2 TELUS Supplier Code of Conduct 2 Contents Introduction... 3 Ethics Business Integrity... 4 No Improper Advantage... 4 Disclosure of Information... 4 Intellectual Property... 4 Fair Business, Advertising and Competition... 5 Responsible Sourcing of Materials... 5 Non-Retaliation... 5 Conflicts of Interest... 5 TELUS Property... 5 Community Investment... 5 Labour Freely Chosen Employment... 6 Child Labour Avoidance... 6 Working Hours... 6 Wages and Benefits... 7 Non-Discrimination... 7 Freedom of Association and Collective Bargaining... 7 Legal Eligibility to Work... 7 Health and Safety Occupational Health and Safety... 8 Property Risk Reduction and Emergency Preparedness... 8 Occupational Injury and Illness... 9 Fit for Work... 9 Environmental Management System Management Accountability and Responsibility...11 Legal and Customer Requirements...11 Risk Assessment and Risk Management...11 Communication and Training...12 Compliance Assessments and Corrective Actions...12 Accurate Accounts and Record Keeping...12 Implementation...13 TELUS Links and Information...13
3 TELUS Supplier Code of Conduct 3 Introduction We value our relationship with our suppliers because they help us achieve our business objectives and contribute to our overall success. We strive to award business to suppliers who demonstrate a strong commitment to sustainable development by adopting ethical, labour, health and safety, and environmental principles that align with ours and ensure the well-being of their employees, contractors and communities. Consistent with our Ethics policy that applies to our employees, this Code is based upon generally accepted standards of ethical business conduct. We expect our suppliers to comply with applicable laws and regulations wherever they operate. This document goes beyond legal compliance, drawing upon internationally recognized standards, to advance social and environmental responsibility and business ethics, and is consistent with TELUS commitment to be a leading corporate citizen. Consistent with our view that this Code applies to our supply chain, we also expect our suppliers to cause their affiliates, suppliers, employees and contractors to perform obligations to TELUS consistent with the ethical standards set out in this Code. The conduct set out in this Code falls into two categories: (i) requirements that are described as expectations ; and (ii) matters where a supplier is encouraged to display an attribute or behaviour. Expectations should be viewed as mandatory requirements on the part of suppliers, where a failure on the part of a supplier to comply with an expectation may have consequences under the applicable supply agreement, up to possible termination of that agreement by TELUS. Where a matter falls within the category of an encouraged attribute or behaviour, the degree to which a supplier is required to display such attribute or behaviour will depend on the particular circumstances of the supplier and the nature of products and services that are being furnished by the supplier to TELUS.
4 TELUS Supplier Code of Conduct 4 Ethics To meet social responsibilities and achieve success in the marketplace, our suppliers are expected to uphold high standards of ethics. Business Integrity Our suppliers are expected to maintain high standards of courtesy, professionalism and honesty in all their interactions with customers, shareholders, suppliers, employees and the community and comply with all applicable federal, provincial, state and local laws. Our suppliers are expected to comply with all applicable international laws regarding bribery and corruption and refrain from engaging in any form of corruption, including kickbacks, extortion and the promising, offering, approving, giving or accepting of bribes. TELUS does not permit facilitation payments to be made, even if they may not be illegal in a particular jurisdiction. Facilitation payments are typically small, unofficial payments made to secure or expedite the performance of a routine government action by a government employee or official. No Improper Advantage Our suppliers are expected to familiarize themselves with the TELUS Ethics policy that provides guidance to TELUS team members on offering or accepting gifts, gratuities, rewards, favours or benefits, particularly by those TELUS representatives with selection, negotiation, purchasing or contract management roles. Our suppliers are expected to refrain from placing TELUS team members in a position where they are, or may perceived to be, in breach of the TELUS Ethics policy. Disclosure of Information Unless disclosure is authorized or legally mandated (for example by court order), our suppliers are expected to protect the confidentiality of their employee, contractor and customer information, including TELUS confidential information, in compliance with applicable laws and contract obligations, including privacy legislation, irrespective of whether the information or data was provided by the employee, contractor or customer, or was created by the supplier. Intellectual Property Our suppliers are expected to respect the intellectual property rights of TELUS and others, and their contractual obligations pertaining to intellectual property rights.
5 TELUS Supplier Code of Conduct 5 Ethics Fair Business, Advertising and Competition Our suppliers are expected to adhere to fair business practices, and comply with all applicable laws relating to competition standards and advertising. Responsible Sourcing of Materials Our suppliers are expected to evaluate the origin or source of their materials throughout their supply chains to reasonably assure that they have not been obtained in any illegal or unethical manner. In particular, our suppliers are expected to have a policy to reasonably assure that the tantalum, tin, tungsten and gold and/ or other rare earth minerals in their products do not directly or indirectly finance or benefit armed groups that are perpetrators of human rights abuses. Suppliers are expected to exercise due diligence on the source and chain of custody of these minerals and make their due diligence measures available to TELUS upon request. Non-Retaliation Our suppliers are expected to refrain from retaliating against anyone who files a report or complaint in good faith internally, with TELUS or with any government agency in accordance with applicable laws. Conflicts of Interest Our suppliers are naturally involved in business relationships with people and organizations in addition to TELUS. It is expected that these relationships will not reasonably appear to compromise the relationship with TELUS or the ability to make impartial and objective business decisions in connection with the TELUS contractual supply arrangement. TELUS Property Our suppliers are expected to take reasonable electronic and physical measures to safeguard TELUS property, including TELUS proprietary or confidential information, facilities, equipment, vehicles, funds, communication networks and information systems and material in their possession or under their control. This also applies to access controls, such as passwords, identification keys, cards and hand-held user authentication devices. Community Investment Our suppliers are encouraged to engage and invest in the communities in which they live, work and serve to foster social and economic development.
6 TELUS Supplier Code of Conduct 6 Labour Our suppliers are expected to uphold the human rights of workers, and treat them with dignity and respect in compliance with internationally accepted standards and laws governing working conditions. This applies to all workers including temporary, migrant, student, contract, direct employees, and any other type of worker. Freely Chosen Employment It is expected that all work for our suppliers is voluntary, and workers are free to leave at any time or terminate their employment. While workers may be asked to provide government-issued documentation as identification, it is expected that they will not be required to surrender government-issued identification, passports or work permits as a condition of employment. Child Labour Avoidance It is expected that our suppliers do not use child labour in any part of their business operations. The minimum age for employment or work shall be 15 years of age (or 14 where the laws of the country permit) or the age for completing compulsory education in that country, whichever is higher. The use of workplace apprenticeship programs, which comply with all applicable laws and regulations, is encouraged. Working Hours Our suppliers are expected to manage operations such that workweeks do not exceed the maximum number of hours set by local law. Where there are no applicable laws, our suppliers are expected to refrain from requiring, except in emergency or unusual situations, work in excess of six consecutive days without a rest day away from work.
7 TELUS Supplier Code of Conduct 7 Labour Wages and Benefits It is expected that compensation paid to workers complies with all applicable wage laws, including those relating to minimum wages, overtime hours and legally mandated benefits. Where no wage law exists, it is expected that workers be paid at least the minimum local industry standard. It is expected that the basis on which workers are being paid is provided in a timely manner via pay stub or similar documentation. Non-Discrimination It is expected that our suppliers are committed to a workforce free of harassment and unlawful discrimination and do not engage in discrimination based on race, national or ethnic origin, color, religion, age, gender, sexual orientation, marital status, disability or conviction for which a pardon has been granted. Freedom of Association and Collective Bargaining It is expected that our suppliers respect the rights of workers to freely join labour unions, seek representation and join workers councils, and to bargain collectively in accordance with local laws. Legal Eligibility to Work It is expected that our suppliers ensure that their workers providing labour services for TELUS away from their home country have the appropriate work permits and comply, at all times, with local immigration laws and regulations in the country in which their work is performed.
8 TELUS Supplier Code of Conduct 8 Health and Safety Our suppliers are expected to comply with all applicable health and safety laws and perform all services in a diligent manner in respect of health and safety matters. Where appropriate, our suppliers are expected to implement and train their workers on policies, programs and procedures to address the following health and safety matters. Occupational Health and Safety It is expected that exposure to potential health and safety hazards will be controlled through proper design, engineering and administrative controls, preventative maintenance and safe work procedures. It is expected that where hazards cannot be adequately controlled by these means, persons present at or near the worksite are provided with appropriate, well-maintained, personal protective equipment. Potential health hazards may include exposure to chemical, biological and physical agents where overexposure to such agents may damage health, and safety hazards where lack of physical guards and barriers around machinery may injure people. There will be no discipline for raising health and safety concerns. Property Risk Reduction and Emergency Preparedness Our suppliers are expected to use reasonable efforts to identify and mitigate property and life safety-related risks including, but not limited to, the structural integrity of the supplier s facilities, fire risk, flooding risk, power supply continuity risk, and other risks which could reasonably be expected, if they occur, to impact the supplier s provision of service, the lives and well-being of their workers and/or otherwise negatively impact TELUS. It is expected that potential emergency situations and events will be identified and assessed, and their impact minimized by implementing emergency plans and response procedures, including: emergency reporting, notification and evacuation procedures, training and drills, appropriate fire detection and suppression equipment, adequate exit facilities and recovery plans.
9 TELUS Supplier Code of Conduct 9 Health and Safety Occupational Injury and Illness It is expected that our suppliers have procedures and systems in place to manage, track and report occupational injury and illness, including provisions to: a) encourage reporting; b) classify and record injury and illness cases; c) provide necessary medical treatment; d) investigate cases and implement corrective actions to eliminate their causes; and e) facilitate return of workers to work. Fit for Work It is expected that our suppliers require their workers to report fit for work, such that their ability to work safely is not impaired for any reason. Their workers should be free of the negative effects of alcohol, drugs, medications or any other substance that could cause impairment.
10 TELUS Supplier Code of Conduct 10 Environmental Our suppliers recognize that environmental responsibility is integral to producing world-class products and services. In manufacturing, industrial and service operations, adverse effects on the community, environment and natural resources are minimized while the health and safety of the public are safeguarded. Our suppliers are expected to comply with all applicable environmental laws and are encouraged to have a strategy, including policies and programs, in place to manage, monitor and reduce the environmental impact of the following, non-exhaustive, list: Consumption of resources (e.g. fuel, electricity, water, paper, etc.) Usage, handling and disposal of hazardous and non-hazardous wastes Release of contaminants into the air (e.g. greenhouse gases, ozone depleting substances, volatile organic compounds) Release of contaminants into water and soil Product life cycle, including product content as well as the recovery and appropriate disposition of materials. Our suppliers are expected to be aware of TELUS Environmental Policy and relevant aspects of the environmental management system, which aligns with the ISO 14001:2004 standard. TELUS objectives, targets and environmental performance are continuously monitored and reported yearly through our Corporate Social Responsibility Report.
11 TELUS Supplier Code of Conduct 11 Management System Our suppliers are expected to have in place the appropriate management system to ensure (a) compliance with applicable laws, regulations and customer requirements related to the supplier s operations and products; (b) conformance with the principles of this Code; and (c) identification and mitigation of operational risks related to this Code. The management system should facilitate continuous improvement. TELUS understands that the design of such a management system will have to be scaled to the particulars of the supplier s business. Such management system may contain the following elements: Management Accountability and Responsibility Clearly identified company representative(s) responsible for ensuring implementation of the management systems and associated programs. Legal and Customer Requirements A process to identify, monitor and understand all applicable laws, regulations and customer requirements that may include business continuity planning and capability in the event that the supplier s operations are interrupted. Risk Assessment and Risk Management A process to identify the environmental, health and safety 1 and labour practice risks associated with the supplier s operations. A process to identify the fraud risks affecting TELUS and its customers information and proprietary rights. A determination of the relative significance for each risk and implementation of appropriate procedural and physical controls to control the identified risks and ensure regulatory compliance. 1 Areas to be included in a risk assessment for environmental health and safety are production areas, warehouse and storage facilities, plant/facilities support equipment, laboratories and test areas, sanitation facilities (bathrooms), kitchen/cafeteria and worker housing /dormitories.
12 TELUS Supplier Code of Conduct 12 Management System Communication and Training A process to communicate clear and accurate information about the supplier s policies, procedures and improvement objectives to its workers and programs to train these workers to meet applicable legal requirements including TELUS contractual requirements. Compliance Assessments and Corrective Actions Periodic self-evaluations to ensure conformity to legal and regulatory requirements, the content of this Code and customer contractual requirements and a process for timely correction of identified deficiencies. Accurate Accounts and Record Keeping Creation and maintenance of accurate and reliable financial and business records to ensure legal and regulatory compliance, conformity to company requirements, confidentiality to protect privacy and the conveyance of accurate information to TELUS or its customers. All business dealings are accurately reflected in the business records. All business records (such as quality, safety or personnel, as well as financial records) relating to the TELUS contractual supply arrangement are protected and retained in accordance with the requirements of the supply contract.
13 TELUS Supplier Code of Conduct 13 Implementation TELUS is committed to continuous improvement and encourages suppliers to proactively share suggestions in regards to process, business performance and relationship improvement for TELUS to consider. TELUS reserves the right to assess and monitor on an ongoing basis the supplier s practices regarding this Code. Such measures may include a request that the supplier complete a self-assessment questionnaire, provide proof of compliance with all applicable laws, or allow onsite inspections of working conditions. TELUS Links and Information TELUS web site: TELUS Corporate Social Responsibility Report: TELUS Ethics Policy: Report a concern or misconduct: or TELUS Procurement contact: TELUS and the TELUS logo are trademarks of TELUS Corporation, used under license TELUS. 14_00234 NEXT PREVIOUS PREVIOUS EXIT
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