J.McLaughlin Code of Conduct

At J. McLaughlin, we continually strive to develop and promote high standards of business practices, social responsibility, and environmental protection. We believe that these standards also best serve the interests of our customers. This Code of Conduct (“Code”) provides specific requirements and recommended guidelines for Suppliers and Vendors on how to maintain safe workplaces, respect fundamental rights, enable environmental resilience and operate with a high standard of business transparency and ethics. This Code is based upon internationally accepted labor standards and industry best practices.

If J. McLaughlin determines that any Vendor or Supplier is in violation of any term of this Code, J. McLaughlin reserves the right to: (i) immediately terminate its relationship with Supplier or Vendor including cancellation of outstanding purchase orders; or (ii) require corrective actions within an acceptable time period.

Suppliers and Vendors agree to communicate and uphold J. McLaughlin’s requirements and standards with their employees, suppliers, and vendors. Suppliers and Vendors shall also adhere to, publicize, and enforce a non-retaliation policy that permits workers to discuss the requirements of this Policy with their management, suppliers, vendors, customers and J. McLaughlin, without fear of retaliation by management.


Suppliers and Vendors shall allow J. McLaughlin or its authorized third-party monitoring firm unrestricted access to all areas of the facilities and to all relevant records whether or not advance notice has been provided.

Suppliers and Vendors are expected to take the necessary corrective actions to resolve all non-compliance issues found from their audits. J. McLaughlin reserves the right to terminate the business relationship with any supplier who is unwilling to comply with this code of conduct.

Suppliers and Vendors agree that they must disclose as soon as reasonably possible in writing to J. McLaughlin conditions that are or may be in conflict with any provision of this Code or any applicable Laws in facilities that produce, store, or handle J. McLaughlin’s products or provide services to J. McLaughlin.

Suppliers and Vendors agree that J. McLaughlin or a third party approved by J. McLaughlin may perform unannounced on-site inspections and audits of Suppliers and Vendors to verify compliance with this Code, including permitting confidential employee interviews, unfettered access to facilities, and providing copies of any books and records as J. McLaughlin may reasonably request.

Suppliers and Vendors agree that they must maintain on site all documentation that may be needed to verify compliance with the laws of the applicable jurisdiction and the provisions of this Code All such documentation is to be made available upon request to J. McLaughlin and/or its designated third-party inspector/auditor.

Suppliers and Vendors must disclose the identity, physical location, and ownership of all factories that will produce products for J. McLaughlin and the identity, location, and ownership of any subcontractors. Any proposed change from one factory to another or the use of subcontractors must be approved by J. McLaughlin in writing before production begins. Any Supplier of J. McLaughlin that uses a subcontractor, even if approved by J. McLaughlin, shall be responsible for the acts and omissions of its subcontractor(s), including, but not limited to, any violation of this Code. Any Supplier that utilizes subcontractors without the prior approval of J. McLaughlin will be subject to order cancelation upon, and for a reasonable amount of time after, J. McLaughlin becomes aware of the use of the unapproved subcontractor. J. McLaughlin shall not be required to compensate Supplier for any services performed or products provided (or which are in process) by an unapproved subcontractor.

Compliance with Laws

Suppliers and Vendors shall operate in compliance with the laws of their respective countries including all applicable rules and regulations regarding labor, wages, social benefits, workplace health and safety, and the environment.

In the event of a labor shortage and foreign contract workers are used, they are to be employed in full compliance with the labor and immigration laws of the host country. The passports and visas of foreign workers are to be their personal possession at all times and never to be withheld by the Supplier or Vendor or any third party.

Suppliers and Vendors will comply with U.S. and international importing laws and will establish programs and maintain documentation to support country-of-origin production verification and preferential trade claims. Suppliers will comply with international supply-chain security requirements and criteria, including those criteria established by U.S. Customs-Trade Partnership Against Terrorism (C-TPAT) and Canada Partners In Protection (PIP).


Suppliers and Vendors shall comply with all environmental rules and regulations applicable to their operations. They shall have an environmental management system in place and adopt measures to mitigate any negative impact on the environment. Suppliers shall identify and maintain all applicable environmental permits, legal documents (e.g. Environmental Impact Assessment), licenses, approvals and/or certifications. All documents required by law or regulation must be available for review.

Child Labor

Suppliers and Vendors agree not to utilize child labor in any of their operations or facilities. A child is anyone who is under sixteen years of age or the minimum age established by Law in the relevant jurisdiction. In addition, factories must comply with all legal requirements for young workers, particularly those pertaining to hours of work, wages, and working conditions. Suppliers shall request original, legal documentation to verify the employees’ age at the time of hire and eligibility to work and maintain documentation or copies of documentation to demonstrate due diligence.

Wages & Benefits

Suppliers and Vendors agree to pay their employees’ and workers’ wages and benefits that meet or exceed the legally required wages and benefits or, where no wage or benefits Laws exist, the local industry standard for the relevant jurisdiction. For each pay period, Suppliers and Vendors must provide their workers with a timely and understandable wage statement that includes sufficient information to verify the accuracy of wages paid for work performed. Wages shall be provided to workers on a monthly or more frequent basis.

Working Hours

Suppliers and Vendors agree to comply with applicable laws and industry practices related to working hours. Suppliers’ and Vendors’ workers must not work more hours in one week than allowable under applicable Laws or regularly exceed the recommended maximum of 56 hours per week, whichever is less. Workers must be properly compensated for overtime work and must be allowed at least one uninterrupted, 24-hour rest period every seventh (7th) day.


Suppliers and Vendors must provide a fair, consistent, and inclusive environment and make all employment decisions based on neutral and objective criteria. In addition to complying with all applicable laws, Suppliers and Vendors must not engage in or tolerate discrimination, harassment, and unfair treatment based on an individual’s race, color, affiliation, ancestry, ethnicity, religion, sex, pregnancy, national origin, age, disability, marital status, veteran status, military status or obligation to perform military service, sexual orientation, gender identity or expression, or genetic information.

Forced Labor

Suppliers and Vendors agree not to use any prison, bonded, forced, involuntary, or unpaid labor either directly or indirectly, by the Supplier or Vendor or any of their suppliers or vendors.

Freedom of Association

Suppliers and Vendors must recognize and respect the right of workers to freedom of association and to bargain collectively. Workers must not be subject to intimidation or harassment in the exercise of their right to join or to refrain from joining any organization.

Safe Workplace

Suppliers and Vendors agree to provide all their workers with a safe and healthy work environment and comply with all applicable Laws and regulations regarding working conditions, including, but not limited to:

  • Access to potable drinking water; sanitary food preparation, storage, and eating facilities; restrooms; emergency medical care; and first aid kits
  • Appropriate personal protective equipment, available at no cost to all applicable employees
  • Instruction in and enforcement of proper use of protective equipment
  • Appropriate safety training for the use of machinery and other equipment, and the handling of chemicals
  • Proper labeling of machinery, hazardous materials, and other potentially dangerous items;
  • Workers are not permitted to engage in the manual transport of a load which, by reason of its weight, is likely to jeopardize a worker’s health or safety;
  • Adequate lighting, ventilation, heating, and clean toilet facilities in all work areas
  • Doors and other exits are well marked, unobstructed, and unlocked from the inside during all working hours for orderly evacuation in case of fire or other emergencies
  • All main exit doors allow workers to clear the building;
  • Evacuation drills are conducted at least two times a year with trained supervisors to monitor the safe and orderly evacuation;
  • Maintain written standards for a safe and healthy work environment and the prevention of accidents and injuries to workers, including: emergency reporting, employee notification and evacuation procedures, and appropriate fire detection and suppression equipment;
  • Where residential housing is provided for workers, facilities must be in compliance with all housing Laws and regulations, occupancy requirements, and health and safety Laws.

Disciplinary Practices

Every employee shall be treated with dignity and respect. Suppliers and Vendors shall not engage in or support the use of corporal punishment, mental or physical coercion and verbal abuse including but not limited to threats of violence and sexual harassment. In addition, Suppliers and Vendors shall not use monetary fines as a disciplinary practice.

Personally Identifiable Information

If a Supplier or Vendor Processes any personally identifiable information (“PII”) on behalf of J. McLaughlin, the Supplier or Vendor shall comply with all privacy and data protection Laws, rules and regulations applicable in the jurisdiction to which such data is subject. The Supplier or Vendor shall only Process PII in accordance with J. McLaughlin’s instructions. The Supplier or Vendor shall implement appropriate technical and organizational measures to adequately protect PII against misuse and loss in accordance with the requirements of all applicable Laws. Upon J. McLaughlin’s request, the Supplier or Vendor shall provide a copy of its current personal data protection and security program covering data processing. The Supplier or Vendor shall ensure that all personnel entrusted with Processing PII have undertaken to comply with the applicable principles of data protection and have been duly instructed on the applicable regulations. The Supplier or Vendor shall promptly inform J. McLaughlin in case of a serious interruption of operations, suspected of breach affecting PII, or any other irregularity in processing PII. Where J. McLaughlin, based upon applicable Law, is obliged to provide information to an individual about the collection, Processing or use of its PII, the Supplier or Vendor shall assist J. McLaughlin in making this information available, including allowing J. McLaughlin personnel or a third party designated by J. McLaughlin, to conduct an audit of Supplier or Vendor’s records and facilities to verify Supplier or Vendor’s compliance with this Manual.


Suppliers and Vendors agree to maintain the confidentiality of J. McLaughlin’s confidential information, which will include but not be limited to information that is not public, and agree only to disclose such information to their employees on a need to know basis for performance of their agreements with J. McLaughlin. Suppliers and Vendors are liable for any disclosure of J. McLaughlin’s confidential information by Suppliers’ and Vendors’ respective employees. Suppliers and Vendors agree that, that J. McLaughlin shall have the right, in addition to any other rights and remedies, to seek injunctive relief for any violation these obligations by Supplier or Vendor without the necessity of posting a bond. Suppliers and Vendors waive the claim or defense that J. McLaughlin has an adequate remedy at law.