others that verify payment
for social insurance and other worker
benefits.

 Copies of worker offers of employment andemployment contracts that specify the basewage and overtime rates, regular work
hours, and the schedule of wage payments.

 Record of all changes in employment status
and corresponding changes in wages andbenefits in workers’ individual files.

Mars Supplier Code of Conduct Guidebook– 19 of 64

COMPENSATION AND BENEFITS

Suggested PracticeAn electronic timekeeping and payroll
system that automatically calculates wages
based on hours worked is preferred overmanual or handwritten systems for thefollowing reasons:••••Accuracy
Objectivity
Consistency across departments orwork units
Ability for workers to verify theirhours worked and wages

MONITORING
To evaluate and improve the impact of the
program, it is recommended that suppliers
routinely evaluate how well their policies andprocedures are being implemented. Monitoring
can take the following forms:

 Routine evaluation of the accuracy andcompleteness of time records and wage
calculations, paying particular attention to: Interview workers who leave the supplier

to determine if their departure is linked
to dissatisfaction with compensation andbenefits.

 Survey workers on a regular basis to

identify and address issues related todissatisfaction with the calculation or
payment of compensation and benefits,
including pregnancy, maternity andlactation benefits.

 Regularly evaluate the performance of labor

contractors and on-site services providers toensure they are meeting Mars expectations
for compensation and benefits.

 ORRECTIVE ACTIONC& SYSTEM REVIEWFor continuous improvement of procedures,
suppliers are encouraged to undertake
immediate corrective and preventive actions,as well as periodic system reviews. This processincludes: Conducting root cause analysis of any
issues uncovered during monitoring.

 Errors in documentation, record keeping, Setting improvement targets and Inadequate knowledge of payroll and Assigning task owners, milestones, andor calculation on the part of the payroll
clerk or payroll department staff.
benefits staff members regarding
policies and procedures, including
how to calculate and record worker
compensation.

 Assess the frequency and nature of worker
complaints and grievances related toerrors in the calculation or payment of
their wages and benefits.

developing both corrective and preventive
actions (modified procedures) to addresseach identified root cause.
completion dates.

 Monitoring that changes in procedures

have been made and that they produce
the desired result.

 Conducting ongoing periodic management
reviews for overall system impact.

Click here for additional resourses
Mars Supplier Code of Conduct Guidebook– 20 of 64

DISCRIMINATIONMANAGEMENT SYSTEMS APPROACH:•This chapter provides guidance on how todevelop and implement management systems
related to Discrimination.

•

DEFINITIONS
Discrimination2 is defined by ILO Convention 111
as making a distinction, exclusion or preference
based on race, color, sex, religion, sexual
orientation, political opinion, national extraction
or social origin (among other characteristics)
with the effect of nullifying equality ofopportunity and treatment in employment.
Discrimination can be deeply rooted and canlead to an underclass of workers who lack
opportunities to develop and improve.
Harassment is defined in the ILO Convention
190 (June 2019) as "a range of unacceptablebehaviours and practices, or threats thereof,
whether a single occurrence or repeated, that
aim at, result in, or are likely to result in physical,
psychological, sexual or economic harm, andincludes gender-based violence andharassment”. This potentially covers physicalabuse, verbal abuse, bullying and mobbing,sexual harassment, threats and stalking, among
other things.
Harassment may be accompanied by inhumane
treatment, such as verbal and physical abuse.

EXAMPLES OF ISSUES SUPPLIERS MAY
ENCOUNTER:•

Job applicants are denied employment
because of personal characteristics or
beliefs.

2) h ttps://www.ilo.org/dyn/normlex/en/f?p=NORMLEXPUB:
12100:0::NO::P12100_ILO_CODE:C111

Mars Supplier Code of Conduct Guidebook••

Medical testing and examinations areadministered that do not evaluate anindividual’s ability to perform the job.
Certain workers have limited
opportunities for bonuses, overtime,
promotion or for job skills training basedon sex, age, etc.
Union representatives and members aretreated differently than other workers.
Female employees are threatened withdismissal, loss of seniority or deduction ofwages should they become pregnant.

USE A MANAGEMENT SYSTEMSAPPROACH TO ADDRESS COMMON RISKS
Implementing the following management systemelements may enable suppliers to better address
the risk of discrimination within the workplace,and help to meet the expectations contained in
the Mars Supplier Code of Conduct: A clear and detailed policy prohibiting
discrimination and harassment.

 Procedures and accountability forestablishing and maintaining compliancewith nondiscrimination laws andregulations.

 Training for management and workers on

the discrimination policy and procedures,
including imposing discipline fairly andhumanely.

 Documentation of objective job

requirements and progressive disciplinary
procedures.

 Ways to monitor that discrimination

prevention controls are working properly
and are effective in ensuring an equal
opportunity and harassment-freeworkplace.
– 21 of 64

DISCRIMINATION Periodic senior level review of how
effectively the overall system isperforming.

The following sections provide a list of systemprocesses, starting with the clear policies thatare the foundation of Planning.

POLICIES
Supplier’s company policies may include: Recruitment, selection and hiring will besolely based on the candidate’s ability toperform the job.

 Discrimination in compensation and benefits,
job advancement, training and other areas of
employment is strictly prohibited.

 Recruitment, selection and hiring
procedures that ensure:•

Job advertisements state only
objective job requirements, suchas knowledge, skills, years ofexperience, etc.
• Interviewers use objective interviewing
techniques and do not ask questions
about personal characteristics.
• No medical examinations or testing
unless part of an objective job
requirement (e.g. “ability to lift xx
pounds unassisted”) or where legallyrequired.
 Third parties who perform recruitment onbehalf of the supplier follow nondiscriminatory practices.

 Harassment, intimidation, verbal and A process for wage increases, promotions

 Discipline will be applied fairly to all Disciplinary procedures that: Prohibit inhumane practices such as verbal

physical abuse, and other inhumane
treatment is strictly forbidden.

employees, using a system of progressive
discipline.

Workers will be provided with reasonableaccommodation for religious practices.
••

Train the interviewers. More than one
interviewer is preferred, particularly ifthey have different backgrounds, as partof a checks and balances system during
the interview process
Use interview evaluation forms to record
notes and evaluation of candidates’
suitability based on agreed criteria

PROCEDURES
The following procedures are examples ofpractices which if implemented would assist a
supplier to deploy the policies noted above:

Mars Supplier Code of Conduct Guidebook

and bonuses on clearly defined objective
job performance criteria.

and physical abuse,•

Follow a process of progressive
discipline.
• Are applied equally and fairly to all
employees.
 A way for workers to contest a disciplinary
action.

 A way to take disciplinary action against

persons who harass or abuse others in theworkplace.

Suggested Practice
Implement procedures that require
supervisors and managers to takedisciplinary action against an employee inprivate and in such a way to preserve his/her dignity.

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DISCRIMINATIONCOMMUNICATION& TRAINING
To ensure that policies and procedures arefollowed, it is recommended that suppliers
assign responsibilities for implementation andtrain responsible staff on their roles. Examples ofsuch practices include: Providing initial and periodic training forrecruitment and hiring staff and thosethat manage recruitment agents on the
supplier’s policies and procedures, andlegal requirements on anti-discrimination.

 Newly hired workers should receive athorough orientation training related tos
the supplier’s policies on discriminationand harassment, disciplinary procedures,
how to file a complaint about
discriminatory practices or incidents ofharassment or abuse, and their legal rights
and responsibilities.

 In-depth training for managers andsupervisors on preventing discrimination in
the workplace, implementing the supplier’s
disciplinary procedures, and supervisory
skills to prevent harassment and abuse.

 Communicating the supplier’s policies on

discrimination, harassment and inhumane
treatment to any third parties that provide
recruitment services on the supplier’s behalf.

Displaying supplier policy and local laws andregulations on discrimination and harassment in
the language(s) that all workers understand.

Suggested PracticeEnsuring that managers understand andconsistently enforce the supplier’s antidiscrimination rules and policies will allow
managers to quickly identify and resolve
potential problems early, before they rise to
the level of discrimination.
•

Explain that discrimination based on
race, color, religion, sex (including
pregnancy, sexual orientation, or
gender identity), national origin,disability, age or genetic information(including family medical history) is
prohibited and will not be tolerated.
Provide examples or case studies ofprohibited conduct, as needed.

 Documentation of job candidate
interviews and hiring decisions.

 Performance evaluations, and documented
reasons for transfers, promotions, wage
increases, and terminations.

 Worker grievance reports related todiscrimination and harassment, including
how they were investigated and resolved.

 Job advertisements showing that only

objective job performance requirements
are listed.

 Records of medical examinations andtesting and the corresponding job and/or
legal requirement.

 Facility rules, disciplinary procedures, andrecords of disciplinary actions taken.

DOCUMENTATION& RECORDS
It is recommended that key procedures are
documented whenever possible to ensure they
are followed consistently. The following are
examples of such practice:Mars Supplier Code of Conduct Guidebook

 Records of disciplinary actions taken andany worker appeals.

 Records of self-assessments and otherevaluations of conformance to the
supplier’s discrimination and harassment
policies and procedures and compliancewith applicable legal requirements.
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DISCRIMINATIONMONITORING
To evaluate and improve the effectiveness of the
supplier’s program, suppliers should routinely
evaluate how well their policies and proceduresare being implemented. Monitoring can take thefollowing forms:

 Perform periodic interviews or surveys
of workers to obtain their feedback on
discrimination and harassment in theworkplace.

 Regularly review and revise anti-

discrimination and harassment policies
and procedures to ensure they are relevant
and up to date.

 Establish and track simple KPIs to measureprogram effectiveness on an ongoingbasis, such as the percentage of workers
surveyed who fell the supplier maintains
an inclusive and harassment-free work
environment; percentage of disciplinary
actions appealed by employees;
comparison of workforce demographics tolocal community demographics, etc.

 Review disciplinary records to determine if
disciplinary actions were applied fairly andin keeping with the supplier’s policy andprocedures.

 Conversations with recruitment staff

members to ensure they understandand effectively implement the supplier’s
discrimination prevention requirements.

 Interviews with newly hired workers todetermine if they were asked questions in
job interviews that were not related to job
skills and qualifications (e.g. plans to havea family).

 Assess the frequency and nature of worker
complaints and grievances related to how
they are treated by their supervisors.

 ORRECTIVE ACTIONC& SYSTEM REVIEWFor continuous improvement of procedures, thesupplier should undertake immediate corrective
and preventive actions, as well as periodic
system reviews. This process includes:

 Conducting root cause analysis of any
issues uncovered during monitoring.

 Setting improvement targets anddeveloping both corrective and preventive
actions (modified procedures) to addresseach identified root cause.

 Assigning task owners, milestones, andcompletion dates.

 Monitoring that changes in procedures

have been made and that they produce
the desired result.

 Conducting ongoing periodic senior

management review for overall systemeffectiveness.

 Perform a regular review of worker

performance evaluations to determine if
the supplier’s process for measuring job
performance based on objective standards
is being properly followed.

Click here for additional resourses
Mars Supplier Code of Conduct Guidebook– 24 of 64

ENVIRONMENTMANAGEMENT SYSTEMS APPROACH:This chapter provides guidance on how todevelop and implement management systems
that mitigate a suppliers impact on theEnvironment.

Natural Resources are materials or substancessuch as water, natural gas, and minerals that
occur in nature and have an economic value.

Suggested PracticeLand rights refer to the inalienable ability of
individuals and companies to freely obtain, use,and possess land at their discretion, as long as
their activities on the land do not impede on therights of others.

Environmental compliance programs
will help to achieve emission reductions,
reduced waste handling costs and improved
worker health and safety.

EXAMPLES OF ISSUES SUPPLIERS MAY
ENCOUNTER:

DEFINITIONS Failure to obtain environmental permits

or not meeting permit requirements (e.g.
routine testing of emissions).

Environmental Aspects are the parts of a
supplier’s activities that can interact with theenvironment; e.g. use of hazardous chemicals.

 Regulatory compliance is not assessed on a

An Environmental Impact is a change to theenvironment – good or bad – caused by anorganization’s environmental aspects. For
example, groundwater contamination caused bya spill of a hazardous chemical.

a process of free, prior and informed
consent.

Environmental performance is the set ofmeasurable results related to the control ofthe supplier’s environmental aspects, such as
reducing a supplier’s environmental impacts or
achieving regulatory compliance.
Pollution is the discharge of a harmful orpoisonous substance into the air, water orground.
An environmental permit is any approval, license
or authorization required by an environmental
law or regulation.
Waste is an output of a supplier’s operations
that has no marketable value. If improperly
disposed, waste can be a source of pollution.
Recycling is the process of reclaiming and/or
reprocessing a material for use in a new product.

Mars Supplier Code of Conduct Guidebook

regular basis.

 Acquisition of land without following Unlicensed vendors used to haul anddispose of hazardous waste materials.

 No process in place to reduce the use ofenergy, water and other natural resources.

USE A MANAGEMENT SYSTEMS APPROACH
TO ADDRESS COMMON RISKS
Implementing the following management
system elements may enable suppliers tobetter address the supplier's impact on theenvironment and help to meet the
expectations contained in the Mars Supplier
Code of Conduct: A clear and detailed environmental andland acquisition policy.

 Procedures and accountability forestablishing and maintaining compliancewith environmental laws and regulations.
– 25 of 64

ENVIRONMENT

 Training for management and workers on

 Process to identify, evaluate and control

 Documentation of all environmental permits

 Emergency preparedness and response

the environmental policy and procedures,
including on the environmental aspects
associated with specific jobs.
and compliance assessment reports.

 Ways to monitor that environmental

emission controls are working properly
and are effective in maintaining emissions
within allowable limits.

 Periodic senior level review of how

effectively the supplier’s overall system isperforming.

 The following sections provide a listof system processes, starting with theclear policies that are the foundation ofPlanning.

POLICIES
Supplier’s company policies may include: Compliance with applicable environmental
laws and regulations.

 Transparent engagement with local

communities and indigenous peoples forthe purchase or lease of land.

 Continuous improvement in environmental
performance.

PROCEDURES
Below are examples of practices that if
implemented can enable a supplier to deploy
the policies noted above: A way to routinely identify, track and apply

applicable environmental and land use laws
and regulations.

Mars Supplier Code of Conduct Guidebook

significant environmental aspects on aregular basis and for all new and modified
production processes and equipment.
procedures for leaks and spills of
hazardous materials, and other possible
environmental incidents (e.g. failure ofemission treatment systems).

 Preventive maintenance procedures foremissions control equipment and otherpollution controls.

 Documented procedures for all jobs withsignificant environmental aspects (e.g.
operation of chemical process equipment,
and handling and storage of hazardous
waste).

 Procedure to identify opportunities toreduce the consumption of energy andwater.

 Procedure for the reporting andinvestigation of all environmental incidents
and violations of permit conditions,
including taking corrective action.

 Process to obtain the free, prior and fully

informed consent of affected communities
or indigenous peoples for all landacquisitions.

COMMUNICATION& TRAINING
To ensure that policies and procedures arefollowed, suppliers should assign responsibilities
for implementation and train responsible staff
on their roles. Examples of such practices
include: Communicate the supplier’s environmental
policy and procedures to all employees
in new employee orientation training andperiodically thereafter.

– 26 of 64

ENVIRONMENT Routinely train workers on the Copies of environmental licenses and Train all employees and on-site contractors

 Emissions monitoring records.
 Records of maintenance for emissions

environmental aspects and impacts of theirjobs, and any associated procedures.
on how to report an environmental
incident or emergency and how to safely
evacuate the workplace.

 Prominently display environmental

warnings and instructions, in thelanguage(s) understood by employees
where hazards are present.

 Offer training for community memberson their right to free, prior and informed
consent (FPIC) to any land acquisitions ortransfers by the supplier that could impact
them or their way of life.

 Routinely encourage workers to reportpotential environmental issues or
improvement opportunities.

DOCUMENTATION& RECORDS
Key procedures should be documented
whenever possible to ensure they are followed
consistently. The following are examples of suchpractices: Register of all applicable environmental
and land use laws, regulations andcustomer requirements.

 Copies of key environmental procedures,permits.

sources (boilers, generators, andproduction equipment) to show that legal
regulations are checked and consistently
achieved.

 Records of emergency evacuation drills,
chemical spill cleanup drills, and othertests of environmental emergency
preparedness.

 Land Rights procedures, including,but not limited to: environmental andhuman rights impact assessment; full,prior, informed consent (FPIC) process,community engagement process, and land
rights grievance process.

 Minutes of meetings and other outreachsessions with individuals, communities andIndigenous Peoples.

 Records of community grievance reports,
including their investigation, resolution
and, where provided, remediation.

Records of self-assessments and otherevaluations of compliance with the supplier’s
environmental policies and procedures and legal
requirements.

such as:

Suggested Practice• Hazardous material storage, handling,
and use,• Waste handling, storage, and disposal,• Operation of processes and equipmentwith regulatory impact, and• Maintenance and monitoring ofemissions control equipment.

Regularly tracking its compliance status
helps the business identify trends, including
problem areas, which may require changes
in business processes or practices to further
reduce compliance risk and to meet its
environmental compliance obligations

Mars Supplier Code of Conduct Guidebook– 27 of 64

ENVIRONMENTMONITORING
To evaluate and improve the supplier’s programsuppliers should evaluate routinely how
well their policies and procedures are being
implemented. Monitoring can take the following
forms:

 Establish and track simple KPIs to measure

regulatory compliance and program
effectiveness on an ongoing basis, such as:□ Number of emissions exceedances per



month
□ Number of workers trained on thecompliance impact of their job
activities□ % of identified regulatory noncompliances corrected on time
□ % of project impacts mitigated tosatisfaction of the community□ % of community grievances addressedon timeRoutinely interview or survey workers
to measure their understanding of thepotential environmental impacts of theirjobs and to learn of any unidentified
environmental compliance issues.

 Perform regular facility inspections toverify that environmental aspects areproperly controlled, emissions controls
are operating properly and are effective,
operational procedures are followed whererequired, and hazardous materials areproperly stored.

 Regularly survey community members to
obtain their feedback on the supplier’s
land use and acquisition policies andpractices.

 Evaluate every environmental incident

drill to verify that alarms and notification
systems worked properly, and that incident
response teams performed as expected.

 Audit the supplier’s environmental andland use processes and procedures on aregular basis. Audits should be performedby trained and qualified internal staff or byexternal auditors.

 Regularly evaluate and address any

grievances received from community
members about environmental or land use
issues.

 ORRECTIVE ACTIONC& SYSTEM REVIEWFor continuous improvement of procedures, thesupplier should undertake immediate corrective
and preventive actions, as well as periodic
system reviews. This process may include: Conducting root cause analysis of any
issues uncovered during monitoring.

 Setting improvement targets anddeveloping both corrective and preventive
actions (modified procedures) to addresseach identified root cause.

 Assigning task owners, milestones, andcompletion dates.

 Monitoring that changes in procedures

have been made and that they produce
the desired result.

 Conducting ongoing periodic senior

management review for overall systemeffectiveness.

Click here for additional resourses
Mars Supplier Code of Conduct Guidebook– 28 of 64

ETHICSMANAGEMENT SYSTEMS APPROACH:•This chapter provides guidance on how todevelop and implement management systems
related to Ethics.

•

Suggested Practice•Managers should encourage open andhonest communication and ensure that
employees can raise concerns about businesspractices without fear of retaliation.

•

DEFINITIONSBusiness ethics is the application of moral
principles to business behavior. It defines
the principles that suppliers should apply tobusiness decision-making.
Corruption is fraudulent or dishonest behavior
or inducing improper behavior by unlawfulmeans, such as bribery.
Bribery is the unlawful practice of offering
money or something of value in exchange forobtaining preferential treatment or improper
advantage.
Improper Advantage is obtaining something
to which the supplier is not entitled, such as agovernment approval or permit, by means of abribe or other unethical practice.
A whistleblower is someone who makes anallegation of violation of ethics policy or legal
requirements.

EXAMPLE OF ISSUES SUPPLIERS MAY
ENCOUNTER:•

Facilitation payments to a government
official or agency to expedite performanceof an administrative function.

Mars Supplier Code of Conduct Guidebook

Offering gifts or something of value to abusiness partner or government official toinfluence a decision in favor of the supplier.
Using confidential information from a
supplier, customer or other business
partner to gain improper advantage.
Conflicts of interest, such as receiving
compensation from a customer, supplier orcompetitor.
No reporting channel for whistleblowers orlack of protection of whistleblowers from
retaliation.

USE A MANAGEMENT SYSTEMS APPROACH
TO ADDRESS COMMON RISKS
Implementing the following management
system elements can help suppliers to ethicallyconduct business:

 A clear and detailed business ethics policy.
 Procedures and accountability for establishingand maintaining compliance with bribery andcorruption laws and regulations.

 Training for management and workers on

the business ethics policy and procedures,
including on the ethics issues associatedwith specific jobs (for example, gift giving
and receiving for procurement staff).

 Documentation of anti-corruption

procedures and records of allegation of
ethical misconduct.

 Ways to monitor that ethics policies andprocedures are effective in preventing
unethical behavior in the supplier’s
relationships with business partners andgovernment officials.

 Periodic management level review of how
the overall ethics management system isperforming.

– 29 of 64

ETHICS

The following sections provide a list of systemprocesses, starting with the clear policies thatform a foundation of Planning.

POLICIES
Supplier’s company policies may include: Prohibition of corruption in any form,
including giving or accepting bribes.

 Compliance with applicable anti-

corruption laws and regulations, including
the US Foreign Corrupt Practices Act andthe UK Bribery Act.

 A way to protect employees from

retribution for refusing to do anythingillegal or in conflict with the supplier’s
ethics policy (for example, being asked tobribe a government official).

Potential conflict of interest
situations••

 Prohibition of gift giving or receiving ofanything of value is prohibited.

 Requirement for employees to declare any
potential conflicts of interest.

PROCEDURES
The following procedures are examples ofpractices which if implemented can assist a
supplier to implement the policies noted above: A way to routinely identify, track and apply

applicable bribery and corruption laws andregulations.

 Procedure for whistleblowers to report

allegations of unethical behavior without
fear of intimidation or reprisal.

 Process to investigate allegations of
unethical behavior.

 A way for employees to declare potential

conflicts of interest and to modify their job
responsibilities accordingly.

 Procedure to limit the amount andfrequency of gifts given or received.

Mars Supplier Code of Conduct Guidebook••

Significant financial interest in apartner, supplier, or competitor.
Conducting business with a partner,
supplier, or customer when someone
with whom the supplier have a close
personal relationship (e.g. a family
member) has a major position in that
supplier.
Outside employment with business
partner, supplier, or competitor.
Working for a government agency withregulatory authority over the supplieror that buys from the supplier.

COMMUNICATION& TRAINING
To ensure that policies and procedures arefollowed, suppliers should assign responsibilities
for implementation and train responsible staff
on their roles. Examples of effective practiceinclude: Communicate the supplier’s ethics policy
and procedures to all employees in
new employee orientation training andperiodically thereafter.

 Routinely train workers on the bribery andcorruption aspects of their jobs, and any
associated procedures, such as reporting
conflicts of interest or limitations on gift
giving and receiving.

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ETHICS Train all employees and on-site contractors
on how to report allegations of unethicalbusiness conduct.

 Prominently display the business ethics

policy and allegation reporting procedure,in the language(s) understood byemployees.

DOCUMENTATION& RECORDS
Key procedures are documented wheneverpossible to ensure they are followed.
Additionally, the supplier should maintaindocuments and records that demonstratecompliance with ethics requirements. The
following are examples of such practices: Register of all applicable bribery andcorruption laws, regulations and customer
requirements.

 Copy of the supplier’s Ethics policy, Records of allegations of unethical conduct
and their investigation and resolution.

 Copies of non-disclosure agreements

and employee declarations of conflict ofinterest.

 Records of disciplinary actions taken for
confirmed cases of violation of supplier
ethics policy and procedures.

 Records of self-assessments and otherevaluations of compliance with the
supplier’s ethics policies and procedures
and legal requirements.

MONITORING
To evaluate and improve the program, suppliers
should routinely evaluate how well their policies
and procedures are being implemented.
Monitoring can take the following forms:

 Establish and track simple KPIs to measure

regulatory compliance and program
effectiveness on an ongoing basis, such as:

endorsed by executive management.

 Copies of key ethics procedures, such as:• Declaration of conflicts of interest andadjusting employee responsibilities toavoid such conflicts,• Reporting allegations of unethicalconduct.
• Investigating and addressing
allegations of unethical behavior,• Disciplinary procedure for individuals
found to have acted unethically.
• Procedure to routinely evaluate
supplier compliance with bribery andcorruption laws and regulations.
Copies of internal and third-party
audits of supplier financial practices andrecord keeping.

Mars Supplier Code of Conduct Guidebook□ Number of ethics allegations perquarter.
□ % of ethics allegations for the samepractice.
□ % of identified unethical businesspractices addressed on time.
Evaluate any threats (explicit or implies)
against employees for refusing to take partin any activity that violates the supplier’s
ethics policy and procedures and takecorrective and preventive action asnecessary.

 Interview or survey workers and business
partners to find out if they are aware ofand are comfortable with the supplier’s
procedure for reporting allegations of
unethical conduct.

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ETHICS

 Audit ethics processes and procedures

on a regular basis to verify that they arebeing implemented as intended and are
effective.

 Regularly evaluate and address all

allegations of unethical behavior from
employees, suppliers, customers and otherbusiness partners.

 Conducting root cause analysis of any
issues uncovered during monitoring.

 Setting improvement targets anddeveloping both corrective and preventive
actions (modified procedures) to addresseach identified root cause.

 Assigning task owners, milestones, andcompletion dates.

 Monitoring that changes in procedures ORRECTIVE ACTIONC& SYSTEM REVIEWFor continuous improvement of procedures,
suppliers should undertake immediate
corrective and preventive actions, as well as
periodic system reviews. This process include:

have been made and that they produce
the desired result.

 Conducting ongoing periodic senior

management reviews for overall systemeffectiveness.

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Mars Supplier Code of Conduct Guidebook– 32 of 64

FORCED LABORMANAGEMENT SYSTEMS APPROACH:This chapter provides guidance on how todevelop and implement management systems
related to Forced Labor.

DEFINITIONS
Forced labor is defined by the International
Labour Organization (ILO) as “all work or service
which is exacted from any person under the
menace of any penalty and for which the person
has not offered himself or herself voluntarily.”
The terms “offered voluntarily” refer to the free andinformed consent of a worker to take a job and hisor her freedom to leave at any time. This is not thecase for example when an employer or recruitermakes false promises so that a worker take a job heor she would not otherwise have accepted.
Recruitment Agents, also known as private
employment agencies or labor brokers,
including sub-agents; are third-party service
providers involved in the recruitment, selection,
hiring, transportation, and, in some cases,
management of migrant workers.
Recruitment agents operate in both the sending
and receiving countries. Receiving country
agents typically work with sending country
agents in the country of origin or residence of
migrant workers to identify and recruit potential
job candidates.
3) T rafficking in human beings: Article 3 of the Protocol to Prevent,
Suppress and Punish Trafficking in Persons, especially Women andChildren defines trafficking in persons as follows:(a) Trafficking in persons shall mean the recruitment, transportation, transfer,harbouring or receipt of persons by means of the threat or use of force orother forms of coercion, of abduction, of fraud, of deception, of the abuseof power or of a position of vulnerability or of the giving or receiving of
payments or benefits to achieve the consent of a person having control overanother person for the purpose of exploitation. Exploitation shall include, ata minimum, the exploitation of the prostitution of others or other forms ofsexual exploitation, forced labour or services, slavery or practices similar toslavery, servitude or the removal of organs.

Mars Supplier Code of Conduct Guidebook

Migrant workers are workers who migrate fromtheir country of origin or permanent residence
to obtain employment at the Supplier’s facility.
This includes domestic and overseas migration.
Penalties include both actual and threats ofphysical violence, withholding of identify
documents, denunciation to authorities, wage
withholding and indebtedness.
Human trafficking3is bringing workers into a situation of
exploitation through a series of actions,
including deceptive recruitment and coercion.
Debt-bondage or indebtedness, is when workers
should continue to work to repay a debt to a labor
broker, their employer, or another third-party,
typically because of recruitment fees or loans.

EXAMPLES OF ISSUES SUPPLIERS MAY
ENCOUNTER
•

•

•

•

•

Workers pay fees to recruitment agents or
sub-agents, often resulting in significant
indebtedness.
Worker identity documents, such as
passports, are withheld by labor brokers
or employers, limiting their ability to move
about freely or quit their jobs.
Upon arrival in the destination country,
workers are asked to sign new contracts
that may be for a different job, with lower
wages and benefits.
Workers are automatically enrolled in
mandatory savings programs and theirmoney is not available to them until
completion of the employment control.
Foreign migrants and contract workers
often work for lower pay and benefits
than local regular workers performing thesame jobs.

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FORCED LABORUSE A MANAGEMENT SYSTEMS APPROACH
TO ADDRESS COMMON RISKS
Implementing the following management
system elements may enable suppliers to ensure
workers are ethically recruited and help to meetthe expectations contained in the Mars Supplier
Code of Conduct: A clear and detailed policy prohibiting
forced and bonded labor.

 Procedures and accountability forestablishing and maintaining compliancewith laws and regulations related to forcedlabor and the Mars Code of Conduct.

 Training for management and workers on

the forced labor policy and procedures on
ethical recruitment.

 Documentation of procedures to track

whether job seekers or employees arecharged recruitment and placement fees
and the amount of the fees.

 Ways to monitor that workers have enteredinto their employment contract voluntarily
and are free to quit without penalty upongiving reasonable notice.

 Periodic senior level review of how

effectively the overall system is performing

The following sections provide a list of systemprocesses, starting with policies that form thefoundation of Planning.

POLICIES
Supplier’s company policies may include: The supplier will only engage recruitment

agents with a history of ethical recruitment
and a commitment to the supplier’s policy
requirements.

 All workers will be provided complete andaccurate terms and conditions of
employment before being asked to sign an
employment contract.

 There will be no contract substitution andany changes in contract terms will be to
the advantage of the worker.

 Workers will be in possession of their

passports and will be provided individual,
secure storage facilities.

 Workers will be free to terminate theiremployment at any time without penalty
upon giving reasonable notice.

 Workers will not be required to makemonetary deposits or to participate inmandatory savings programs.

 Wages will be paid in full and on time.
 There will be no unreasonable restrictions
in employee movement from theworkplace or accommodation when notworking.

 Migrant workers found to be victims of

trafficking or provided with fraudulent
immigration documents will be provided
with access to remedy to the extent
allowed by law.

 On a case by case basis, workers who arefound to have paid fees that constrain theirability to freely choose employment as partof the recruitment process will have those
fees reimbursed.

 Workers will not be charged recruitment orplacement fees by the supplier to obtaina job. All such fees will be paid by theemployer.

Mars Supplier Code of Conduct Guidebook– 34 of 64

FORCED LABORPROCEDURES
The following procedures are examples ofpractices which if implemented can assist a
supplier in deploying the policies noted above: Recruitment procedures that ensure:• Job advertisements describe positions
accurately and state the policy related
to fees.
• Job candidates are given a complete
and accurate description of the terms
and conditions of employment bothverbally and in writing.
• Employment contracts are in alanguage the worker understands andis provided for review before signing.
• Workers do not make deposits or post
bonds in order to obtain the job.
• Procedure to screen all recruitment
agents for their recruitment practices,
regulatory compliance history, andboth willingness and ability to meet the
supplier’s policy before engaging them.
Formal service agreements withrecruitment agencies and labor contractorsthat workers do not pay any fees thatwould place them in conditions of Forced
Labor.

 Workers are in possession of their identity

documents at all times and that the agent,broker or employer retains them only
as long as needed to obtain or renew
required documentation, such as visas andwork permits.

 Process to ensure that workers are free toCOMMUNICATION& TRAINING
To ensure that policies and procedures arefollowed, suppliers should assign responsibilities
for implementation and train responsible staff
on their roles. Examples of such practices
include: Provide initial and periodic training forrecruitment and hiring staff and thosethat mange recruitment agents and labor
contractors on the supplier’s policies andprocedures, and legal requirements on
forced labor prevention.

 Newly hired migrant workers should

receive a thorough pre-departure
training related to their contract terms,
information about where they will be living
and working, and their legal rights andresponsibilities.

 All newly hired workers should receive

a new hire orientation covering the
supplier’s workplace policies andprocedures – including those addressing
forced labor.

 Communicate the supplier’s forced labor
policy to any third parties that provide
recruitment services on the supplier’s
behalf.

 Display supplier policy and local laws

and regulations on forced labor in thelanguage(s) that all workers understand.

 Communicate the supplier’s forced labor

policy and performance requirements toon-site contractors and service providers.

return home during paid leave or for family
emergencies without penalty.

Mars Supplier Code of Conduct Guidebook– 35 of 64

FORCED LABORD OCUMENTATION& RECORDS
Key procedures should be documented
whenever possible to ensure they are followed
consistently. The following are examples of suchpractices: Copies of migrant worker personal

identification documents, work permits
and visas, medical certificates and anyother documents and records requiredby law.

 Copies of signed employment contracts
for all workers.

 Service agreements with recruitment
agencies and labor contractors.

 A roster of all foreign migrant and local
contract workers.

 Records of recruitment agent and labor
contractor screening assessments andrecords of ongoing monitoring of theirperformance against the supplier’s
forced labor requirements.

 Records of worker grievance reports

and how they were investigated andresolved.

 Records of self-assessments andother evaluations of conformance tothe supplier’s forced labor policies
and procedures and compliance withapplicable legal requirements.

MONITORING
To evaluate and improve the effectiveness ofthe program, it is recommended that suppliers
routinely evaluate how well their policies

Mars Supplier Code of Conduct Guidebook

and procedures are being implemented.
Monitoring can take the following forms:

 Establish and track simple KPIs to measureprogram effectiveness on an ongoingbasis, such as the number of new migrant
workers required to pay excessive
recruitment fees or the percentage of newhires who understand their employment
agreement.

 Regular verification of the validity

and completeness of migrant worker
immigration and work documents to verify
that procedures are being properly
followed by internal staff and third-party
recruitment agents and labor brokers. This
process should be part of the routine
evaluation of recruitment agent
performance.

 Conversations with recruitment staff

members to ensure they understand andeffectively implement the supplier’s forcedlabor prevention requirements.

 Interviews with all new contract workers

and newly arrived migrant workers todetermine if the supplier’s standards were
met throughout the recruitment, selection
and hiring process.

 Assess the frequency and natureof contract and migrant worker
complaints and grievances related
to their treatment during the hiring
process, in the workplace, and insupplier-provided or arranged
accommodation and transport.

 Regular evaluations of the performance ofrecruitment agents and labor contractors
in meeting supplier forced labor
prevention requirements.

 Perform periodic interviews or surveys of
migrant and contract workers.

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FORCED LABOR ORRECTIVE ACTIONC& SYSTEM REVIEWFor continuous improvement of procedures,
supplier should undertake immediate corrective
and preventive actions, as well as periodic
system reviews. This process may include: Conducting root cause analysis of any

 Assigning task owners, milestones, andfinal completion dates.

 Monitoring that changes in procedures

have been made and that they produced
the desired result.

 Conducting ongoing periodic senior
management reviews for overallsystem effectiveness.

issues uncovered during monitoring.

 Setting improvement targets anddeveloping both corrective andpreventive actions (modified procedures)to address each identified root cause.

Click here for additional resourses
Mars Supplier Code of Conduct Guidebook– 37 of 64

FREEDOM OF ASSOCIATIONThis chapter provides guidance on how todevelop and implement management systems
related to Freedom of Association.

DEFINITIONS
Freedom of Association4
means allowing workers to form and jointrade unions, worker associations and worker
councils or committees of their own choosing.
The purpose is to have good two-way
communication between management andworkers
Collective Bargaining5is the way employers and worker representatives
reach agreements on working conditions,wages, overtime, grievance procedures andworker involvement in workplace affairs.
Peaceful Assembly refers to the right of workers
to come together and collectively express theirideas to management related to the terms andconditions of employment. An “assembly” isan intentional and temporary gathering in a
private or public space for a specific purpose
and includes demonstrations, inside meetings,
strikes, processions, rallies or even sits-ins.

EXAMPLE OF ISSUES SUPPLIERS MAY
ENCOUNTER
•

•

•
•

•

Job applicants are denied employment
because of their association with tradeunions or other worker organizations.
Worker representatives are not paid forthe time spent on their representative
responsibilities.
Union representatives and members aretreated differently than other workers.
Attempts are made to dissuade workers
from joining a trade union or otherrepresentative worker organization.
Worker representatives are selected bymanagement rather than being
democratically elected.

USE A MANAGEMENT SYSTEMS APPROACH
TO ADDRESS COMMON RISKS
Implementing the following management
system elements may enable suppliers to ensurethat workers’ rights to freedom of associationand collective bargaining are respected andhelp to meet the expectations contained in theMars Supplier Code of Conduct: A clear and detailed commitment to4) ILO Convention 87 - Freedom of Association and Protection of the Rightto Organise Convention, 1948. Article 2: “Workers and employers, without
distinction whatsoever, shall have the right to establish and, subject only tothe rules of the organisation concerned, to join organisations of their own
choosing without previous authorization.”5) ILO Convention 154 - Collective Bargaining Convention, 1981. Article 2: “theterm collective bargaining extends to all negotiations which take place
between an employer, a group of employers or one or more employers’organisations, on the one hand, and one or more workers’ organisations, on
the other, for--(a) determining working conditions and terms of employment;
and/or (b) regulating relations between employers and workers; and/or (c)regulating relations between employers or their organisations and a workers’organisation or workers’ organisations.

Mars Supplier Code of Conduct Guidebook

respecting the rights of freedom of
association and collective bargaining inthe supplier’s policy.

 Procedures and accountability forestablishing and maintaining compliancewith freedom of association laws andregulations.

 Training for management and workers on
the freedom of association policy andprocedures, including how unions andother worker organizations can conduct
their activities without interference.

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FREEDOM OF ASSOCIATION

 Documentation of all collective bargaining
agreements and minutes of worker
management meetings.

 Ways to monitor that there is nodiscrimination against job applicants due tounion affiliation.

 Periodic management level review of how

effectively the overall system is performing.

The following sections provide a list of systemprocesses, starting with policies that form thefoundation of Planning.

POLICIES
Supplier’s company policies may include: Supplier recognition of workers’ rights

to freedom of association and collective
bargaining.

 Right for workers to peacefully assemble todiscuss workplace issues.

 Worker right to join or not join trade Clearly defined procedure describing

how the supplier interacts with tradeunions and other representative worker
organizations.

 A process to provide reasonable facilities
for the union or worker organizations to
conduct its business on site.

 A way to define a reasonable timeand place for peaceful assembly forthe purpose of maintaining a safe andproductive work environment.

 A way for workers to collectively petition

management with concerns or requests inthe absence of a trade union.

 Process to ensure workers are notdiscriminated against in salary, benefits,or promotion because they belong to aunion.

 A way to ensure that there is nointerference with worker representatives’performance of their duties and that
representatives are paid for time spent
conducting their representative activities.

unions or other representative worker
organizations of their own choosing.

 Worker affiliation with trade unions will

not be considered in hiring decisions or in
eligibility for wage increases, promotion,access to training and other employment
decisions.

Practice Tip
Where Freedom of Association rights arelimited by law, make sure that workers
know that the supplier is willing to workwith an alternative representative worker
organization.

PROCEDURES
The following procedures are examples ofpractices which if implemented can assist a
supplier to deploy the policies noted above: Hiring procedures that ensure job

applicant affiliation with trade unions orother representative worker organizations
is not a consideration in selection for a job.

Mars Supplier Code of Conduct Guidebook

COMMUNICATION& TRAINING
To ensure that policies and procedures arefollowed ,suppliers should assign
responsibilities for implementation and train
responsible staff on their roles. Some
examples of this practice include:– 39 of 64

FREEDOM OF ASSOCIATION

 Provide initial and periodic training for

all workers, supervisors and managers on
the supplier’s policies and procedures,and legal requirements on freedom of
association and collective bargaining.

 In-depth training for managers andsupervisors on how to ensure that therights to freedom of association andcollective bargaining are respected andnot infringed.

 Communicating regularly with all workers

on their rights and the supplier policy
respecting their rights. The supplier policy
should be prominently posted in theworkplace in the language(s) understoodby the workforce.

 Allow worker representatives toparticipate in training delivered by thetrade union on their representative
responsibilities.

 Make sure that in the absence of a

trade union or other representative
worker organization, that the suppliercommunicates to workers their right topeacefully assemble to discuss workplaceissues.

DOCUMENTATION& RECORDS
Key procedures are documented wheneverpossible to ensure they are followed consistently.
The following are examples of such practices: Accurate minutes of union-management

meetings or of worker-management
meetings (where there is no trade union)
covering issues discussed and suggestions
or actions agreed upon.

 Election results for union or worker
organization representatives.

Mars Supplier Code of Conduct Guidebook

 The collective bargaining agreement,
if any, with the trade union.

 Logs of individual or collective complaints
or grievances, including how they wereresolved. Actions taken to address issues
should be posted in the workplace.

 Records showing that supplier supportof the union or representative worker
organization is limited to provided facilities
for it to conduct its business.

 Records of self-assessments andother evaluations of conformance tothe supplier’s freedom of associationand collective bargaining policies
and procedures and compliance withapplicable legal requirements.

MONITORING
To evaluate and improve the program, suppliers
should routinely evaluate how well their policies
and procedures are being implemented.
Monitoring can take the following forms:

 Establish and track simple KPIs to measureprogram effectiveness on an ongoingbasis, such as the percentage of workers
surveyed who understand their rights
to freedom of association, collective
bargaining and peaceful assembly, and thepercentage of workers who believe thesupplier respects those rights.

 Review termination records and exit

interviews to determine if departing
workers described discrimination based onunion membership or serving as a worker
representative.

 Conversations with managers andsupervisors to ensure they understandand effectively implement the supplier’s
freedom of association and collective
bargaining policy and procedures.
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FREEDOM OF ASSOCIATION Periodically review recruitment, selection
and hiring procedures and records toensure that there is no discrimination
against job applicants with union
affiliation.

 Routinely review complaints and Conducting root cause analysis of any
issues uncovered during monitoring.

 Setting improvement targets anddeveloping both corrective and preventive
actions (modified procedures) to addresseach identified root cause.

grievances from workers related to theadministration of the supplier’s freedomof association and collective bargaining
procedures.

 Assigning task owners, milestones, and ORRECTIVE ACTIONC& SYSTEM REVIEW Conducting ongoing periodic senior

completion dates.

 Monitoring that changes in procedures

have been made and that they produce
the desired result.
management reviews for overall systemeffectiveness.

For continuous improvement of procedures,
supplier should undertake immediate corrective
and preventive actions, as well as periodic
system reviews. This process includes:

Click here for additional resourses
Mars Supplier Code of Conduct Guidebook– 41 of 64

HEALTH & SAFETY
MANAGEMENT SYSTEMS APPROACH
This chapter provides guidance on how todevelop and implement management systems
related to Health and Safety.

EXAMPLES OF CHALLENGES SUPPLIERS
MAY ENCOUNTER
The following are typical issues facing suppliers:•

Ensuring that workplace safety and healthhazards are properly controlled depends
on feedback from workers. Employees
should be encouraged to report hazards andsuggest appropriate control measures.

•••

DEFINITIONS
Job Hazard Analysis is a process to evaluate thehealth and safety hazards of a job by breaking
it down into individual tasks and identifying
potential hazards of each task.
Engineering Controls are ways to prevent
employee exposure to hazards by controllingthem at the source, such as providing machine
guarding, local exhaust ventilation, noise
enclosure, and chemical storage cabinets.
Personal Protective Equipment (PPE) are devices
worn by workers to prevent exposure to hazards
that cannot be controlled by engineeringmeans. Typical PPE includes chemical protective
gloves, safety glasses, hearing protection andrespirators.

••

Exit aisles are obstructed and exit doors
are locked or blocked.
Workers are discouraged from reporting
health & safety issues and work-related
injuries.
Machine safeguarding is not maintainedin good working order or is bypassed.
Workers should obtain a pass or
supervisor’s approval to use the toilet or
get a drink of water.
Regular evacuation drills are notconducted.
Food preparation and storage facilities
do not meet local health regulations.

USE A MANAGEMENT SYSTEMS APPROACH
TO ADDRESS COMMON RISKS
Implementing the following management
system elements can help suppliers to ensurethat workers have safe and healthy work
conditions. Examples of such practices include: A clear and detailed occupational health &safety policy.

 Procedures and accountability forestablishing and maintaining a safe &healthy workplace.

Hazardous Material is a chemical substance(solid, liquid, gas or vapor) that has the potential
to cause harm to human health by skin contact,
inhalation or ingestion.

 Training for management and workers on the

Physically Demanding Work means work thatcan cause a musculoskeletal injury due to a
combination of the force, frequency of motion
and posture involved in performing the job.

 Documentation of all injuries and records

Mars Supplier Code of Conduct Guidebook

health & safety policy and procedures,
including on the specific health & safety
hazards and precautions of each worker’s job.
of accident investigation reports and theirresolution.

– 42 of 64

HEALTH & SAFETY Ways to monitor that health & safety hazard
controls and procedures are being followed
and are effective in preventing workrelated injuries and illnesses.

 Periodic management level review of how

effectively the overall system is performing.

The following sections provide a list of systemprocesses, starting with the policies that form
the foundation of Planning.

POLICIESTo align with best practice, company policies
may include: Compliance with applicable health &safety laws and regulations.

 Maintaining a safe and healthy working
environment and employer-provided
housing, transportation and foodservices.

 Workers who suffer work-related injuries
and illnesses are provided with all
medical treatment and related services
needed for a full recovery and return towork.

 Respect for workers’ right to unrestricted

access to basic liberties (e.g. toilet facilities
and drinking water).

 Provide workers with knowledge of thehealth & safety risks of their jobs.

PROCEDURES
The following procedures are examples ofpractices which if implemented can assist a
supplier to deploy the policies noted above:

Mars Supplier Code of Conduct Guidebook

 A way to systematically identify, track andapply applicable health & safety laws andregulations.

 Process to identify, evaluate and control

health & safety hazards on a regular basis
and for all new and modified production
processes and equipment.

 Emergency preparedness and response

procedures for fire, medical emergencies,
and other possible emergency situations (e.g.
flood, storm, earthquake, chemical spill).

 Preventive maintenance procedures formachine guarding, exhaust ventilation andother hazard controls.

 Documented safe work procedures for alljobs with identified health & safety hazards(e.g. “lockout-tagout” procedures to prevent
accidental startup and injury while working
on machinery or equipment).

 Procedure to provide, maintain, and replace
as required, personal protective equipment
where hazards cannot be controlled byengineering means.

 Procedure for the reporting and investigationof all work-related injuries and illnesses,
including taking appropriate actions toprevent a recurrence.

 Process to encourage workers to report safety

and health concerns or offer suggestions forhazard controls without fear of intimidation or
reprisal.

Risk vs Hazard:
What’s the difference?
A hazard is a potential danger. Risk is the
chance of something going wrong and theseverity of the outcome.
Exposed electrical wires are an electrocution hazard,
that is, they have the potential to cause injury.
A risk is the probability of a worker contacting
the wires and getting shocked, burned or killed.
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HEALTH & SAFETYCOMMUNICATION& TRAININGDOCUMENTATION& RECORDS

To ensure that policies and procedures arefollowed, suppliers should assign
responsibilities for implementation and train
responsible staff on their roles. Some
examples of such practices include:

Key procedures are documented wheneverpossible to ensure they are followed. The
following are examples of such practice: Communicate the health & safety policy
and procedures to all employees in
new employee orientation training andperiodically thereafter.

 Routinely train all workers on the specifichazards and health & safety procedures fortheir jobs.

 Train all employees and on-site contractors

on how to report a fire or other emergency
and how to safely evacuate the workplace.

 Prominently display health & safety

warnings and instructions, in thelanguage(s) understood by employees
where hazards are present.

 Train workers on how to report workplace
injuries and illnesses and the importanceof doing so.

 Routinely encourage workers to reportpotential health & safety hazards in theworkplace or in their housing.

 Inform workers of their rights to access basic
liberties as needed, and to take the rest andmeal breaks to which they are entitled.

Continuous learning.
Training doesn’t end after one session orpresentation. Workers need to be continuously
reminded of safe practices. Encourage workers
to monitor others for safe practices. Encourage
workers to report hazards and suggest
corrective measures. And recognize workers for
exemplary safety practices.

Mars Supplier Code of Conduct Guidebook

 Register of all applicable health &safety laws, regulations and customer
requirements.

 Records of health & safety hazard
assessments.

 Health & safety procedures, such as

emergency evacuation, electrical safety,
use of personal protective equipment,
industrial hygiene, among others.

 Health & safety committee meeting

minutes, action items, and attendance
records.

 Log of work-related accidents, injuries andillnesses.

 Records of emergency evacuation drills,
chemical spill cleanup drills, and othertests of emergency preparedness.

 Internal and third-party audit reports,
workplace inspections, accident
investigation reports, and complianceinspection reports by regulatory
agencies.

 Health & safety corrective and preventive

action plans, including documented
evidence of hazard control improvements.

 Records of health & safety training

attendance and assessment of knowledge
and/or skills (quizzes, tests, skills
demonstrations).

 Inspection and maintenance records formachinery, machine safeguards, local
exhaust ventilation, and other health andsafety hazard control systems.
– 44 of 64

HEALTH & SAFETY Records of self-assessments andother evaluations of conformance tothe supplier’s health & safety policies
and procedures and compliance withapplicable legal requirements.

MONITORING
To evaluate and improve the program, suppliers
should routinely evaluate how well their policies
and procedures are being implemented.
Monitoring can take the following forms:

 Establish and track simple KPIs to measureprogram effectiveness on an ongoingbasis, such as:□ Injury and illness rates (incidence rate□□□and lost workday rate).
Percentage of reported accidents
investigated.
Percentage of corrective andpreventive actions implemented on
time.
Percentage of workers trained on jobspecific health & safety hazards.

 Routinely interview or survey workers tomeasure their satisfaction with workplace
health & safety conditions and to learn of
any unidentified health & safety hazards.

 Perform regular workplace, housing andfood service inspections to verify that
health & safety hazards are properly
controlled, machine guarding is effective,
PPE is used where required, hazardous
materials are properly stored, and exhaust
ventilation systems are working properly.

 Perform routine monitoring of worker

exposure to potential health hazards(noise, dust, vapors, gases, ionizing andnon-ionizing radiation, etc.)

 Evaluate every emergency evacuation drill

to verify that alarms and notification systems
worked properly, and all employees were able
to leave the facility in the designated time.

 Audit the supplier’s health & safety

processes and procedures on a regularbasis. Audits should be performed bytrained and qualified internal staff or byexternal auditors.

 ORRECTIVE ACTIONC& SYSTEM REVIEWFor continuous improvement of procedures,
supplier should undertake immediate corrective
and preventive actions, as well as periodic
system reviews. This process includes:

 Conducting root cause analysis of any
issues uncovered during monitoring.

 Setting improvement targets anddeveloping both corrective and preventive
actions (modified procedures) to addresseach identified root cause.

 Assigning task owners, milestones, andcompletion dates.

 Monitoring that changes in procedures

have been made and that they produce
the desired result.

 Conducting ongoing periodic senior

management reviews for overall systemeffectiveness.

Click here for additional resourses
Mars Supplier Code of Conduct Guidebook– 45 of 64

ISSUE REPORTING
MANAGEMENT SYSTEMS APPROACH:This chapter provides guidance on how todevelop and implement management systems
related to Issue Reporting.

DEFINITIONS
Grievance is an allegation or report of a rightviolated, a procedure or standard not followed,
an obligation not fulfilled, or other workplace
practice or condition that could adversely
impact a worker.
Grievance Process is the mechanism used by
the supplier by which employees can reporta an issue or grievance to management andthe way the grievance is investigated andresolved.
Confidential means the protection of theworker’s identity throughout the issue
reporting and resolution process, whileanonymous refers to the ability of a worker toreport a grievance without identifying her/himself. Anonymity is especially important forvulnerable workers.

EXAMPLES OF ISSUES SUPPLIERS MAY
ENCOUNTER:
•

•
•
•

Employees do not use the grievanceprocess because they do not trust it toprotect their confidentiality or they believe
it is ineffective.
Reported issues are not addressed in atimely manner.
Workers are not aware of how to report agrievance anonymously.
Workers suffer retaliation or harassment forreporting grievances.

Mars Supplier Code of Conduct Guidebook

USE A MANAGEMENT SYSTEMS APPROACH
TO ADDRESS COMMON RISKS
Implementing the following management
system elements may help suppliers to ensurethat the supplier’s workers have access to proper
channels of communication and issue reporting
processes:

 A clear and detailed issue reporting(worker grievance) policy.

 Procedures and accountability for

implementing a confidential worker
grievance process that is trusted byworkers and includes prompt investigation
and resolution of reported issues.

 General training for management andworkers on the grievance policy andprocess, including how to report agrievance and the process for grievanceresolution and communication to theaffected worker(s).

 Documentation of the grievance process
and records of grievances reports andtheir resolution.

 Ways to monitor that the issue reportingand investigation process is being
followed, that workers feel comfortableusing the process, and that it is effective in
identifying and resolving issues related tothe implementation of workplace policies
and procedures affecting workers.

 Periodic senior level review of how
effectively the overall system isperforming.

The following sections provide a list of systemprocesses, starting with the policies that form
the foundation of Planning.

– 46 of 64

ISSUE REPORTING

POLICIES
Supplier’s company policies may include: Constructive resolution of issues related

to the implementation of supplier policies
and procedures.

The more reporting channels
available to employees, the more
comfortable workers may be toreport an issue.
The typical range of reporting channels
includes: Confidentiality of the individual reporting• Ability to raise issues and grievances

•
•
•
•

the issue will be protected.
anonymously.

 Multiple reporting channels will be
provided – formal and informal.

 Prohibition of retaliation or harassment of

Verbal reporting to a supervisor or
Human Resources
Telephone hotline
Online, web-based report forms
SMS messaging, andSuggestion boxes in locations that
ensure privacy

individuals who report a grievance.

PROCEDURES
The following procedures are examples ofpractices which if implemented may assist a
supplier to deploy the policies noted above: A way for workers to report using different
reporting channels, including at least one
that provides anonymity.

 Procedure that allows workers to report agrievance against a supervisor to a person
other than the supervisor (or someone in
the same management reporting chain).

 Procedure for timely management

investigation and resolution of grievancereports with communication back to theindividual who filed the grievance.

 A procedure for workers to track the statusof grievances.

 Process for workers to appeal the

resolution of a grievance with which they
do not agree.

Mars Supplier Code of Conduct Guidebook

COMMUNICATION& TRAINING
To ensure that policies and procedures arefollowed, suppliers should assign responsibilities
for implementation and train responsible staff
on their roles. Examples of such practices
include: Communicate the grievance process to all
employees in new employee orientation
training and periodically thereafter.

 Prominently display instructions, in thelanguage(s) understood by employees,on the different ways to report agrievance.

 Include instruction on issue reporting inan employee handbook or on the back of
employee identification badges.

 Provide training for all managers andothers with assigned responsibility forreceiving and responding to employee
grievances.
– 47 of 64

ISSUE REPORTING

 Communicate the time limits for

management to respond, in writing,to worker grievances. When resolution
is delayed, the supervisor or manager
handling the complaint should
communicate, also in writing, the reason
for the delay.

 Records of grievance appeals, including

meeting minutes and a statement of the
final resolution of the issue.

 Records of self-assessments andother evaluations of conformanceto the supplier’s grievance policies
and procedures and compliance withapplicable legal requirements.

 Train workers on how to appeal agrievance decision if they disagree with
how it was resolved.

DOCUMENTATION& RECORDS
Key procedures are documented wheneverpossible to ensure they are followed
consistently. The following are examples of suchpractice:

MONITORING
To evaluate and improve the program, suppliers
should routinely evaluate how well their policies
and procedures are being implemented.
Monitoring can take the following forms:

 Establish and track simple KPIs to measureprogram effectiveness on an ongoingbasis, such as the: Documentation of the grievance reporting,□ percentage of grievances addressed

investigation, resolution and appeal
processes.

 Logging and classification of all reported

issues. Classification of issues is needed toseparate grievances from safety concerns,
improvement suggestions, and otherreported issues.

 Grievance records that include the issue,

when it was reported, who it was assigned
to for investigation and resolution, how it
was addressed, when it was communicatedback to the grievant. All such records should
be kept confidential, with access limited todesignated individuals.

 A summary of issues reported throughthe grievance process, as well as
management’s response(s) to theissues raised, should be posted in areas
accessible to the workers, such as on
notice boards and in the canteen. Postings
should not contain any information that
could be used to identify the grievant.

Mars Supplier Code of Conduct Guidebook

within the stated time limit;□ percentage of grievances filed for thesame issue; and□ percentage of issue resolutions
appealed by workers.
Routinely interview or survey workers
to understand their level of trust andconfidence in the grievance process.

 Regularly evaluate utilization of theavailable reporting channels to determine
if they are meeting the should have of theworkforce.

 Periodically evaluate how well thedefined process for investigating andresolving grievances is being followedby managers and other responsible
individuals by reviewing grievancerecords and interviewing responsible staff
to understand their knowledge of theprocess.

– 48 of 64

ISSUE REPORTING

 ORRECTIVE ACTIONC& SYSTEM REVIEWFor continuous improvement of procedures,
supplier should undertake immediate corrective
and preventive actions, as well as periodic
system reviews. This process includes:

 Conducting root cause analysis of any

 Assigning task owners, milestones, andfinal completion dates.

 Monitoring that changes in procedures

have been made and that they produced
the desired result.

 Conducting ongoing periodic senior
management reviews for overallsystem effectiveness.

issues uncovered during monitoring.

 Setting improvement targets anddeveloping both corrective and preventive
actions modified procedures) to addresseach identified root cause.

Click here for additional resourses
Mars Supplier Code of Conduct Guidebook– 49 of 64

WORK HOURSMANAGEMENT SYSTEMS APPROACH:This chapter provides guidance on how todevelop and implement management systems
related to Work Hours.

DEFINITIONSRegular work hours are the hours worked during
the normal work day. Local law typically sets thelimit of regular hours to between 40 and 48 per
week.
Overtime are the hours worked beyond thenumber of regular hours in a day or week.
Overtime can be performed either before orafter the worker’s normal work day or shift.
Rest time refers to the short rest and meal breaks
from work during the normal workday or thefull day off each week. Both rest breaks and restdays are typically required by local law.
Working hours records describes the system of
timekeeping to accurately record actual hours
worked. These records typically include:•••

Shift schedule and production records.
Time cards and/or electronic timekeeping
data.
Overtime approval records.

EXAMPLE OF ISSUES SUPPLIERS MAY
ENCOUNTER:•••

Employees work more hours than allowed
by law each week or month.
Overtime work cannot be refused without
retaliation or penalty, such as not being
offered overtime work in the future.
Employees work for weeks without a restday, resulting in an increase of workrelated injuries and lower productivity.

Mars Supplier Code of Conduct Guidebook•

Workers are not provided with the daily
rest breaks required by law.

USE A MANAGEMENT SYSTEMS APPROACH
TO ADDRESS COMMON RISKS
Implementing the following management
system elements may help suppliers to ensurethat work hours are properly managed:

 A clear and detailed commitment tolimiting work hours in compliance with thelaw and in consideration of worker safety
in the supplier’s policy.

 Procedures and accountability forestablishing and maintaining complianceworking hours laws and regulations.

 Training for management and workers on

work hours legal requirements and how tomanage work hours to within legal limits.

 Documentation of all hours worked in the

timekeeping system and worker pay slips.

 Ways to monitor that work hours do not

exceed legal limits and that workers areprovided with one day of rest each week.

 Periodic senior level review of how

effectively the overall system is performing.

POLICIES
Supplier’s company policies may include: Compliance with country and local laws

and regulations governing working hours
and time off.

 Rest breaks and meal breaks will be provided
during the work day as required by law.

– 50 of 64

WORK HOURS Workers can refuse overtime without
penalty.

 Overtime work will not be assigned if theadditional time could compromise worker
health and safety.

 Juvenile workers will not be assigned
overtime or night work.

 24 consecutive hours of rest will be

provided every seven days, or 48
consecutive hours every 14 days whenrequired for production and allowed by
local law.

 Workers will not be required to work morethan 60 hours per week (including
overtime).

 A leave scheduling process that ensures all

employees are able to take the paid annual
leave and public holidays to which they areentitled.

 Process to provide employees with pay

slips that list regular and overtime hours
worked and leave time.

COMMUNICATION& TRAINING
To ensure that policies and procedures arefollowed, suppliers should assign responsibilities
for implementation and train responsible
staff on their roles. Examples of such practiceinclude: Providing initial and periodic training for

PROCEDURES
The following procedures are examples ofpractices which if implemented can assist
a supplier to deploy the policies noted above: A way for workers to accurately record

their own work hours, preferably using anelectronic timekeeping system.

 Process for planning production andmanaging working hours that ensures
hours worked do not exceed legal limits.

 Procedure to ensure juvenile workers(those under age 18) do not work overtime
or at night.

 Procedure to request employees towork overtime, including the ability for
employees to turn down such requests.

 A work scheduling process that ensures

all workers are given a least one day ofrest (24 consecutive hours) per seven days
worked.

Mars Supplier Code of Conduct Guidebook

all workers, supervisors and managers on
the supplier’s policies and procedures,and legal requirements on working hours,
breaks and time off.

 In-depth training for managers andsupervisors on how to manage working
hours to within legal limits.

 The supplier work hours policy should

be prominently posted in the workplacein the language(s) understood by the
workforce.

 Training production workers to perform

more than one job to accommodate
seasonal production should have or to
replace employees who are absent or on
leave without requiring employees to work
excessive hours.

 Communicating regularly to employees
during busy production periods about
anticipated overtime hours.

– 51 of 64

WORK HOURSDOCUMENTATION& RECORDS
Key procedures are documented wheneverpossible to ensure they are followed. The
following are examples of such practice: Accurate records of hours worked for each
employee, such as individual pay slips andreports generated from the timekeeping
and payroll systems.

 Documented process for managing

employee work hours to within legal limits.
The process should be cross-functional,
with input from Production Planning,
Human Resources, Procurement, and Sales
and Marketing.

 Records of employee grievances related toinaccurate recording of working hours, or
inaccurate wage payments for the numberof recorded regular and overtime hours.

 Employment contracts that list regular

work hours, work breaks and rest days,
anticipated overtime hours, legal limits onwork hours, and the wage rates that will be
paid for both regular and overtime work.

 Any documented worker-managementagreement(s) that require employees towork a specified amount of overtime, suchas in a Collective Bargaining Agreement(CBA).

 Copies of signed worker consent forms forovertime work.

 Records of self-assessments andother evaluations of conformanceto the supplier’s work hours policies
and procedures and compliance withapplicable legal requirements.

Mars Supplier Code of Conduct Guidebook

MONITORING
To evaluate and improve the program, suppliers
should routinely evaluate how well their policies
and procedures are being implemented.
Monitoring can take the following forms:

 Establish and track simple KPIs to measureprogram effectiveness on an ongoingbasis, such as the total hours worked per
week or month; the percentage of workers
receiving one 24-hour rest day per week;
absenteeism or tardiness relative to hours
worked; and productivity or quality metrics
relative to hours worked.

 Perform random checks of the regular andovertime work hours listed on worker pay
slips against timekeeping system records
to make sure that work hours are being
recorded properly.

 Regularly evaluate trends in hiring,production capacity planning, working
hours and other functions and data to help
the supplier meet legal requirements forregular and overtime hours.

 When a situation arises that results in

employees working excessive overtime orwithout a day off, investigate and address
the root causes of the problem to put inplace sustainable solutions to prevent a
recurrence. For example, was it becauseof unexpected circumstances such as arush order or broken equipment, or due
to a more systemic problem, such as raw
material quality issues or high worker
turnover?

 Routinely review complaints andgrievances from workers related to theadministration of the supplier’s work hours
policies and procedures.

– 52 of 64

WORK HOURS ORRECTIVE ACTIONC& SYSTEM REVIEWFor continuous improvement of procedures,
supplier should undertake immediate corrective
and preventive actions, as well as periodic
system reviews. This process includes:

 Conducting root cause analysis of any

 Assigning task owners, milestones, andcompletion dates.

 Monitoring that changes in procedures

have been made and that they produce
the desired result.

 Conducting ongoing periodic senior

management reviews for overall systemeffectiveness.

issues uncovered during monitoring.

 Setting improvement targets anddeveloping both corrective and preventive
actions (modified procedures) to addresseach identified root cause.

Click here for additional resourses
Mars Supplier Code of Conduct Guidebook– 53 of 64

ADDITIONAL RESOURCES SECTION
MANAGEMENT SYSTEMS• International Labour Organization Guidelines on occupational safety and health management systems – ILO-OSH 2001;
http://www.ilo.org/safework/info/standards-and-instruments/WCMS_107727/lang--en/index.htm
 Audit Matrix for the ILO Guidelines on Occupational Safety and Health Management Systems(ILO-OSH-2001):
http://www.ilo.org/wcmsp5/groups/public/---ed_protect/---protrav/---safework/documents/
publication/wcms_214128.pdf• United Nations Global Compact Guiding Principles on Business and Human Rights (pages 13 – 27):
http://www.ohchr.org/Documents/Publications/GuidingPrinciplesBusinessHR_EN.pdf• Social Accountability International: Guidance document for social accountability:
http://www.sa-intl.org/index.cfm?fuseaction=document.viewDocument&documentid=563&docu
mentFormatId=1166&vDocLinkOrigin=1&CFID=16526546&CFTOKEN=a3488158d311bf6b-B50FDD1C1C23-C8EB-803CF412CB1C445B• International Organization for Standardization (ISO) ISO 14001:2015 – Environmental management systems:
https://www.iso.org/publication/PUB100411.html
 ISO 26000:2010 – Guidance on social responsibility:
https://www.iso.org/standard/42546.html
 ISO 20400:2017 – Sustainable Procurement - Guidance:
https://www.iso.org/standard/63026.html
 ISO 45001:2018 Occupational health and safety:
https://www.iso.org/standard/63787.html
 ISO 37001:2016 – Anti-bribery Management Systems – Requirements with guidance for use:
https://www.iso.org/standard/65034.html

Mars Supplier Code of Conduct Guidebook– 54 of 64

ADDITIONAL RESOURCES SECTION
CHILD LABOR• International Labour Organization How to do business with respect for children’s right to be free from child labour: ILO-IOE child labour
guidance tool for business:
http://www.ilo.org/ipecinfo/product/download.do?type=document&id=27555
 Training Manual to Fight Trafficking in Children:
https://www.ilo.org/ipec/areas/Traffickingofchildren/WCMS_111537/lang--en/index.htm• E thical Trading Initiative (ETI):
http://www.ethicaltrade.org/
 ETI - Child Labour:
http://www.ethicaltrade.org/in-action/issues/child-labor Base Code Guidance – Child Labour:https://www.ethicaltrade.org/sites/default/files/shared_resources/eti_base_code_guidance_-_child_labour_web_0.pdf• F air Labor Association (FLA):
http://www.fairlabor.org/topic/child-labor• U
 N Global Compact (Principle 5):https://www.unglobalcompact.org/what-is-gc/mission/principles/principle-5

Mars Supplier Code of Conduct Guidebook– 55 of 64

ADDITIONAL RESOURCES SECTIONCOMPENSATION AND BENEFITS• I nternational Labour Organization:
http://www.ilo.org LO Labour Standards on Wages:
http://www.ilo.org/global/standards/subjects-covered-by-international-labour-standards/
wages/lang--en/index.htm• E thical Trading Initiative (ETI):
http://www.eti.org
 ETI Base Code:
http://www.ethicaltrade.org/resources/key-eti-resources/eti-base-code Living wage: make it a reality:
http://www.ethicaltrade.org/resources/key-eti-resources/living-wage-eti-conference-08briefing-paper• UN Global Compact
 “The Labour Principles - A Guide for Business:”
http://www.unglobalcompact.org/docs/issues_doc/labour/the_labour_principles_a_guide_
for_business.pdf

Mars Supplier Code of Conduct Guidebook– 56 of 64

ADDITIONAL RESOURCES SECTIONDISCRIMINATION• International Labour Organization:
 ILO Helpdesk – Q&As on Business, Discrimination & Equality:
https://www.ilo.org/empent/areas/business-helpdesk/faqs/WCMS_DOC_ENT_HLP_BDE_FAQ_EN/
lang--en/index.htm• E thical Trading Initiative (ETI):
http://www.ethicaltrade.org/
 Women Workers:
http://www.ethicaltrade.org/in-action/issues/women-workers
 HIV/AIDS at Work:
http://www.ethicaltrade.org/in-action/issues/HIVAIDS-at-work• UN Global Compact
 “The Labour Principles - A Guide for Business:”
http://www.unglobalcompact.org/ docs/issues_doc/labour/the_labour_principles_a_guide_for_business.pdf
 UN Global Compact Principle Six:
https://www.unglobalcompact.org/what-is-gc/mission/principles/principle-6

Mars Supplier Code of Conduct Guidebook– 57 of 64

ADDITIONAL RESOURCES SECTIONENVIRONMENT• United Nations
 UN Global Compact – Preserving the Livelihoods of Indigenous Peoples:
https://www.unglobalcompact.org/what-is-gc/our-work/social/indigenous-people UN Global Compact - A Business Reference Guide: United Nations Declaration on the Rights
of Indigenous Peoples:
https://www.unglobalcompact.org/docs/issues_doc/human_rights/IndigenousPeoples/
BusinessGuide.pdf• International Finance Corporation (IFC):
 Performance Standards on Environmental and Social Sustainability (2012):
http://www.ifc.org/wps/wcm/connect/115482804a0255db96fbffd1a5d13d27/PS_English_2012_
Full-Document.pdf?MOD=AJPERES• United States Environmental Protection Agency (EPA) Compliance with Environmental Laws:
https://www.epa.gov/compliance• European Commission
 Environment:
http://ec.europa.eu/environment/index_en.htm
 Eco-Management and Audit Scheme (EMAS):
http://ec.europa.eu/environment/emas/index_en.htm

Mars Supplier Code of Conduct Guidebook– 58 of 64

ADDITIONAL RESOURCES SECTIONETHICS• U
 K Bribery Act:
https://www.legislation.gov.uk/ukpga/2010/23/contents• U
 S Foreign Corrupt Practices Act:
http://www.justice.gov/criminal/fraud/fcpa/• O
 ECD, Good Practice Guidance on Internal Controls, Ethics, and Compliance:
http://www.oecd.org/investment/briberyininternationalbusiness/anti-briberyconvention/44884389.pdf• Transparency International Business Principles for Countering Bribery:
http://www.transparency.org/whatwedo/tools/business_principles_for_countering_bribery/1/
 Business Principles for Countering Bribery – Small and medium enterprise (SME) edition:
http://www.transparency.org/whatwedo/tools/business_principles_for_countering_bribery_
sme_edition/1/
 Business Integrity Toolkit:
https://www.transparency.org/whatwedo/tools/business_integrity_toolkit/0• U
 N Global Compact – Anti-corruption:
https://www.unglobalcompact.org/what-is-gc/our-work/governance/anti-corruption• International Finance Corporation (IFC): Combatting Fraud and Corruption:
https://www.ifc.org/wps/wcm/connect/Topics_Ext_Content/IFC_External_Corporate_Site/
AC_HomeMars Supplier Code of Conduct Guidebook– 59 of 64

ADDITIONAL RESOURCES SECTIONFORCED LABOR• International Labour Organization
 ILO Topics – Forced Labour:
http://www.ilo.org/global/topics/forced-labour/lang--en/index.htm
 ILO Helpdesk – Business and Forced Labour:
http://www.ilo.org/empent/areas/business-helpdesk/WCMS_DOC_ENT_HLP_FL_EN/lang--en/index.htm• C alifornia Transparency in Supply Chains Act:
http://info.sen.ca.gov/pub/09-10/bill/ sen/sb_0651-0700/sb_657_bill_20100930_chaptered.html• V erité Research:
http://www.verite.org/helpwanted/toolkit/• UN Global Compact: UN Global Compact Principle Four: Forced and Compulsory Labour:
http://www.unglobalcompact.org/AboutTheGC/TheTenPrinciples/Principle4.html• U K Modern Slavery Act 2015:
http://www.legislation.gov.uk/ukpga/2015/30/ contents/enacted• B usiness and Human Rights Resource Center: French Corporate duty of vigilance law:
http://www.respect.international/french-corporate-duty-of-vigilance-law-english-translation/

Mars Supplier Code of Conduct Guidebook– 60 of 64

ADDITIONAL RESOURCES SECTION
FREEDOM OF ASSOCIATION• I nternational Labour Organization:
http://www.ilo.org
 ILO Helpdesk - Freedom of Association:
http://www.ilo.org/empent/areas/ business-helpdesk/WCMS_DOC_ENT_HLP_FOA_EN/lang-en/index.htm
 ILO Helpdesk - Collective Bargaining:
http://www.ilo.org/empent/areas/business-helpdesk/WCMS_DOC_ENT_HLP_CB_EN/lang-en/index.htm• Ethical Trading Initiative: Freedom of Association and Collective Bargaining guidance:
http://www.ethicaltrade.org/resources/key-eti-resources/foa-and-cb-guidance Union rights at work:
http://www.ethicaltrade.org/issues/union-rights-work• UN Global Compact: Principle 3: Freedom of Association and Collective Bargaining:https://www.unglobalcompact.org/what-is-gc/mission/principles/principle-3 Human Rights Dilemmas forum:
http://human-rights.unglobalcompact.org/dilemmas/freedom-of-association/

Mars Supplier Code of Conduct Guidebook– 61 of 64

ADDITIONAL RESOURCES SECTIONHEALTH AND SAFETY• International Labor Organization
 ILO Occupational Safety and Health:
http://www.ilo.org/safework/lang--en/index.htm• United States Occupational Safety and Health Administration (OSHA): Safety and Health Topics:
https://www.osha.gov/SLTC/index.html• European Union Agency for Health and Safety at Work http://osha.europa.eu/enMars Supplier Code of Conduct Guidebook– 62 of 64

ADDITIONAL RESOURCES SECTION
ISSUE REPORTING• Harvard University: Rights-Compatible Grievance Mechanisms –A Guidance Tool for Suppliers:

https://sites.hks.harvard.edu/m-rcbg/CSRI/publications/Workingpaper_41_RightsCompatible%20Grievance%20Mechanisms_May2008FNL.pdf• I nternational Labour Organization:
http://www.ilo.org
 Factsheet No. 5 – Grievance Handling:
http://www.ilo.org/wcmsp5/groups/public/---ed_protect/---protrav/---travail/documents/
publication/wcms_622209.pdf• Ethical Trading Initiative: Access to remedy – Operational Grievance Mechanisms:
https://ethicaltrade.org/sites/default/files/shared_resources/ergon_-_issues_paper_on_access_to_remedy_and_operational_grievance_mechanims_-_revised_draft.pdf

Mars Supplier Code of Conduct Guidebook– 63 of 64

ADDITIONAL RESOURCES SECTION
WORK HOURS• I nternational Labour Organization:
http://www.ilo.org
 Working time http://www.ilo.org/empent/areas/business-helpdesk/WCMS_DOC_ENT_HLP_TIM_EN/lang-en/index.htm• V erité:
http://www.verite.org• F or Workers’ Benefit – Solving Overtime Problems in Chinese Factories:
http://www.verite.org/sites/default/files/Chinese_Overtime_White_Paper.pdf• I mpactt:
http://www.impacttlimited.com
 https://impacttlimited.com/wp-content/uploads/2017/01/ImpacttOvertimeReport-1.pdf• Ethical Trade Initiative (ETI): Base Code Guidance: Working hours:
https://www.ethicaltrade.org/resources/base-code-guidance-working-hours
 China Working Hours Briefing:https://www.ethicaltrade.org/sites/default/files/shared_resources/china_working_hours_
briefing.pdf• UN Global Compact: Human Rights Dilemmas forum:
https://hrbdf.org/dilemmas/working-hours/

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