CODE OF ETHICS

1. Child Labor

Midwest Mill Co. will not tolerate the use of child labor by its suppliers and/or their subcontractors. ‘Child labor’ is defined as the employment of persons younger than the age of 14, the local legal minimum working age, or the local legal age for compulsory education, whichever is higher (i.e. employees under legal age).  

2. Involuntary (Forced) Labor

B.     Forced overtime without pay or penalty

3. Harassment or Abuse

Suppliers and/or their subcontractors shall treat each of their employees with respect and dignity. No supplier and/or their subcontractor employees shall be subject to any physical, sexual, psychological or verbal harassment or abuse.

 4. Compensation

Wages and benefits must be in conformity with the minimum wage prescribed by local law or the prevailing local industry wage, whichever is higher. Workers must be provided with benefits and overtime compensation that conform to the better of applicable local law or prevailing local industry standards. For example:

A.     Unauthorized deductions from pay
B.     Not paying required benefits
C.     Hourly rates (regular or overtime) below legal limit

5. Age Documentation & Hours

Suppliers and/or their Subcontractors must have documentation proving employees’ age and restrict working hours for juveniles and pregnant women as prescribed by law. For example:

A.     Missing age documents for employees
B.     Unrestricted working hours for women and children
C.     No health check or work registration for juvenile employees

 6. Non-Discrimination

Suppliers and/or their subcontractors must employ workers on the basis of their ability to perform the requisite tasks, and not on the basis of their personal characteristics or beliefs. For example:

A.     Disallowing time for religious ceremony and/or dress code, or any religious discrimination

 7. Laws and Workplace Regulations

Workplace policy of suppliers and/or their subcontractors must adhere to all local laws and Midwest Mill Co.’s code of conduct. For example:

A.     Employment contracts not completed according to law
B.     Employee handbooks not provided according to law
C.     Regulations for Suppliers and/or their Subcontractors not approved by Ministry of Labor/not posted

8. Freedom of Association

Suppliers and/or their Subcontractors must recognize and respect the legal rights of employees to free association. Suppliers and/or their subcontractors must not threaten, penalize, restrict, or interfere with employees’ lawful efforts to organize or join associations of their choosing. For example:

A.     Penalizing employees based on meeting/membership activities

 9. Health and Safety

Suppliers and/or their subcontractors must provide workers with a safe, clean and healthy working environment, as well as living and eating facilities (where applicable), which comply with all relevant local laws and regulations. For example:

A.     Drinking water available 24/7
B.     Safety equipment not available/not being worn (i.e. gloves)
C.     Broken windows/glass
D.     Obstruction of emergency exits
E.     First aid kit violations
F.     Exposed electrical wiring/damaged wiring
G.     Fire hydrants not properly charged and/or expired
H.     Employees not trained in use of fire extinguishers
I.     Plan for fire drill/evacuation not posted
J.     Bathrooms are not clean or properly stocked dormitories
K.     Lock in policy
L.     Glass fire hydrant boxes in dormitories broken
M.     Insufficient hot water for showers (based on local health code)
N.     Bathrooms are not clean or properly stocked

10. Hours of Work/Overtime

Employee work hours must be reasonable and in compliance with local laws and standards with no regularly scheduled work weeks in excess of sixty (60) hours (or lower if prescribed by local law or local industry standards). For example:

A.     Not recording all working hours
B.     Hours allowed by policy/law exceeded

11. Environment

Operations of suppliers and/or their subcontractors must impact the environment as minimally as possible and comply with all relevant local laws and regulations. For example: