| Developed By: HR, Vendor Management, Procurement |
| Last Updated: 12/10/2025 |
SBM Management Services, LP and all global affiliates (“SBM”) are committed to conducting business with integrity and mutual respect for people and the planet. Included in the SBM Supplier Code of Conduct are standards established to ensure ethical conduct in the workplace, safe working conditions, fair treatment of workers, and environmentally responsible practices. These standards apply to all global suppliers, subcontractors, and service providers (“Vendors”), as well as first- and second-tier subcontractors and other third parties acting on their behalf of Vendors (collectively, “Vendor Agents”), who contribute to the delivery of goods or services to SBM. For clarity, Vendor Agents are any first or second-tier subcontractors, service providers, or other third parties acting on behalf of a Vendor who contributes to the delivery of goods or services to SBM; Vendor Agents are considered extensions of the Vendor for purposes of compliance with this Code.
SBM Vendors are required to remain in compliance with all national, federal, state, and local regulations and laws applicable to their business(es) and must require the same of their Vendor Agents. In all aspects of the working relationship, SBM’s Vendors and their Vendor Agents shall support SBM’s core values by conducting business ethically and with integrity, by protecting human rights and adhering to labor standards, by supporting environmental responsibility, by striving for performance excellence and transparency, and by accepting accountability for their conduct. SBM reserves the right to review and/or audit any Vendor’s compliance with this Code. These requirements represent SBM’s minimum expectations and do not create a contractual obligation unless expressly stated in a written agreement.
SBM has a zero-tolerance policy to prohibit all forms of bribery, corruption, extortion, and embezzlement. These and all forms of illegal or inappropriate activity are strictly prohibited and may result in termination of any or all Vendor agreements with SBM and possible legal action. Bribes or other means of obtaining undue or improper advantage will not be promised, offered, authorized, given, or accepted. This includes offering, promising, giving, authorizing, or accepting anything of value, either directly or indirectly, to obtain/retain business, direct business to any person, or otherwise gain an improper advantage. Records prepared for SBM, such as business dealings, records of time worked, and expenses, shall be accurate, truthful, and complete, and shall meet applicable standards, laws, and requirements.
Except where prohibited by law, programs that safeguard the confidentiality, anonymity, and protection of whistleblowers shall be maintained. Vendors must have a clearly developed and communicated process that enables personnel to raise concerns without fear of retaliation.
All business dealings shall be transparently and accurately recorded and intellectual property rights shall be respected. Standards of fair business, advertising, and competition should be upheld. Vendors must be committed to reasonably protecting the personal data and information of all those they do business with, including customers, employees, Vendor Agents, suppliers, and consumers. Vendors must comply with applicable privacy and information security laws and regulations when personal information is collected, stored, shared, and transmitted.
Vendors should adopt or establish a management system with a scope related to this Code. Vendors must develop policies and procedures around human rights, health and safety, ethics and the environment, as well as due diligence and continual improvement. These policies and procedures should be approved by executive management, communicated throughout all levels of the company to all employees, and managed for compliance.
Within the management system, Vendors should establish a process to identify, monitor, and stay informed on applicable laws and regulations, and customer requirements including this Code. Additionally, Vendors should conduct regular, comprehensive risk assessments, complete with a continual improvement process, to identify potential risks related to adherence with this Code and regulatory compliance.
Vendors are responsible for training employees on established programs and policies applicable to this Code and legal and regulatory requirements. Proper documentation and records shall be maintained, with appropriate adherence to confidentiality to protect privacy. SBM reserves the right to verify adherence to this Code. Vendors are expected to communicate similar expectations outlined within this Code to their own Vendor Agents throughout their supply chains and monitor compliance.
SBM is committed to upholding the human rights of all workers – direct employees, temporary, migrant, student, contract, vendor, supplier, and any other type of worker - and treating them with respect and dignity. SBM Vendors are required to do the same. SBM has a zero-tolerance policy against forced labor of any kind. SBM and all SBM Vendors and their Vendor Agents commit to ensuring that forced labor in any form, including but not limited to indentured labor, involuntary or exploitative prison labor, bonded, debt bonded, slavery or trafficking of persons, transporting, harboring, recruiting, transferring, or receiving persons by means of threat, force, coercion, abduction, or fraud for labor or services, is not permitted.
All work must be voluntary, and all workers must be free to terminate their employment at any time without penalty if reasonable notice is given. Vendors will not hold workers’ identity, immigration, or work permit documents, such as government-issues identification or passport, longer than reasonably necessary for administrative processing or as required by local law. Workers shall not pay recruitment fees or other fees for their employment, either directly or through third parties and Vendors are expected to repay any worker that has paid such fees. Vendors will not unreasonably restrict workers’ freedom to move into, out of, or at working facilities. As part of the hiring process, suppliers are expected to give each worker a written agreement describing the terms of employment in a language understood by the worker, and, if internationally relocating, the written agreement must be provided before they leave their country of origin.
Vendors and their Vendor Agents will not use child labor. “Child” means any person underage 15, under the age for completing compulsory education, or under the minimum age for employment in the country, whichever is greatest. Workers under the age of 18 will not perform work that is likely to jeopardize their health or safety, including night shifts and overtime. Vendors may use legitimate, properly managed apprenticeship programs, such as student internships, if proper documentation is retained and due diligence undertaken to protect the students’ rights in accordance with applicable laws and regulations. Vendors are required to verify the age of all workers through an appropriate mechanism. Unless otherwise addressed by local law, Vendors are expected to pay student workers, interns, and apprentices at least the same wage rates as other entry-level workers performing equal or similar tasks.
Vendors will pay legally mandated wages and benefits, will comply with laws and regulations regarding wage deductions, and will provide workers with timely and understandable wage statements or similar documentation that includes sufficient information to verify accurate compensation for work performed each pay period. Wage deductions as disciplinary measures are not permitted. Workers shall be compensated for overtime pay at rates greater than regular working hour rates, in accordance with local laws and regulations. All workers shall receive equal pay for equal work and qualification. The use of temporary and/or outsourced labor shall comply with local law.
Vendors agree to adhere to all maximum working hours limitations set by local law. All overtime shall be voluntary, and workers should be allowed at least one day off (or more, if required by local law) every seven days. Except in emergencies or unusual situations, for workers paid hourly, workweeks should not exceed 60 hours per week (including overtime)or, if less, the maximum set by local law, or as agreed.
Vendors shall commit to a workplace free of discrimination and harassment. Vendors will not permit harsh or inhuman treatment, including sexual harassment or abuse, corporal punishment, mental or physical coercion, bullying, public shaming, violence or gender-based violence, or verbal abuse of workers. Vendors will not discriminate in screening, hiring, or employment practices based on race, color, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, ethnicity, national origin, caste, disability, genetic information, medical condition, pregnancy, religion, political affiliation, union membership, covered veteran status, or body art. Vendors will provider reasonable accommodation for worker’s religious practices and disabilities. In accordance with the Responsible Business Alliance Code of Conduct and ILO International Labor Standards,
Vendors will not subject workers or potential workers to medical tests (aside from drug screening to the extent permitted or required by law), including pregnancy or virginity tests, or physical exams that could be used in a discriminatory way.
Vendors will ensure that workers and their representatives are able to engage in direct communication with management to share ideas and concerns regarding working conditions and management practices, without fear of discrimination, intimidation, or harassment. Vendors must respect the right of all workers to form and join trade unions of their own choosing, to bargain collectively, and engage in peaceful assembly, while respecting the right of workers to refrain from such activities. Where freedom of association and collective bargaining is restricted by applicable laws and/or regulations, workers should be allowed to elect and join alternative, lawful forms of worker representations tallow for open communication with management or have systems in place that allow for open communication with management.
Vendors to SBM must conform to all applicable health and safety laws and regulations. SBM recognizes that minimizing work-related injuries and illnesses creates a safer, healthier workplace environment for all and as such we expect our Vendors and their Vendor Agents to value workplace health and safety as well.
Vendors shall be committed to the safety and health of workers and shall ensure that potential exposure to health and safety hazards (i.e. chemical, fire, fall hazards, etc.) be identified and mitigated through the establishment of an appropriate environmental health & safety/industrial hygiene program prior to initiating any work activity. Vendors are responsible for addressing and controlling worker exposure to potential safety hazards in conformance with all applicable standards and/or regulations and by utilizing suitable means, e.g., design, educational materials and training, preventative maintenance, work procedures, gender-responsive measures, and appropriate personal protective equipment (PPE). Vendors must provide adequate safeguards against machinery-related risks, e.g., lockout/tag-out mechanisms and interlocks. Vendors shall maintain Material Safety Data Sheets (MSDS) identifying products’ chemical properties, potential health hazards, safe handling and storage procedures, and emergency response measures. Procedures, policies, and systems must be put in place to manage, track, report, and record occupational illnesses and injuries and adhere to occupational illness and injury-related laws and regulations.
Vendors must identify and assess potential emergency situations and events and their impact(s) and develop plans to minimize these impact(s) by implementing emergency plans and/or response procedures, evacuation procedures, emergency preparedness training(s) and drills. Emergency drills should be conducted annually for all shifts and workers or as required by local law, whichever is more stringent. Emergency plans must follow local laws and regulations, and have the goal of minimizing harm to life, the environment, and property.
For physically demanding work, (e.g. repetitive tasks, heavy lifting, prolonged standing, etc.) Vendors should develop plans to control worker exposure to identified hazards. When working around machines, such as production or other machinery, Vendors shall evaluate all machinery for safety hazards, ensure they are properly maintained, train workers, and install proper safety guards to reduce hazards. All workers shall be provided with access to clean toilet facilities, potable water, and sanitary food preparation, storage, and eating areas.
It is paramount that Vendors provide workers with appropriate workplace health and safety training and information in a language they can understand for all hazards they are exposed to. Vendors must properly train workers and post health and safety related information, in accordance with local laws and regulations, and workers should be encouraged to report any health and safety concerns without fear of retaliation.
SBM’s Vendors should identify environmental impacts and aim to minimize adverse effects on the environment and the communities in which we work. Vendors are required to obtain, maintain, and keep current all required environmental permits. Any emissions and discharges of pollutants and generation of waste should be minimized, and the use of natural resources should be conserved. Hazardous substances (e.g. chemicals, waste, or other materials that pose a hazard to humans or the environment) must be identified, labeled, and managed in compliance with local laws and regulations, and all hazardous data must be properly tracked and documented.
Vendors should implement systems to identify, manage, reduce, and recycle waste, including tracking and documenting waste generation and diversion over time. Vendors must comply with local waste management sorting requirements. Vendors should implement a water management program to document and monitor water use and discharge, as appropriate, and seek opportunities to conserve water and reduce contamination. Compliance with all water and waste regulations is mandatory. Air emissions that have been found to be detrimental to the ozone should be managed properly and all air emissions control systems must be routinely monitored in compliance with applicable regulations. Vendors should establish and report against an absolute corporate-wide greenhouse gas reduction goal, tracking and documenting reduction progress covering Scope 1, 2, and 3 greenhouse gas emissions and energy consumption.
Vendors are required to adhere to all applicable laws, regulations, and customer requirements regarding the prohibition or restriction of specific substances in manufacturing or in products, including labeling for disposal and recycling. For manufacturing Vendors, a policy and due diligence process and/or framework must be established to verify the source and chain of custody of minerals from conflict-affected or high-risk areas whenever their products – or those of their suppliers – contain raw materials mined in such regions.
SBM encourages employees, Vendors, Vendor Agents, and customers to report suspected violations to this Code without fear of retaliation. Reports should be submitted through established reporting channels, which have been communicated in writing. Vendors are expected to establish a process to allow for two-way communication with Vendor Agents, workers, representatives, employees, customers, and other stakeholders where appropriate, without fear of retaliation.