A PRACTICAL GUIDE FOR STORA ENSO S SUPPLIERS. June 2015

Transcription

1 A PRACTICAL GUIDE FOR STORA ENSO S SUPPLIERS June 2015

2 Table of contents Introduction 1. Definitions 2. Management systems 3. Human and labour rights 3.1 Human rights 3.2 Basic workers rights 3.3 Wages and working hours 4. Occupational health and safety 5. Environmental impact 6. Responsible business 7. General requirements 8. Enforcement 9. Terminology Appendix 1 Supplier Code of Conduct check list 2

3 Introduction This Practical Guide for Stora Enso s Suppliers (the Guide) is aimed to help Stora Enso s suppliers to interpret requirements and to give practical guidance in how to comply with Stora Enso s Supplier Code of Conduct, which we see as an essential part of being a supplier for Stora Enso. This Guide will give you practical guidance on how you can assess how well you meet our requirements for suppliers, and how to identify potential areas for improvement. If improvements are needed, Stora Enso is willing to co-operate and provide assistance to ensure that favourable practices are developed. We acknowledge that the size, operations and organizations of our suppliers are different, and therefore we are willing to work with you to identify correct and sufficient measures, which enable you to comply with our Supplier Code of Conduct. We understand that our suppliers may need time or assistance to meet our standards, and we are committed to work with suppliers who demonstrate commitment and a willingness to move forward together. Combining our efforts is the best way to make our businesses become more successful and sustainable throughout the supply chains. We make the requirements of the Supplier Code of Conduct in this Guide more hands-on by providing you with examples. Given the broad variety of our suppliers businesses, such examples might fit to your concrete situation better or not so well, this needs to be evaluated in the individual case. On the other hand, we are aware that many of our suppliers have own compliance and sustainability organizations and policies in place. Therefore, we acknowledge and appreciate it to rely on your organizations if you confirm that your rules and organizations fulfil the requirements we outline in our Supplier Code of Conduct, or that those are even more comprehensive. However, we would still need to have rights for seeking information about compliance from you as well as for participating in corrective actions. Therefore, we would always like to reserve our rights as described in chapters 7 and 8 of the Supplier Code of Conduct. The Supplier Code of Conduct is incorporated into our suppliers contracts by attaching it as an appendix to the contracts. To ensure that we are in agreement about implementing the Supplier Code of Conduct in all our mutual business, we are requesting from you the general commitment to the document by signing and reverting to us a letter with the confirmation on the Supplier Code of Conduct. This commitment would then also serve as contractual supplement in case of our individual contracts which do not contain the complete set of appendices. This Guide follows the same structure as the Supplier Code of Conduct, with eight different chapters: Definitions, Management systems; Human and labour rights; Occupational health and safety; Environmental impact; Responsible business; General requirements; and Enforcement. If you need further clarification on the terms used in the Supplier code of Conduct or this Guide, please refer to the terminology chapter at the end of the Guide. As we seek to improve our processes and this Guide, we wish to receive feedback from you. If you have any questions or require additional support with any parts of the Supplier Code of Conduct or implementation of the requirements, please do not hesitate to contact us.

4 1 Definitions The first chapter in the Supplier Code of Conduct is about the definitions 4

5 1. Definitions A Supplier is any person or legal entity which provides Stora Enso with products or services. In addition to Suppliers who have a direct contractual relationship with Stora Enso, this definition also includes the Suppliers sub-suppliers. Stora Enso Representatives include the company s employees and legal representatives. 5

6 2. Management systems The second chapter in the Supplier Code of Conduct is about the management systems

7 2. Management systems The Supplier shall have appropriate management systems in place to enable adherence to this Supplier Code of Conduct or its own equivalent code of conduct, whichever is stricter, as well as all other relevant and applicable laws and regulations. The functioning and quality of the management system shall be in proportion to the size, complexity and risk environment of the Supplier s business. A management system here means a framework or processes used to ensure that an organisation can fully achieve its objectives and improve its performance and act according to laws and regulations. It is a description how the organisation works; organisation chart including roles and responsibilities; the main processes and their links to each other, and target setting and monitoring of the performance; key documents and the instructions. A management system may be manually documented and maintained, or supported using IT tools. The quality and exact functioning of your management system will depend on the nature and size of your operations. A complex, global operation with many employees and potential risks will require an advanced management system. As an example, management systems which are based on standards like ISO 9001, ISO 14001, OHSAS and/or SA 8000 can give a frame and structure to the requirements of the Supplier Code of Conduct, unless there are special circumstances which would need further evaluations. A privately-owned one-man or relatively small enterprise will only need a lighter approach. As an example the supplier should be able to describe, and show applicable evidences and documents, which shall demonstrate how the requirements of the Supplier Code of Conduct are taking into account in the operations. The most important thing is that a suitable management system should be in place to help you as a supplier to improve your performance and control your operations. 2.1 The Supplier shall adopt a systematic approach to the assessment, mitigation and management of risks related to human and labour rights, occupational health and safety, responsible business and environmental impact (hereafter referred to as Code of Conduct Issues ). You should be aware of the impacts and risks of your operations on occupational health and safety issues; responsible business; environment and the human rights of your employees, suppliers, business partners and neighbouring communities. You should systematically and in a reasonable manner document assessments, and mitigations plans, which are regularly reviewed by the senior management of your company.

8 2. Management systems 2.2 The Supplier shall adopt measurable performance targets in relation to Code of Conduct Issues and define related actions to reach these targets with a view to ensure continuous performance improvement. We also encourage our suppliers senior management to take responsibility for setting of measurable targets based on the Supplier Code of Conduct issues. Such targets can be shared with Stora Enso where this is appropriate. Your management can assign persons to be responsible for individual issues and targets. Senior management is also responsible for the regular review of the performance to ensure that targets are reached and improvements are made. The regular, systematic review of the performance ensures that the supplier is making progress and continuous improvement. 2.3 All applicable laws, regulations and contractual terms governing the Supplier s assignments shall be duly applied and communicated, with sufficient training provided to relevant employees and business partners. At Stora Enso we are committed to fully follow all applicable legislation wherever we operate, and we expect our suppliers to do the same. Where legal provisions are absent or unenforced, we expect you to follow our Supplier Code of Conduct, as explained in this Guide, and to notify us if any conflicts or potential conflicts with legal implications arise. We encourage suppliers to systematically keep and update any documents, records, permits and licenses that may be needed when audits or other assessments are performed. For you to follow Supplier Code of Conduct effectively all of your employees will need to understand the requirements set out in the Supplier Code of Conduct and in this Guide. We therefore expect you to provide sufficient training on these issues. If you feel you do not have sufficient knowledge or personnel to conduct such training, you should contact Stora Enso for assistance. 8

9 2. Management systems 2.4 The Supplier shall have systems in place to enable the reporting of Code of Conduct Issues-related grievances (e.g. a whistle-blowing system). This means that all of your employees (permanent, temporary or contracted) and the employees of your relevant business partners must have an opportunity to formally report work-related grievances and any breaches against your policy documents or the Supplier Code of Conduct. Such processes should preferably be anonymous, and in all cases without fear of retaliation. Also, they must be in accordance with all relevant and applicable legal requirements. Confidential and anonymous grievance channels may vary from sophisticated internet-based channels to a more simple mail box. The most important thing is that all employees should be aware of their opportunity to report their concerns promptly through effective channels. In case of grievances related to Stora Enso, we expect you to report these to us promptly so we can initiate any necessary actions. You must respect the privacy of all employees in accordance with applicable privacy related laws and regulations. We do not accept workplace monitoring or collection of employee personal data without the knowledge of employees. 9

10 2. Management systems 2.5 The Supplier shall duly ensure and monitor that its own suppliers and sub-suppliers comply with this Supplier Code of Conduct or their own equivalent code of conduct. The Supplier is liable for the performance of its sub-suppliers as for its own work. Companies operate in a complex world among many different stakeholders with various interests. It is not sufficient to manage only our own operations; we also need to take into account the surrounding communities, our business partners, non-governmental organisations and other stakeholders. For this reason we also require our suppliers to monitor their own suppliers and sub-suppliers, for example through contractual sustainability requirements, on-site audits or site visits. We need to make sure that all of the stakeholders involved in our supply chain know about the requirements as set in the Stora Enso s Supplier Code of Conduct, or supplier s own code of conduct, and how we can work together effectively and responsibly. You should communicate the requirements as set-out in the Stora Enso s Supplier Code of Conduct, or in your own code of conduct, effectively and explain why it is important to follow them. You may consider devising your own code of conduct or your sub-suppliers code of conduct, if such meet the requirements according to Stora Enso s Supplier Code of Conduct, and then require your business partners to adhere to it. You should encourage your suppliers to learn more about the important issues in your code of conduct and/or Stora Enso s Supplier Code of Conduct. Make sure that your monitoring approach ensures that materials you provide to us or use to manufacture components, parts, or products; or services should be sourced from environmentally and socially responsible sources only. Materials and services, which either directly or indirectly contributes to conflicts, are unacceptable. As relevant, you must exercise due diligence regarding the source and chain of custody of the materials and services you provide/use and make any due diligence measures available upon request. 10

11 3. Human and labour rights The third chapter in the Supplier Code of Conduct is about the human and labour rights

12 3. Human and labour rights The Supplier is required to respect human rights and not be complicit in human rights violations within its sphere of influence. Human rights must always be respected across all your operations and your relationships with business partners and other stakeholders who might be impacted by your operations. This includes your own employees, those of your sub-suppliers and business partners, as well as people in surrounding communities. All applicable and relevant laws must be fully respected, together with the requirements listed below on workers basic rights, wages and working hours, occupational health and safety, environmental performance and responsible business practices. These requirements equally apply to all your employees including permanent, temporary, onsite contractors and agency workers, as well as piece-rate, salaried, hourly paid, legal young workers (minors), part time, night, and migrant workers. In addition to labour rights, suppliers should also take into account human rights impacts related to: Environmental and social impacts on surrounding communities affecting their health, livelihoods, access to clean water, education, community and cultural life. Acquisition, renting and leasing of land or property without adequate fee, prior and informed consent or adequate compensation to affected people. Improper displacement or resettlement of neighbouring communities, including indigenous people, ethnic minorities and other possible vulnerable groups, to support activities of the supplier. This includes harmful environmental and social impacts resulting from establishment of new operations, expansion or reduction of existing operations and termination of operations. Potential improper treatment of people working on supplier sites of operation or neighbouring communities by security personnel employed by or acting on behalf of the supplier. Adverse human rights impacts resulting from the use and disposal of the supplier s products or services Non-resolution of grievances filed by neighbouring communities related to adverse impacts resulting from supplier operations. All suppliers should understand what human rights are, and how they apply within their business contexts. Periodic systematic assessments of your actual and potential human rights impacts will support you in this respect. We also strongly recommend you to commit to the UN Guiding Principles on Business and Human Rights.

13 3. Human and labour rights The Supplier is required to duly map its human rights impacts whenever the need for such action is agreed. You should be aware of the impacts of your operations on the human rights of your employees, suppliers, business partners and neighbouring communities. When you and Stora Enso have separately agreed on such a process, you should submit systematically documented assessments of human rights related impacts to Stora Enso. Regardless of any agreement, you should always systematically assess, mitigate and manage human rights impacts as described in chapter The Supplier is required to have in place adequate remedial mechanisms in case of any human rights violations. You must effectively prevent any adverse impacts on human rights within your sphere of influence. In cases where adverse human rights impacts occur in spite of all your efforts, remedial mechanisms and corrective actions need to be in place for prompt implementation. If necessary, external organisations may be brought in to help implement and monitor such remedial measures. 13

14 3. Human and labour rights 3.2 Basic workers rights The Supplier is required not to employ any workers below 15 years (14 years in certain developing countries) or the minimum age according to national legislation, whichever is higher (in line with the ILO Convention 138 on child labour). We do not accept child labour anywhere along our supply chain. This includes both our direct suppliers and any sub-suppliers. You must not employ any person aged below the minimum age of 15 years (or 14 years for certain countries), or anyone under the minimum age for employment in the country, whichever is highest in line with ILO Convention 138 on minimum age for admission to employment. You are expected to have robust age verification procedures and records in place, to ensure that no underage persons work in your operations (including your own employees and contracted workers). The worst forms of child labour as covered by ILO Convention 182 on the worst forms of child labour, which include slavery and trafficking of children, child prostitution and the use, procuring or offering of a child for illicit activities are particularly strictly unacceptable anywhere in our supply chain. Even if these issues are not present in your own operations as a Stora Enso supplier, it is important to understand the risks of this type of child labour among your suppliers and sub-suppliers, and to emphasise that you totally prohibit such practices. If in spite of your efforts it becomes evident that a child or underage person has been employed in your operations or those of a sub-supplier, we expect you to inform us of the situation immediately. Such cases should be handled together with experienced personnel in order to make sure the correct actions are taken and the rights of children and underage persons are protected. We also strongly recommend you to commit to the Children s Rights and Business Principles developed by UNICEF, the UN Global Compact and Save the Children The Supplier is required to ensure that employing young people above minimum age but under 18 years does not jeopardise their education, health, safety or morals. We support the use of legitimate workplace apprenticeship programmes which comply with all relevant laws and regulations. All young workers below the age of 18 but over the minimum age as mentioned above must be protected from performing any work that is likely to be hazardous, that interferes with their education, or that may be harmful to their health or physical, mental, social, spiritual or moral development. 14

15 3. Human and labour rights The Supplier is required to fully recognise employees right to organise, belong to a union and bargain collectively. Workers should have the right to join or form trade unions of their own choosing, and to bargain collectively, without prior authorisation from suppliers management. You must not obstruct or prevent such legitimate activities. If you operate in an area where the right to freedom of association and collective bargaining is legally restricted or prohibited, you may not hinder any other forms of independent and free workers representation and negotiation that arise. We expect that you will never penalise or discriminate against worker representatives or trade union members because of their links with a trade union, or their legitimate trade union activity, in accordance with international labour standards. You must also give worker representatives access to the workplace in order to carry out their representative functions. These provisions are in line with ILO Conventions 87 and 98 on Freedom of Association and Collective Bargaining. 15

16 3. Human and labour rights The Supplier is required not to use any forms of involuntary labour. We do not accept any use of forced, bonded, indentured labour or other forms of involuntary labour. All work, including overtime work, must be voluntary, and workers must be free to leave employment on reasonable notice. Workers must not be required to surrender any governmentissued identification, passports, or work permits as a condition of their employment. Third-party agencies providing workers must also comply with these provisions and related laws. All documents relating to employment relationships should be available to employees, and explained accurately in a language understood by the worker whenever possible. This requirement is to ensure that suppliers activities respect ILO Conventions 29 and 105 on Forced and Compulsory Labour. All forms of human trafficking are unacceptable to Stora Enso. This includes the transportation, harbouring, recruitment, transfer, or receipt of any persons by means of threat, force, coercion, abduction, fraud, or payments to any person having control over another person for the purpose of exploitation The Supplier is required not to discriminate against any employees. Discrimination based on race, colour, age, gender, sexual orientation, ethnicity, disability, religion, political affiliation, union membership, national origin, marital status or any other such characteristics during any part of any employment relationship (hiring, compensation, benefits, advancement, discipline, termination, or any other employment practices) is not acceptable to Stora Enso. We expect you to treat all individuals, regardless of their position within your organisation or your suppliers organisations with due respect and without any discrimination (ILO Conventions 100 and 111 on Discrimination). 16

17 3. Human and labour rights The Supplier is required to treat all employees fairly and respectfully. All forms of unfair and inhumane treatment of workers, including bullying, abuse or harassment, are absolutely unacceptable to Stora Enso. We expect you to provide workers with access to clean toilet facilities, potable water, and hygienic food preparation and storage facilities. Any accommodation provided to employees by you or a third party on your behalf must be clean and safe, offer reasonable personal space, and be fitted with adequate emergency exits, heating and ventilation. Employees with family responsibilities such as dependent young children and aged parents under their care might require some flexibility in their working arrangements. Stora Enso recommends suppliers to allow for flexible working arrangements to ensure equal opportunities for employees with family responsibilities. 3.3 Wages and working hours The Supplier is required to pay employees at least the minimum wage and applicable overtime wages defined by national laws or any applicable collective agreements. You must fully observe all laws and regulations relating to minimum wages, overtime wages, piece rates, and other elements of compensation including legally defined benefits (such as social insurance, parental leave benefits, paid annual leave etc.). We also urge our suppliers to ensure that their employees wages and benefits are sufficient to meet the basic needs for employees and their families / legitimate dependents. We require suppliers to keep adequate records of the wages and social security fees they pay. 17

18 3. Human and labour rights The Supplier is required to apply normal working hours that comply with applicable law and collective agreements, and where no such laws or collective agreements exist working hours will not exceed 48 hours per working week on a regular basis. All applicable working hour requirements defined in local laws and regulations must be duly followed. Employees weekly working hours must never exceed 60 hours, including overtime, except in emergency or exceptional situations. All overtime work should be voluntary, and workers should have at least one day off in each calendar week. We expect our suppliers to keep verifiable working time procedures and records, including records of overtime hours, for all of their employees. Practices such as double bookkeeping on working hours are unacceptable The Supplier is required to provide all employees with at least one rest day in seven consecutive working days unless regulated otherwise by applicable laws. Every one of your employees must have at least one rest day (a continuous period of not less than 24 hours) in every seven consecutive days. 18

19 4. Occupational health and safety The fourth chapter in the Supplier Code of Conduct is about the occupational health and safety

20 4. Occupational health and safety Safety is a top priority for us at Stora Enso. In many locations we share the same workplace with many of our suppliers, where we must all operate according to the same safety principles and rules to ensure that everyone works and gets home safely every day. This is why we expect you as a Stora Enso supplier to share and meet the following occupational health and safety (OHS) principles and rules together with us. 4.1 The Supplier is required to fulfil all applicable legal occupational health & safety (OHS) requirements. We expect you as our supplier to be fully aware of all the legislative OHS requirements that are relevant to your operations, and fulfil them strictly. 4.2 The Supplier is required to have a written OHS policy of its own, to demonstrate management s commitment to OHS, and to assign responsibility for OHS within its organisation. In your written OHS policy, your top management should communicate the importance of a healthy and safe workplace to all of your employees. Your policy should also express your management s intent to promote health and safety. It is not possible to manage a company s OHS issues successfully without strong support from top management level. Your managers should visibly and pro-actively demonstrate their commitment to health and safety through their own actions. We expect that responsibility for OHS issues should be clearly assigned to specific people within your organisation. Overall responsibility for OHS must be given to a named person, and all your employees should know who this person is. All employees must also be made aware of their own roles and responsibilities concerning OHS issues through regular training.

21 4. Occupational health and safety 4.3 The Supplier is required to ensure that operational controls such as rules and procedures are in place and communicated to all employees. Suppliers are required to carry out Hazard Identification and Risk Assessments and to determining controls. Hazard Identification, Risk Assessment and controls are the basic key elements of the OHS management. Hazards must be identified and risks evaluated in all work areas and in all work types. The risk assessment must include all health and safety issues relevant to the work, including mechanical, biological, chemical, psycho-social and ergonomics risks. The risk assessment must contain: evaluation/prioritization of risk (e.g. impact x likelihood assessment) and corrective actions or measures to remove / mitigate / control the risk. As one example of OHS risk mitigation and controls, a special attention has to be paid to controlling that appropriate Personal Protective Equipment (PPE) are available and used by its employees. 4.4 The Supplier is required to have emergency preparedness and response procedures in place. Your written and well communicated procedures should be designed to respond to emergencies such as fires, explosions, chemical spills, natural disasters, medical emergencies or any other emergency situation that might arise in your operations. You should have sufficient capacity to provide first aid as necessary, in the shape of readily available first aid equipment and suitably trained staff. It is essential to hold regular drills to practise emergency responses. Emergency procedures are needed to ensure that in any case of emergency everyone immediately knows what actions they need to take to control the situation as soon as possible and limit any damage.

22 4. Occupational health and safety 4.5 The Supplier is required to increase its employees awareness of health and safety issues, to enhance safety culture through open communications, and to ensure that its staff has received appropriate OHS training. You are expected to provide your staff with regular training on relevant OHS issues. You should also issue regular communications on OHS matters to increase awareness. OHS rules and procedures will not be effective if your employees are not aware of them. Your OHS training sessions should be designed to ensure that everyone knows the risks and the correct way to work safely, and to build up a pro-active safety culture in all workplaces. To build up a healthy and safe workplace all of your employees should be engaged in the continuous improvement of OHS. Employees often have the best understanding of working methods and they are also often best able to find solutions to improve safety. To improve company-wide awareness and communications on safety issues it is worth establishing a forum to exchange information between employees and management on issues including unsafe incidents, safe working methods, up-coming regulation or training.

23 4. Occupational health and safety 4.6 The Supplier is required to measure and monitor its OHS performance and OHS hazards with the help of properly conducted workplace inspections and audits. The Supplier is required to measure the OHS performance. The company must follow up OHS performance using suitable metrics such as number of incidents and accident rates. The regular follow-up of OHS metrics is needed to evaluate the effectiveness of OHS rules, procedures and other measures such as training and communication (i.e. are the accidents increasing or decreasing). Typical OHS metrics are for example statistics on Total Recordable Incidents (TRI) and Lost Time Accidents (LTA) rates, number and type of incidents (near-misses, accidents), absenteeism or attendance %. The Suppliers are required to monitor the OHS hazards and to carry out workplace inspections and audits Employees must identify risks before starting to work. The supervisors must follow up that all safety rules and procedures are followed in daily work. All work has to be planned beforehand to ensure that the work can be done is a safe way The company has to ensure that OHS rules and procedures are followed in daily work and that the physical conditions are safe by carrying out regular safety inspections and audits. The audits are important because the audit results give systematic information on the areas of strengths and opportunities for improvement. 4.7 The Supplier is required to report and investigate all health and safety incidents. All accidents and near misses in your operations must be properly recorded and investigated. Concrete corrective actions must always be defined, and their implementation must be followed-up. To define the right measures needed to eliminate the root causes of accidents you need to keep accurate detailed records on the number and nature of near misses and accidents. Corrective actions must be realised as soon as possible to prevent similar accidents in future. Suppliers which are operating in localities within Stora Enso s sphere of responsibility such as inside one of our mills, or in our harvesting, logistics service or tree planting sites are also required to report all accidents to Stora Enso.

24 5. Environmental impact The fifth chapter in the Supplier Code of Conduct is about environmental impacts 24

25 5. Environmental impact Stora Enso strives to comply with and when possible, go beyond the requirements of all applicable environmental legislation and regulations. We are committed to systematic environmental protection throughout our operations. We strive to ensure that our operations and products have superior environmental performance throughout their life cycles, and we expect our business partners and suppliers to do the same. By utilising our expertise in renewable and recyclable materials and by using resources efficiently we can together create products and solutions that promote sustainable living. As our supplier you play an important role in enabling this to happen. We believe that many solutions on climate change and environmental challenges will be based on the use of renewable raw materials, and on cleaner and more energy-efficient production processes. Our ultimate Vision Zero of a company with no waste-to-landfill, no harmful air emissions, and no wastewater discharges is challenging, and helps us to take steps in the right direction, also along our supply chain. Effective ways to reduce your environmental impacts include: Assignment of responsibilities for environmental management in your company, starting from the top. Responsibilities for environmental issues should follow the management organisation in your company and be clearly documented and communicated to managers and workers on all relevant levels. Identification of all aspects of your organisation s activities, products or services that could have environmental impacts. For these environmental aspects you should define procedures or instructions to ensure they are managed responsibly. Setting of targets for improvements in environmental impacts, suitably defined with regard to the potential environmental impacts of your company, and backed by environmental programmes specifying the measures, resources and responsibilities needed to reach these targets. You should continuously monitor progress towards the achievement of these targets, and duly adapt the related programmes at least annually. These targets will provide the basis for your commitment to continuous improvement in environmental performance, which must be the overarching objective of your environmental policies. To manage all the relevant environmental aspects of your operations we recommend implementing a formal environmental management system relevant to the size and scope of your operations. For example following the systematics of the internationally recognised environmental standard ISO or EU s Eco Management and Audit Scheme (EMAS) will greatly help you to meet the requirements of our Supplier Code of Conduct or your own code of conduct.

26 5. Environmental impact 5.1 The Supplier is required to fulfil all environmental requirements defined in relevant laws, regulations and environmental permits. We require you to comply with all legal and official environmental requirements affecting your operations. You should have adequate processes in place to ensure that your employees are aware of these requirements and that you can continually comply with them. All of your obligatory operating permits must be valid, and you must fully meet their conditions. You should maintain a process to identify all the legal and other environmental requirements that you must meet. You should also work in close co-operation with legal experts whenever you need to communicate on related instructions and procedures, especially in response to changing legal or official requirements. We encourage you to identify the needs and requirements of your different stakeholders in relation to environmental impacts. Important stakeholder groups include the authorities, non-governmental organisations, the media, trade organisations, customers, partners and your own personnel. It is important to ensure that: Information sources are identified. Legal requirements are identified. Other requirements are identified. Interpretations of various requirements are conducted. Responsibilities for compliance are clarified. 5.2 The Supplier is required to assign responsibility for environmental issues within its organisation. Responsibilities for environmental issues must be clearly assigned to specific members of your personnel with appropriate qualifications and adequate resources. Responsibilities do not only concern employees involved in leading and coordinating environmental management. They also affect any employee working issues which directly or indirectly affects identified with environmental aspects of your operations. A clear chain of command is needed to ensure that procedures and instructions are followed. All relevant environmental aspects need to be handled properly; and all the relevant environmental legislation and regulations must be fully observed. You should establish and regularly update pprocedures and instructions covering any significant environmental aspects of your operations, especially those linked to legal requirements.

27 5. Environmental impact 5.3 The Supplier is required to ensure that its employees have appropriate knowhow and experience in relation to environmental issues, as well as resources to enable them effectively to meet their responsibilities. Your employees who directly or indirectly affect the environmental aspects should have the appropriate know-how and experience to understand the issues concerned. They should also be fully aware of what is expected from them. You should provide the right information and training for all of your employees. Your management representatives should also be duly trained and capable of leading your employees on these issues. We recommend that you regularly evaluate training needs and development plans for all of your employees working with issues which directly or indirectly affects identified significant environmental aspects. It is also worth regularly assessing the outcomes of such training. 5.4 The Supplier is required to ensure that written instructions covering all processes with potential environmental impacts, such as the storage and handling of hazardous materials, are available and that the relevant information is communicated to all employees involved. It is worth performing an environmental risk assessment of your operations, to help you pro-actively address any aspects that could potentially have a significant impact on the environment. This will enable you to create a documented register of the significant environmental aspects of your operations. You should consider all environmental aspects of your processes, products and services, including: Direct environmental impacts, e.g. discharges to water and air; noise; waste and residuals generated; consumption of power and heat, materials and chemicals; restoration sites and related liabilities; as well as your use of natural resources including land. Indirect environmental impacts, e.g. impacts generated by your suppliers or service contractors, or during transportation, product handling and packaging.

28 5. Environmental impact Assessments of your environmental aspects should be maintained and periodically updated, since various developments such as new investments or changing processes can have a significant effect on the related environmental impacts. Your identification of environmental aspects should form the basis for related procedures including: Defining your organisation, responsibilities, authority and resources (including human resources, specialized skills, technical capacity and financial resources) Manuals and working instructions Operational controls Communicating your demands to your employees and your own suppliers and contractors Keeping records and documentation Below are listed some examples of aspects of your operations that are likely to result in significant environmental impacts. It is worth having written procedures and instructions in place on all these issues as necessary: Energy efficiency We are committed to continuously improving Energy Efficiency or our operations. We expect our suppliers to support us in this effort by for instance offering energy efficient products and services and implement needed procedures to improve energy efficiency of their own operations. When relevant, energy efficiency work can be included into the environmental management system or follow other internationally recognised standards, such as ISO

29 5. Environmental impact Managing wastes and residuals: Make sure all containers for wastes and residuals containers are clearly marked to avoid misunderstandings when it comes to the disposal, reuse and recycling of these materials. Ensure enough containers are available to avoid the mixing of waste that would be recyclable. Ensure that all hazardous wastes are safely stored and that you contract licensed suppliers for their transportation and final treatment. If you have any liquid hazardous wastes, make sure they are stored in such a way that they cannot leak into the surroundings. Make sure you have an effective traceability system for all your waste, to help you meet your responsibilities regarding the safe disposal of wastes and your reporting obligations. Keep good records of the amounts of waste and residuals you generate, and monitor the related trends. This can help you to reduce both your costs and your environmental impacts. Air emissions: Make sure you have procedures and instructions in place for anyone operating equipment related to energy production and consumption. These should duly cover the monitoring of energy use, the maintenance of equipment, and related reporting. If you have air emission abatement equipment such as filters, scrubbers or cyclones, make sure that they are inspected systematically and regularly to ensure they perform effectively. Water discharges: If you have your own wastewater treatment system you should make sure that it is functioning well at all times. You will also need to understand how your wastewater discharges affect the recipient water body, whether it is a lake, a river or the sea, or a municipal wastewater treatment facility. Make sure that you have procedures in place to manage and control all water discharges effectively. This will help you to optimise the related monitoring, treatment processes, equipment maintenance and reporting.

30 5. Environmental impact Water use: It is important to be aware where the water that you use comes from. If you operate in an area where water is considered as a scarce resource, you should inform your Stora Enso key contact, and actively find ways to: Introduce new work procedures or processes that will reduce your water consumption. Work with other stakeholders using the same water source to reduce total water consumption. Chemicals: You should maintain effective system/systems covering the purchasing, production, storage, handling and disposal of chemical substances and products with regards to safety issues and environmental impacts. Below are some examples of useful procedures for this purpose: Keep updated safety information for all chemicals including those manufactured on site. Make sure that the MSDS/SDS sheets you obtain from your suppliers are up to date. Ask for new sheets if the ones you currently have are more than 3 years old. Keep your staff well informed on the OHS and environmental impacts of the chemicals you use, and provide them with regular training about chemical safety. Make sure that all chemical products used or manufactured in your operations and processes comply with legal labelling requirements, including the global GHS information system or the related European CLP system. Make sure that procedures for the handling and unloading of chemicals are clear both to your own personnel and to your suppliers. Make sure that chemical storage tanks and containment facilities are dimensioned as required and regularly inspected to identify any risk of spillage. Risk assessments should be run regularly wherever chemicals are used. Remember to keep documented records on spillages, tank maintenance and chemical disposal. Review your system(s) regularly (at least once per year), particularly to find out whether any MSDS/SDS sheets are out of date Implement any new handling information from updated SDS sheets into your operations All chemicals used in food contact applications should be approved and safe.

31 5. Environmental impact 5.5 The Supplier is required to proactively work to prevent emergencies and ensure the capacity to react appropriately to such events, by analysing, identifying and adopting suitable preventive and corrective measures. You should have effective systems in place to prevent emergencies. Train your employees to identify and manage risks pro-actively. Emergency plans should be duly established with procedures and equipment that enable rapid responses to any environmental emergencies or accidents. These plans should include measures designed to prevent negative environmental impacts and channels that enable rapid communications to any third-parties who may be affected. Make sure that you regularly review your emergency plans and revise your procedures with regard to any newly identified risks or recent accidents or incidents.

32 5. Environmental impact 5.6 The Supplier is required to handle environmental violations and complaints systematically and communicate them to employees and external stakeholders, including Stora Enso if affected. You should have a system in place enabling you to realise both preventive and corrective actions. The related procedures should not only consist of analysing cases of non-compliance; since it is also important to assess near misses to help you avoid possible future incidents. It is also important to inform everyone in your organisation about the causes of any infraction or near miss, to enable them to act accordingly in future. You should define procedures and assign responsibilities for related communications. Such communications should reach interested external stakeholders (including the authorities, local communities, non-governmental organisations and your suppliers, contractors and customers) as well as your internal stakeholders (your employees, owners and related companies). Systematic procedures for dealings with internal and external stakeholders should include regular assessments of whether needs and requirements are being fulfilled. Such work may incorporate the use of appropriate communication tools including online social media. 5.7 The Supplier is required to provide Stora Enso with up-to-date material safety data sheets (MSDS or SDS), as applicable, and any other relevant documents and information requested by Stora Enso. You should take a systematic approach of dealing with MSDS/SDS sheets for chemicals. We expect our suppliers to maintain and update SDSs for any of their products delivered to Stora Enso. You should also have a system that ensures you receive updated SDSs from your own suppliers, as the information they contain is vital for your own environmental and OHS work. In case MSDS/SDS which is only linked to the chemical products/articles is not relevant for you as a supplier, this clause only applies to other relevant documents and information.

33 6. Responsible business The sixth chapter in the Supplier Code of Conduct is about the responsible business 33

34 6. Responsible business Responsible Business means that you are expected to act ethically and comply with all applicable laws, regulations and voluntary commitments whenever and wherever doing business with us and require the same compliance throughout your entire supply chain. The Supplier is required to conduct its business in full compliance with Stora Enso s Business Practice Policy or the Suppliers own equivalent ethical rules, whichever are stricter. Working for Stora Enso means that you have to conduct your business in line with ethical rules on business conduct that are equivalent to Stora Enso s own rules expressed in the Stora Enso s Business Practice Policy. If you are uncertain what that means for your particular assignment, please raise the question with your contact person within Stora Enso. If you have other equivalent ethical rules you can continue to apply them instead of the Stora Enso Business Practice Policy. Please note that this exception applies only if your own ethical rules in all aspects are as stringent as the rules Stora Enso applies. From a contractual point of view, this means that breaches of the rules of responsible business in chapter 6 of the Supplier Code of Conduct will be regarded as a breach contract between your company and the Stora Enso company with whom you have business relationship. You can ask the Business Practice Policy from your Stora Enso contact, or you can find Stora Enso s Business Practice Policy at: The Supplier is required to conduct business in full compliance with all applicable antitrust and fair competition laws. Stora Enso is committed to free and open competition in markets. We believe every company should have the freedom to trade and compete as they wish, as long as they follow applicable laws and regulations. We expect you to make the same commitment, and never become involved in fixing prices in the sharing of confidential information between competitors, or in any other unfair or restrictive business practices. 34

35 6. Responsible business 6.2 The Supplier is required to prevent situations where there is a conflict of interest between the Supplier and Stora Enso, You should avoid situations, in which personal interests, outside activities, external interests or relationships may have an effect on your ability to fulfil your obligations towards us. As an example a conflict of interest could arise when you are involved in some other activities or contractual arrangements with other parties, have significant ownerships and powers in other companies, which relationships could influence in your decisions or work for us, and make it difficult for you to make decisions or provide services or products with the content or in a form that serves the best interests of Stora Enso. For the avoidance of doubt, this does not restrict you freedom to compete in the market and to contract with other customers, and negotiate your business relationship with Stora Enso. Working for companies other than Stora Enso is not a conflict of interest, unless you have made a specific separate agreement that directly restricts your ability to act freely in your business relationship with us. We expect you to inform us of any situation that could possibly be seen as resulting in a conflict of interest. 6.3 The Supplier is requested to act in compliance with all applicable anti-corruption laws, by, among other things, refusing to receive or offer bribes, facilitation payments or anything of value for the purpose of obtaining or retaining business or any improper benefit or advantage. We have a zero tolerance approach to corrupt practices of any kind, and it is also our policy to require all suppliers who work with Stora Enso or on Stora Enso s behalf to strictly follow this same principle. This means that you must not offer, give, receive, or solicit any Bribes, Facilitation Payments or other means to obtain any improper benefit or advantage. Additionally you must not allow any other party to make improper payments to your benefit. It is important to remember that offering or accepting Gifts, Hospitality, or payment for Expenses is prohibited where they are of unreasonably high value, or could inappropriately affect business transactions. Our requirements on Gifts, Hospitality and Expenses in relation to Stora Enso employees are further explained below. 35

36 6. Responsible business 6.4 The Supplier is required to act in compliance with all rules and regulations related to the safety and quality requirements of products and services, including rules defined by Stora Enso. As our supplier you must always act in full compliance with all applicable laws and regulations. In addition, you should always comply with other safety, security and quality policies, regulations and standards, with amendments, as agreed and set out in the contract between us. Stora Enso has defined rules to ensure safety and protection of environment in its operations and at its premises, which rules you should also adhere to. As an example, when you enter into our premises or facilities you should always familiarise yourself and adhere to safety and environmental instructions of that site. We require all our suppliers to deliver quality products that offer a high level of safety, reliability and environmental performance. In particular, all suppliers are expected to comply fully with all standards defined to prevent, identify and correct safety defects. 6.5 The Supplier is required to transparently and accurately record and disclose details of its business activities, corporate structure financial situation and performance in accordance with applicable laws and regulations. We expect you to truthfully and accurately as defined by applicable law disclose information regarding your business activities, structure, financial situation and performance in accordance with all applicable laws, regulations and prevailing industry practices. For this purpose you will need to maintain transparent and up-to-date financial records as well as records that enable you to demonstrate compliance with all applicable regulations. 36

37 6. Responsible business 6.6 Stora Enso Representatives shall always pay for their own travel and accommodation costs when visiting the Supplier, conferences, reference plants etc. 6.7 Stora Enso Representatives shall not be offered any gifts, hospitality or expenses that could be considered unreasonable or inappropriate with regard to possible business transactions. At Stora Enso we always pay our own travel and accommodation costs. There is no occasion when any organisation or person inviting our representatives would be allowed to pay any of their costs relating to travel and accommodation. We encourage all of our stakeholders to do business in this same transparent manner, so as to support fair and open competition. Offering Gifts or other types of Hospitality such as goods, services, meals, entertainment or excursions to our employees is strictly prohibited whenever such arrangements are not reasonable or could inappropriately affect business transactions between you and Stora Enso. 37

38 7. General requirements The seventh chapter in the Supplier Code of Conduct is about the general requirements. 38

39 7. General requirements 7.1 The Supplier is required to immediately report any non-compliance with the Supplier Code of Conduct to Stora Enso. The Supplier and any of its employees may report their concerns confidentially to: Head of Internal Audit Stora Enso AB P.O. Box SE Stockholm, Sweden. If you have any questions about issues relating to the Supplier Code of Conduct or this Guide the best person to approach first is your own contact person at Stora Enso. Alternatively, you may send your questions or concerns to: If you notice or suspect any actual or potential violations of our Supplier Code of Conduct, including the conduct of any employee of Stora Enso, we invite you to report this immediately. You may report your concerns anonymously in confidence to the Head of Internal Audit at Stora Enso (address above). Any such reports are handled confidentially and as promptly as possible. We will not accept retaliation against Whistleblowers. Suppliers located in China, India, Russia and Brazil may alternatively report their concerns confidentially through Stora Enso s external service provider, The Network, via internet ( ) via (storaenso@tnwinc.com) or via telephone (phone numbers available below) 24 hours a day, 7 days a week. Country/Provider AT&T Access Code Phone Number Brazil Brazil China China China India Russia Russia Russia Russia Russia Russia To use the AT&T service, please, dial your country-specific access code to reach AT&T. When connected, enter the 866-number. 39

40 7. General requirements 7.2 The Supplier is required to disclose information and data regarding issues covered by the Supplier Code of Conduct at the request of Stora Enso, unless this would conflict with its statutory obligations on disclosure of information. 7.3 The Supplier is required to allow Stora Enso, or any third party authorised by Stora Enso and reasonably acceptable to the Supplier, to conduct in the presence of the Supplier an audit of the Supplier s operations relevant for the Supplier Code of Conduct including but not limited to the Supplier s facilities, and relevant extracts from books and records. At the Supplier s request, the parties involved in any such audit shall enter into a confidentiality agreement regarding the circumstances disclosed in the audit. In order to monitor compliance with our Supplier Code of Conduct or your own code of conduct, and to facilitate your co-operation with Stora Enso, we might ask for certain information from you. We also reserve the right to conduct audits on suppliers premises or in other locations where suppliers work in order to ensure their compliance with our Supplier Code of Conduct. Whenever we conduct such audits we ensure that suppliers interests including the confidentiality of information are duly respected. We perform such audits carefully to ensure that they do not unduly interfere with suppliers business operations. Whenever we require you to produce any information or data to us or whenever we conduct audits, we ensure together with you that your obligations and interests including the confidentiality of information are duly respected. No request for information shall lead to any infringement of confidentiality or other mandatory obligations provided by the law. 40

41 8. Enforcement The eighth chapter in the Supplier Code of Conduct is about the enforcement 41

42 8. Enforcement 8.1 If Stora Enso finds that the Supplier is not meeting the requirements and expectations set out in the Supplier Code of Conduct, Stora Enso will offer guidance specifying which issues need to be corrected or improved. The Supplier must then take corrective actions promptly as advised by Stora Enso. Stora Enso nevertheless reserves the right to cancel outstanding orders, suspend future orders or terminate the contract with the Suppliers in case of a material breach of the Supplier Code of Conduct. 8.2 Should the main contract between Stora Enso and the Supplier, to which the Supplier Code of Conduct forms an Appendix, contain separate termination rules, it is nevertheless understood by both parties that breach of the Supplier Code of Conduct may be considered a material breach of contract, thus entitling Stora Enso to terminate the contract. At Stora Enso we aim to build long-lasting relationships with our suppliers so that together we can develop our businesses and create better products. If we find that a supplier is not meeting our requirements and expectations, our first step is always to offer guidance in an attempt to correct any issues that need improvement, while maintaining our relationship with the supplier. However, under certain circumstances a breach against our Supplier Code of Conduct or supplier s own code of conduct may cause us to cancel outstanding orders, suspend future orders or terminate a contract. It should be understood however, that this is a remedy we will apply only in cases of material breach of the Supplier Code of Conduct. In case there are termination clauses is the contract between our companies, we consider the termination clauses of such contracts prevailing, however, that a breach of requirements under the Supplier Code of Conduct can constitute a reason for termination. 42

43 Terminology 43

44 Terminology Guidance: Review the key terms if needed. If any of the terms sound unfamiliar, do not hesitate to ask your contact person at Stora Enso for clarification! Anti-bribery laws Anti-bribery laws mean legislation, which prohibits corporations and individuals from engaging in Bribery and Corruption. Failure to comply with such laws and adopt effective compliance programs and procedures can result in significant fines and imprisonment for individuals. Bribe A Bribe is an offer or receipt of any money, gift, loan, fee, reward or other advantage to or from any person as an inducement to act, or omit to act, in a way which is dishonest, illegal or a breach of trust. Bribery Bribery, also known as corruption, means giving or receiving a Bribe. At Stora Enso, we have zero tolerance for Bribery and Corruption and it is every supplier s responsibility to avoid all situations that may be interpreted as such. Child labour From ILO: Child labour is work that deprives children of their childhood, their potential and their dignity, and that is harmful to physical and mental development. Not all work done by children should be classified as child labour. Work that does not affect children s health and personal development or interfere with their schooling, is generally regarded as being something positive. Stora Enso does not accept child labour anywhere along our supply chain. This includes both our direct suppliers and any sub-suppliers. Supplier is not allowed to employ any person aged below the minimum age of 15 years (or 14 years for certain countries), or anyone under the minimum age for employment in the country, whichever is highest in line with ILO Convention 138 on minimum age for admission to employment. Suppliers are expected to have robust age verification procedures and records in place, to ensure that no underage persons work in the suppliers operations (including your own employees and contracted workers). 44

45 Terminology CLP European Regulation on classification, labelling and packaging of substances and mixtures, the CLP Regulation or CLP. Competition laws Competition laws are laws that promote and seek to maintain market competition by regulating anti-competitive conduct and business practices. Confidential information (including protecting personal information) Stora Enso supplier might have access to highly confidential information, which needs to be treated with utmost care and confidentiality. Confidential information, whether financial, know-how or of any other type, must be kept secure and protected. Stora Enso must maintain a high standard of commercial and financial security throughout the group. No one who has access to confidential information may use it for their own or others personal gain. Conflict of interest In a supplier/buyer relationship a conflict of interest is any circumstance or situation where a personal, professional or financial interest may have effect on the ability of the supplier to fulfil its loyalty obligations towards the customer or to deliver agreed products or services with the best interest of Stora Enso Discrimination Based on definition by ILO: Discrimination is any distinction, exclusion or preference made on the basis of race, colour, sex, religion, political opinion, national extraction or social origin, which has the effect of nullifying or impairing equality of opportunity or treatment in employment or occupation; Discrimination can also be such other distinction, exclusion or preference which has the effect of nullifying or impairing equality of opportunity or treatment in employment or occupation as may be determined by the Member concerned after consultation with representative employers' and workers' organisations, where such exist, and with other appropriate bodies. Any distinction, exclusion or preference in respect of a particular job based on the inherent requirements thereof shall not be deemed to be discrimination. 45

46 Terminology Do What's Right Do What s Right is one of Stora Enso s Values which tells us what direction to go to stay on the path. It takes us beyond local practices and helps us move the people and communities forward. We must always be aligned with the local laws and rules, but also be ready to aim higher whenever applicable. That is the only way we can fulfil our Purpose Do Good for the People and the Planet. Do What s Right is also the name of the Stora Enso s reporting line which suppliers in certain countries can have access to. EMAS The Eco-Management and Audit Scheme (EMAS) is a voluntary environmental management instrument developed by the European Commission. It enables organizations to assess, manage and continuously improve their environmental performance. The scheme is globally applicable and open to all types of private and public organizations. Facilitation payment Facilitation Payment is an informal, unofficial payment, typically requested by an individual (usually, but not necessarily, a public official) to encourage the recipient or a third party to carry out services that you have a right to receive even without such payment, or to expedite a routine task. It is also known as a gratuity or a grease payment. It can be a payment to expedite or secure performance of routine, non-discretionary tasks, such as obtaining permits, licenses, or other official documents, processing governmental papers, such as visas and work orders, providing police protection, mail pick-up and delivery, providing phone services, power and water supply and loading and unloading cargo. Payment of Facilitation payments are prohibited according to the Suplier Code of Conduct and Stora Enso s policies. Fair and equal opportunity Equality, diversity and respect are the core principles of the United Nations Declaration of Human Rights. Everyone should be considered equal, treated with respect and given equal opportunity in recruitment, remuneration, development and advancement of employment regardless of race, religion, political opinion, gender, age, national origin, sexual orientation, marital status or disability. Fair employment practices Fair employment practices are practices that are built on the guiding principles set by the International Labour Organization and protected with all applicable local laws and legislations ensuring the rights of the employees. 46

47 Terminology Free and fair competition Free and fair competition is competition based on the factors of price, quality and service. Stora Enso is committed to free and open competition in the marketplace. We are successful because of the high quality and competitiveness of our products and services and the talent and commitment of our employees and suppliers. Gifts Gifts can be goods as well as services. Appropriate gifts are given as a mark of friendship or appreciation of reasonable value and without expectation of consideration or value in return. GHS The Globally Harmonized System of Classification and Labeling of Chemicals (GHS) is an internationally agreed-upon system, created by the United Nations. It is designed to replace the various classification and labeling standards used in different countries by using consistent criteria for classification and labeling on a global level, and United States standards. Human rights The United Nations Universal Declaration of Human Rights defines certain fundamental rights and freedoms which Stora Enso fully supports. These rights cover freedom of speech and opinion, thought, education and work, among others. We want everyone to be treated equally, without having to fear for their privacy, physical or mental well-being. We aim to create a work environment where people are respected regardless of individual differences, talents or personal characteristics. Hospitality Hospitality includes entertaining, meals, receptions, tickets to entertainment, social or sports events etc. International Labour Organization (ILO) The International Labour Organization (ILO) is a specialized agency of the United Nations. ILO is devoted to promoting social justice and internationally recognized human and labour rights, pursuing its founding mission that labour peace is essential to prosperity. Today, the ILO helps advance the creation of decent work and the economic and working conditions that give working people and business people a stake in lasting peace, prosperity and progress. Its tripartite structure provides a unique platform for promoting decent work for all women and men. Its main aims are to promote rights at work, encourage decent employment opportunities, enhance social protection and strengthen dialogue on work-related issues. 47

48 Terminology Involuntary labour Involuntary or forced labour refers to situations in which persons are coerced to work through the use of violence or intimidation or by more subtle means such as accumulated debt, retention of identity papers or threats of denunciation to immigration authorities. ISO 9001 ISO 9001 is a standard which sets out the criteria for a quality management system and can be certified to. It can be used by any organization, large or small, regardless of its field of activity. The standard is based on a number of quality management principles including a strong customer focus, the motivation and implication of top management, the process approach and continual improvement. Using ISO 9001helps ensure that customers get consistent, good quality products and services, which in turn brings many business benefits. ISO14001 ISO is a standard which sets out the criteria for an environmental management system and can be certified to. It maps out a framework that a company or organization can follow to set up an effective environmental management system. It can be used by any organization regardless of its activity or sector. Using ISO 14001can provide assurance to company management and employees as well as external stakeholders that environmental impact is being measured and improved. ISO The ISO Energy Management Systems Standard provides organizations with a framework to increase energy efficiency, reduce energy costs and improve energy performance. It is a standard based on the common elements found in all of ISO's management systems standards, assuring a high level of compatibility with ISO 9001 (quality management) and ISO (environmental management). Labour rights Human and labour rights are international labour standards as defined by the United Nations Universal Declaration of Human Rights and the core conventions of the International Labour Organization. LTA Lost-time accident is an accident that causes sick-leave for the work days following the incident day. 48

49 Terminology Management system A management system is a proven framework for managing and continually improving an organization's policies, procedures and processes. The best businesses work as complete units with a shared vision. This may encompass information sharing, benchmarking, team working and working to the highest quality, environmental and social principles. A management system helps your organization to achieve these goals through a number of strategies, including process optimization, management focus and disciplined management thinking. MSDS Material safety data sheet, or safety data sheet (SDS) for chemicals. Occupational health and safety (OHS) Occupational health and safety (OHS) is a multidisciplinary activity aiming to protect and promote the health of workers, develop and promote healthy and safe work environment, and enhance physical, mental and social well-being of workers. In addition, OHS supports the development and maintenance of employee working capacity, as well as professional and social development at work, enabling workers to conduct socially and economically productive lives and to contribute positively to sustainable development. OHSAS It is an internationally applied British Standard for occupational health and safety management systems. It exists to help all kinds of organizations put in place demonstrably sound occupational health and safety performance. It is a widely recognized and popular occupational health and safety management system. PPE Personal protective equipment is equipment worn to minimize exposure to serious workplace injuries and illnesses. These injuries and illnesses may result from contact with chemical, radiological, physical, electrical, mechanical, or other workplace hazards. Personal protective equipment may include items such as gloves, safety glasses and shoes, earplugs or muffs, hard hats, respirators, or coveralls, vests and full body suits. 49

50 Terminology SA 8000 SA 8000 is an auditable certification standard that encourages organizations to develop, maintain, and apply socially acceptable practices in the workplace. SA stands for social accountability. As it can be applied worldwide to any company in any industry, it is an extremely useful tool in measuring, comparing, and verifying social accountability in the workplace. SA 8000 certification is a management systems standard. The management systems criteria require that facilities seeking to gain and maintain certification must go beyond simple compliance to the standard, but also integrate it into their management systems and practices and demonstrate ongoing conformance with the standard. SA 8000 is based on the principles of international human rights norms as described in International Labour Organisation conventions, the United Nations Convention on the Rights of the Child and the Universal Declaration of Human Rights. Safety culture Safety culture is the set of enduring values and attitudes regarding safety issues, shared by every member of every level of an organisation. Safety culture refers to the extent to which every individual and every group of the organisation is aware of the risks and unknown hazards induced by its activities; is continuously behaving so as to preserve and enhance safety; is willing and able to adapt itself when facing safety issues; is willing to communicate safety issues; and consistently evaluates safety related behaviour. Save the children The Save the Children Fund is an international non-governmental organization that promotes children's rights, provides relief and helps support children in developing countries. It was established in the United Kingdom in 1919 in order to improve the lives of children through better education, health care, and economic opportunities, as well as providing emergency aid in natural disasters, war, and other conflicts. In addition to the UK organisation, there are 30 other national Save the Children organisations who are members of Save the Children International, a global network of non-profit organisations supporting local partners in over 120 countries around the world. Save the Children promotes policy changes in order to gain more rights for young people, especially by enforcing the UN Declaration of the Rights of the Child. Alliance members coordinate emergency-relief efforts, helping to protect children from the effects of war and violence. Secondary employment Secondary employment is regarded as any work or related ventures taken outside your primary work place. 50

51 Terminology Sub-supplier Any supplier of Stora Enso s supplier. TRI Total recordable incident is an accident that requires professional medical attention (therefore creating an official record of the happening), causing sick-leave or not causing sick-leave. UN Global Compact The United Nations Global Compact is a strategic policy initiative for businesses that are committed to aligning their operations and strategies with ten universally accepted principles in the areas of human rights, labour, environment and anti-corruption. By doing so, business, as a primary driver of globalization, can help ensure that markets, commerce, technology and finance advance in ways that benefit economies and societies everywhere. UNICEF UNICEF was established on 11 December 1946 by the United Nations to meet the emergency needs of children in post-war Europe and China. Its full name was the United Nations International Children's Emergency Fund. In 1950, its mandate was broadened to address the long-term needs of children and women in developing countries everywhere. UNICEF became a permanent part of the United Nations system in 1953, when its name was shortened to the United Nations Children's Fund. However, UNICEF retained its original acronym. Worker s rights Worker s rights or labour rights are international labour standards defined by the core conventions of the International Labour Organization. 51

52 Appendix 1 Supplier Code of Conduct check list 52

53 Supplier Code of Conduct check list Definitions Requirement Site inspection Interview Document review The Stora Enso Sustainability Requirements: requirement by requirement Things to look for and ask to see during the tour of the site Topics to cover and understand during the interviews with management and persons responsible for the operations Documents to be reviewed and asked A Supplier is any person or legal entity which provides Stora Enso with products or services. In addition to Suppliers who have a direct contractual relationship with Stora Enso, this definition also includes the Suppliers sub-suppliers Check the address, locations, and refer them to the documents Sample and check supplier s subsuppliers Top management Documents, permits, registers or similar which proves that the supplier exists Supplier s supplier (sub-suppliers) 53

54 Supplier Code of Conduct check list 2. Management systems General about Management systems A management system describes the set of procedures an organization needs to follow in order to perform and meet its objectives. In small organizations, there may not be an official system, but "our way of doing things which might not be in a written form. In the larger the organization procedures need to be recorded to ensure everyone is clear on who does what. This process of systemizing how things are done is known as a management system. It helps to Establish goals and plan how to meet them Follow procedures to get there Make sure you are following your procedures Manage and address issues as they arise; and Show continuous improvement 1. Plan 2. Do 2. Check 2. Act 54

55 Supplier Code of Conduct check list Some example of the Key questions to the management: General management of the company o o o o o o o o o o o o o o o o o o Are there policies in place for working conditions, health and safety, environmental performance and responsible business? Do you know the applicable laws and regulations? Are laws and regulations followed systematically? Are the laws and regulations duly applied and communicated (with sufficient training) to relevant employees and business partners? What type of permits you need to have in order to have a license to operate? Do you have a system to assess, mitigate and manage risks related to human and labour rights, occupational health and safety, responsible business and environmental impacts? What is your management structure (organization chart that shows who is responsible for what)? Are the roles and responsibilities of the employees defined (preferably in written, for example in the employment contracts)? Do you have procedures or instructions (written or understanding of steps you follow each time you complete a task)? Do you have training program for your employees? Preferable a written acknowledgement that each employee has been trained in the procedures relevant to them. How does the company follow-up and evaluate its performance? Do you have measureable targets in relation of this Code of Conduct issues and define related actions to reach the targets in order to ensure continuous improvement? How do you do corrective actions? (E.g. fixing any problems you discovered and writing down how you did it, and check the effects) Do you have a budgeting process in place? Is there a third party auditing process in place for the annual accounts? Are invoices paid via third party bank accounts? Are invoices paid in cash? Are all taxes and official governmental permits paid as requested? How do you manage and keep records? How is confidential information managed? (keeping files in a centralized location that show the procedures are successfully followed) 55

56 Supplier Code of Conduct check list Human and labour rights o Is the management aware of human rights and show respect to human right in all operations including own employees, business partners, and other stakeholders? o What is your policy on discrimination? o What is your policy on involuntary labour? o What is your policy on human trafficking? o Are you aware of all applicable laws on worker s basic rights, wages, working hours, occupational health and safety, environmental performance and responsible business? o Are you aware of all your employees including permanent, temporary, onsite contractors and agency workers, as well as piece-rate, salaried, hourly paid, legal young workers (minors), part time, night, and migrant workers? o Are the human rights impact mapped and actions planned? o Do you have child labour in your supply chain? What is the minimum age in your countries of operations? o Do you allow employees to join or form trade unions of their own choosing, and to bargain collectively? o Do you have young workers below the age of 18 but over the minimum age? How do you make sure that young workers below the age of 18 but over the minimum age are protected from performing any work that is likely to be hazardous, that interferes with their education, or that may be harmful to their health or physical, mental, social, spiritual or moral development? o Do all the employees have a written contract? o Do you keep adequate records of the wages and social security fees paid? o Do you keep verifiable working time procedures and records, including records of overtime hours, for all employees? o Are there ways to discuss work related grievances with the employees? 56

57 Supplier Code of Conduct check list Occupational health and safety (OHS) o o o o o o o o How do the management and the leaders support safety culture? Do you have a safety policy? Do you have a safety organisation? Have you assigned the safety responsibilities in your organisation? How do you communicate them throughout your organisation? Do you have hazardous identification and risk assessments in place? Do you have procedures for emergency situation, well communicated and practiced? Do you have training records on OHS issues? Have you defined OHS metrics? How do you monitor them? Is safety performance followedup? How do you report and investigate health and safety incidents? Environmental impact o What is your environmental policy or principles? o Are you aware of all applicable environmental laws and regulations, and permits? o Do you have an environmental organisation and/or assigned responsibilities? o How do you make sure that organisation has the right capabilities on environmental issues? Do you keep training records? o How do you recognize your environmental impacts? What are the impacts? o How do you recognize your environmental risks? How do you avoid the risks? o What are the environmental targets? o Is there a systematic way to follow up the environmental performance (for example the use of energy, water, electricity or gasoline)? o How is the waste treatment organized? Is it clear where the waste is distributed to? 57

58 Supplier Code of Conduct check list 2. Management systems cont. Requirement Site inspection Interview Document review 2.1 the Supplier shall adopt a systematic approach to the assessment, mitigation and management of risks related to human and labour rights, occupational health and safety, responsible business and environmental impact (hereafter referred to as Code of Conduct Issues ) Information on site on human and labour rights, occupational health and safety, responsible business and environmental impact performance Procedures (measurements, safety Waste and fresh water management, air emission control and equipment, waste management Management has set targets, is aware of the status of the targets and performance Management confirms continuous improvement Relevant, valid certificates if any (e.g. ISO9001; ISO14001; OHSAS etc.) Company specific policies or principles exist and are communicated Documentation of targets and performance review, action plans Documentation of management review Status of implementation of guidance (documents, training plans/programs, list of participants), and how the understanding of procedures is ensured) Customer requirements and performance (awareness of the requirements within the employees) and improvement Internal audits and review (continuous improvement) 2.2 the Supplier shall adopt measurable performance targets in relation to Code of Conduct Issues and define related actions to reach these targets with a view to ensure continuous performance improvement Observe documents Management interview From the business point of view supplier has set short-term and /or long-term targets to the relevant items (human and labour rights, occupational health and safety, responsible business and environmental impact) Management reviews Targets and action plans 58

59 Supplier Code of Conduct check list 2. Management systems cont. Requirement Site inspection Interview Document review 2.3 all applicable laws, regulations and contractual terms governing the Supplier s assignments shall be duly applied and communicated, with sufficient training provided to relevant employees and business partners Observe documents and systems Management is aware of relevant laws and their requirements Management is aware of policies and principles and can describe content Copies of relevant laws exist Company specific policies or principles exist and are communicated Training materials and list of trained employees and business partners 2.4 the Supplier shall have systems in place to enable the reporting of Code of Conduct Issues-related grievances (e.g. a whistle-blowing system) Observe documents and systems Management has a guidance, has set a system and is aware of the process Documentation (e.g. procedure and process description) 2.5 the Supplier shall duly ensure and monitor that its own suppliers and sub-suppliers comply with this CoC or their own equivalent code of conduct. The Supplier is liable for the performance. On-site subcontractors and sub-suppliers delivering goods are in compliance with requirements (for instance chemical handling) Management has recognized its suppliers Management confirms and can describe supplier requirements and follow-up Management ensures that the content of this Supplier Code of Conduct is communicated to its supplier and they are compliant with it. A list of major suppliers and subcontractors exists Documentation on supplier requirements and their implementation (e.g. contracts, follow-up documents) exists Audit reports and corrective action plans 59

60 Supplier Code of Conduct check list 3. Human and labour rights 3.1 Human rights Requirement Site inspection Interview Document review To respect human rights and not be complicit in human rights violations within its sphere of influence. Observe documents Management interview Management reviews Targets and action plans To duly map its human rights impacts whenever the need for such action is agreed. Observe documents Management interview Documents of the mapping to have in place adequate remedial mechanisms in case of any human rights violations. Observe the system and instructions Management interview Observe the system and instructions 60

61 Supplier Code of Conduct check list 3.2 Basic workers rights Requirement Site inspection Interview Document review Not to employ any workers below 15 years (14 years in certain developing countries) or the minimum age according to national legislation, whichever is higher (in line with the ILO Convention 138 on child labour) No children working on-site Management confirms policy on age of employees and can describe checking method Policy and principles on regarding minimum age exist Records on employee ages exist, and are in compliance with requirements Documents on procedure exists on checking age of new employees To ensure that employing young people (under 18 years) does not jeopardise their education, health, safety or morals. No young employees in unsuitable or heavy jobs are visible on-site Management confirms existence of list of jobs not suitable for young workers and can describe the practices List of work suitable / un-suitable for under 18-year olds is available Records on young employees (under 18, above minimum age) exist To fully recognise employees right to organise, belong to a union and bargain collectively Information on shop stewards/ employee representatives is available on-site Management confirms existence of unions, freedom of association and collective bargaining Employee representatives are available for interview Management can tell about topics raised by employees Management can describe process for electing employee representatives (should be a democratic process) List of unions present at the site exists, with member list (if allowed by local legislation) List of head shop stewards/ employee representatives exist Meeting minutes are available from meetings between management and employees 61

62 Supplier Code of Conduct check list Requirement Site inspection Interview Document review Not to use any forms of involuntary labour. Movement (leaving the workplace) is free, all doors are not locked No excessive security personnel on-site Personnel have access to basic needs such as water and sanitary facilities during Management confirms freedom of employment and that overtime is voluntary Management can describe recruitment practices confirming freedom of employment (for instance no penalties for not working overtime) Management can explain wage payment practices and any salary deduction Policy and principles on freedom of employment exist Policy proving that overtime work is voluntary Documentation on full payment of salary exist Records on employee debt to company exists, with evidence of fair payback practices No evidence of keeping employee documents exist Not to discriminate against any of its employees To treat all employees fairly and respectfully. Information on grievance system is available on-site (for instance suggestion or complaint boxes exist) Interview employees Management confirms existence of policy and can describe the grievance system Interview confirms that practices such as pregnancy tests of employees are not used. Interviews confirm that recruitment practices are fair and transparent Interview management Interview employees Policy on non-discrimination exists Documentation on grievance system exists and records on possible grievances exist Documentation 62

63 Supplier Code of Conduct check list 3.3 Wages and working hours Requirement Site inspection Interview Document review to pay employees at least the minimum wage and applicable overtime wages defined by national laws or any applicable collective agreements, to apply normal working hours that comply with applicable law and collective agreements and where no such laws or collective agreements exist working hours will not exceed 48 hours per working week on a regular basis to provide all employees with at least one rest day in seven consecutive working days unless regulated otherwise by applicable laws Copies of relevant laws and/or collective agreements defining minimum wage are available for employees (for instance wage rates or minimum wage posted in factory) Copies of relevant laws and/or collective agreements defining working hours are available for employees (including compensation for overtime) Systems for recording working hours (punch card machine, sign in at gate) Sample and check records Management is aware of minimum salary level and how it is defined Management confirms payment of minimum or above wage Management can describe wage payment practices Employees can explain salary calculations Management is aware of regulations on working hours and can describe the rules Management confirms that over-time is voluntary Management can describe the procedures for overtime work Management is aware of the rest day policy and how it is defined Management confirms Management can describe the practices Employees can explain Copies of relevant laws and/or collective agreements defining minimum wage exists Salary records exist and are in compliance with requirements, clearly indicating the paid net salary, and payment directly to employee Employee contracts show wage and payday Copies of pay slips given to workers Copies of relevant laws and/or collective agreements defining working hours and overtime compensation exist Possible exception permits to deviate from working hours requirements from local authorities exist Records on working hours exist, and are in compliance with requirements Records on overtime and overtime compensation exist and are in line with legal requirements Check records 63

64 Supplier Code of Conduct check list 4. Occupational health and safety (OHS) Requirement Site inspection Interview Document review 4.1 To fulfil all applicable legal Occupational Health & Safety requirements. 4.2 To have a written OHS policy of its own, to demonstrate management s commitment to OHS, and to assign responsibility for OHS within its organisation 4.3 To ensure that operational controls such as rules and procedures are in place and communicated to all employees # of emergency exits, exits not blocked, clear exit signs Evacuation plan Fire extinguishers are available and have been tested Fire alarm or sprinkler First aid kits exist and are valid Potable water is available for employees (and has been tested) Hygiene of canteens and sanitary facilities Interview people at the site and ask about the policy Written safety instructions are accessible and/or visible at the workplace in relevant languages Safety signs are visible on-site Can you see any un-safe behaviour? Management is aware of relevant laws and their requirements Management is aware of policies and principles and can describe content Management is aware of policies and principles and can describe content Management is aware of written safety instructions, and can indicate where to find them Copies of relevant laws exist Company specific policies or principles exist and are communicated Company specific policies or principles exist and are communicated Written safety instructions exist and are communicated 64

65 Supplier Code of Conduct check list Requirement Site inspection Interview Document review 4.4 to have emergency preparedness and response procedures in place, 4.5 to increase its employees awareness of health and safety issues, to enhance safety culture through open communications, and to ensure that its staff have received appropriate OHS training. Observe the instructions/signs/training Interview people and check the awareness Employees on site are wearing PPEs and follow safety instructions Management is aware of accident documentation and can comment on safety performance Management s confirm that there is regular health and safety training and can give a general description of how of is done. Records of accidents and corrective actions taken exist Process description for how accident are dealt with Training material and records exist Training schedules and plans exists 4.6 To measure and monitor its OHS performance and OHS hazards with the help of properly conducted workplace inspections and audits. Review the monitoring system Review the inspection/audit reports Check the corrective actions Management is reviewing the performance regularly and can show minutes of the meeting or similar Reports Minutes of the meetings Action plans 4.7 To report and investigate all health and safety incidents. Check the incident reports Interview people at the site Management is committed to safety Management is aware of the incidents and has conducted investigations followed with corrective action plans. Incident reports Corrective actions plans 65

66 Supplier Code of Conduct check list 5. Environmental requirements Requirement Site inspection Interview Document review 5.1 To fulfil all environmental requirements defined in relevant laws, regulations and environmental permits Management is aware of legal requirements Copies of relevant laws exist If applicable, environmental permit exist Check emissions records against possible limits in the permit Typical permit limits include for instance COD, PH, nitrogen Reports required by authorities 5.2 To assign responsibility for environmental issues within its organization. Environmental contacts are available on site Management is aware and can describe the organisation and name responsible persons Organsational charts and job descriptions exist with titles and responsibilities described 5.3 To ensure that its employees have appropriate know-how and experience in relation to environmental issues, as well as resources to enable them effectively to meet their responsibilities. Instructions and information is available on site to employees Management can tell about environmental training Training materials and records exist Training records when new processes have been introduced Training plans and schedules exist showing regular training an training of new employees 66

67 Supplier Code of Conduct check list Requirement Site inspection Interview Document review 5.4 To ensure that written instructions covering all processes with potential environmental impacts, such as the storage and handling of hazardous materials, are available and that the relevant information is communicated to all employees involved. Stacking heights for chemical storage are visible and followed Chemical storage areas are marked Chemicals are stored undercover and drainage exists Instructions exist on-site in relevant languages Management is aware of practices regarding the storage and handling hazardous materials MSDS exist Instruction on the handling and storage of hazardous chemicals exist and are communicated 5.5 to proactively work to prevent emergencies and ensure the capacity to react appropriately to such events, by analysing, identifying and adopting suitable preventive and corrective measures, Instructions and information is available on site to employees Management can tell about emergencies Documents of the analysis existing Training materials and records exist Training records when new processes have been introduced Training plans and schedules exist showing regular training 5.6 to handle environmental violations and complaints systematically and communicate them to employees and external stakeholders, including Stora Enso if affected, Instructions Management can describe the system Records of the communications 5.7 To provide Stora Enso with up-to-date material safety data sheets (MSDS or SDS), as applicable, and any other relevant documents and information requested by Stora Enso. MSDS are available on site Management is aware of the process for updating and delivering MSDSs Management can comment on REACH Check version of MSDS that have been supplied to Stora Enso Documentation of processes to update the MSDS 67

68 Supplier Code of Conduct check list 6. Responsible business Requirement Site inspection Interview Document review To conduct business activities in compliance with the Stora Enso business practice policy or other equivalent ethical rules (regarding antitrust and fair competition, anticorruption, avoidance of conflict of interest) and to fulfil other applicable laws and regulations. 7. General requirements Laws, policies, principles and guidelines are available on-site in appropriate languages Management repots on possible non-compliances Management is aware of relevant laws and their requirements Management is aware of policies, principles and guidelines and can describe content Management confirms training has been conducted Copies of relevant laws exist Company specific policies or principles exist and are communicated Company specific guidelines exist and are communicated Documentation (content and records) on business practice training exists Requirement Site inspection Interview Document review 7.1 to immediately report any noncompliance with this CoC to Stora Enso. The Supplier and any of its employees may report their concerns confidentially to: Head of Internal Audit Stora Enso AB P.O. Box SE Stockholm, Sweden. See web page for more details. Management is aware of the process for delivering such information to Stora Enso Documentation (e.g. process description) of delivering such information to Stora Enso exists 68

69 Supplier Code of Conduct check list 7. General requirements Requirement Site inspection Interview Document review 7.2 to disclose information and data regarding issues covered by this CoC at the request of Stora Enso, unless this would conflict with its statutory obligations on disclosure of information 7.3 to allow Stora Enso, or any third party authorised by Stora Enso and reasonably acceptable to the Supplier, to conduct in the presence of the Supplier an audit of the Supplier s operations relevant for this CoC including but not limited to the Supplier s facilities, and relevant extracts from books and records. At the Supplier s request, the parties involved in any such audit shall enter into a confidentiality agreement regarding the circumstances disclosed in the audit 69

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