Everbrite Headquarters

Conducting Business

At Everbrite, we appreciate that suppliers operate in different legal and cultural environments throughout the world. At a minimum, we necessitate that all suppliers and their facilities meet the standards and promote the principles outlined in this Code of Conduct. This Code of Conduct is intended to advance Everbrite’s commitment to all aspects of integrity including ethical, environmental, and economic. We strive to develop and strengthen partnerships based on transparency, collaboration and mutual respect. Our Code of Conduct is an extension of the values and beliefs of the company leadership that form the foundation of our company.  Visit www.everbrite.com for information.

The provisions of this Code are in addition to, and not in lieu of, the provisions of any legal agreement or contract between a supplier and Everbrite or any of its affiliates.  We expect suppliers to hold their supply chain, including subcontractors and third party labor agencies, to the same standards contained in this Code.  This Code does not create any third-party beneficiary rights or benefits for suppliers, subcontractors, their respective employees or any other party.

HUMAN RIGHTS AND LABOR STANDARDS

Human Rights: We expect our suppliers to conduct their activities in a manner that respects human rights as set out in The United Nations Universal Declaration of Human Rights.

Freedom of Association: Suppliers shall respect the rights of workers to associate or not to associate with any group, as permitted by and in accordance with all applicable laws and regulations.

Employment Status: Suppliers shall employ workers who are legally authorized to work in their location and facility and are responsible for validating employees’ eligibility to work status through appropriate documentation.

Employment Practices: Suppliers shall not use any form of slave, forced, bonded, indentured, or involuntary prison labor.  They shall not engage in human trafficking or exploitation, or import goods tainted by slavery or human trafficking.  They shall not retain employees’ government-issued identification, passports or work permits as a condition of employment.    

Anti-Discrimination and Fair Treatment: Suppliers shall promote and maintain a workplace free from discrimination and treat their employees with fairness, dignity and respect.  No form of physical, sexual, psychological or verbal harassment or abuse shall be tolerated.

Working Hours and Rest Days: Employees shall be allowed at least one day off every seven days, and any overtime worked shall be voluntary. If local law allows, employees may voluntarily work overtime on rest days, provided that they are allowed at least one day off within the next seven days.  Continuous working days are never to exceed 21 days without a rest day.

Underage Labor: Suppliers shall ensure that no child labor has been used in the production or distribution of their goods or services. A child is any person under the minimum employment age according to the laws of the facility's country, or, in the absence of law, under the minimum age for completing required education.  Suppliers shall not employ anyone younger than 14, regardless of the country's minimum working age.

Wages and Benefits: Suppliers shall ensure that their workers are paid lawful wages, including overtime, premium pay, and equal pay for equal work without discrimination.  There shall be no disciplinary deductions from pay.

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WORKPLACE ENVIRONMENT

Suppliers shall ensure that all workers receive communication and training on emergency planning and safe work practices.  In addition, suppliers shall have systems to prevent, detect and respond to potential risks to the safety, health and security of all employees.

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ENVIRONMENTAL MANAGEMENT

Suppliers are responsible for managing, measuring and minimizing the environmental impact of their facilities.  Specific focus areas include air emissions, waste reduction, recovery and management, water use and disposal, and greenhouse gas emissions.

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BUSINESS INTEGRITY

Compliance with Law: Suppliers’ business activities shall comply with applicable laws and regulations in the countries and jurisdictions in which they operate.  This Code applies to activities in the locations where suppliers’ goods are produced, where any related services are performed, and where the goods enter the supply chain.

Anti-Bribery: Suppliers shall not engage in any form of bribery, kickbacks, corruption, extortion or embezzlement.  Suppliers shall not take any action that would cause Everbrite to violate the U.S. Foreign Corrupt Practices Act or any other anti-bribery law or regulation.

Audits and Assessments: Everbrite’s reserves the right to audit compliance with this Code.  Audits are facility inspections that include employee interviews and a review of supplier records and business practices.  Such audits are conducted by Everbrite’s or its approved monitoring firm.  If an audit identifies a violation of this Code, suppliers shall act promptly to correct the situation to Everbrite’s satisfaction.

Books and Records: Suppliers shall maintain accurate and transparent books, records and accounts to demonstrate compliance with applicable laws and regulations and this Code.

Confidentiality: Suppliers shall safeguard Everbrite’s information by keeping it secure, limiting access, and avoiding discussing or revealing such information in public places.  These requirements extend even after the conclusion of a supplier’s business relationship with Everbrite’s.

Reporting Violations and Whistleblower Protection: Suppliers are responsible for prompt reporting of actual or suspected violations of the law, Everbrite’s standards of business conduct, for Everbrite’s employees, or the Everbrite’s supplier guidance document.  This includes violationsby any employee or agent acting on behalf of either the supplier or Everbrite.  Suppliers shall create internal programs for handling reports of workplace grievances, including anonymous reports.  Such programs shall protect worker whistleblower confidentiality and prohibit retaliation.

Additional Standards: In addition to complying with this Code, suppliers are responsible for complying with Everbrite’s supplier guidance document, and being aware of and supporting the standards of business conduct for Everbrite’s employees.

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Conflict Materials

Several metals commonly used in the electronics industry — gold (Au), tantalum (Ta), tungsten (W) and tin (Sn) — have a variety of sources, including what has been termed as a "Conflict Region."

Everbrite LLC will continue to undertake reasonable due diligence within our supply chain to assure that these metals are not procured as "Conflict Metal." A "Conflict Metal" is derived from ore sourced from mines in conflict areas of the Democratic Republic of Congo (DRC) or illegally taxed on trade routes, either of which is controlled by non-government military groups or unlawful military factions. Everbrite LLC is committed to sourcing responsibly and considers mining activities that fuel conflict as unacceptable. Everbrite is guided by the Responsible Materials Initiative (RMI).

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Raising an Integrity Concern

Subject to local laws and any legal restrictions applicable to such reporting, each Everbrite supplier is expected to promptly inform Everbrite of any integrity concern involving or affecting Everbrite, whether or not the concern involves the Supplier, as soon as the supplier has knowledge of such integrity concern.   An Everbrite supplier shall also take such steps as Everbrite may reasonably request to assist Everbrite in the investigation of any integrity concern involving Everbrite and the supplier.  

  1. Define your concern with specific information:
    Who or what is the concern? When did it arise? What are the relevant facts?
  2. Prompt reporting is crucial-- an Integrity concern may be raised by an Everbrite Supplier as follows:
    • Contact a cognizant EB manager; OR
    • Contact the Everbrite ethics hotline

      Phone: 1-888-592-7483
      Fax: 1-888-592-7483
      Email: Everbrite@myeccho.org
      Mail:      Attn: Everbrite
                    2250 E. Devon Ave, Ste. 341
                    Des Plaines, IL 60018

Everbrite will thereupon promptly review and investigate the concern.
Reminder: Everbrite policy forbids retaliation against any person reporting an integrity concern.