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Corporate Responsibility

CAPP Supplier Code of Conduct

Our Core Values

CAPP and its global subsidiaries (collectively “CAPP”) are committed to a set of core values that serve as CAPP’s guiding principles when conducting business with the highest standards of ethics, responsibility, and focus on sustainability. We expect the same commitment from our suppliers, who play a critical role in delivering products and providing services that reflect our values. The CAPP Supplier Code of Conduct (“Code of Conduct”) outlines our minimum expectations regarding legal compliance, the protection of human rights, environmental stewardship, business ethics, and responsible sourcing, among other key values.

This Code of Conduct applies to each member of CAPP’s global vendor, supplier, and third-party community (“Suppliers”) and each must adhere to the principles outlined below and promote them within their own supply chains.

Compliance with Laws: We expect our Suppliers to maintain full compliance with all laws and regulations applicable to their business, and when conducting international business, Suppliers must comply with local and national laws, codes, rules, orders regulations in the countries or jurisdictions in which such business is conducted (collectively, “Applicable Law”). All requirements in this Code of Conduct are to be interpreted as obligations in addition to the foregoing requirement to comply with Applicable Law.

2. Human Rights and Labor Practices

2.1. Respect for Human Rights: Suppliers shall support and respect internationally recognized human rights and ensure they are not complicit in human rights abuses. In accordance with the International Labour Organization (“ILO”), Suppliers shall commit to uphold human rights of workers and treat workers with dignity and respect. This commitment applies to all workers including temporary, contract, student, migrant, and direct employees. Suppliers will also respect the rights of vulnerable groups including women, migrants, and children in accordance with ILO conventions. Suppliers will ensure that workers are protected against physical, sexual, psychological, and verbal harassment and abuse.

2.2 Freely Chosen Employment: All forms of forced labor, including without limitation, bonded labor, involuntary prison labor, slavery, and human trafficking are strictly prohibited. Suppliers will ensure that all workers should be free to leave work or terminate employment upon reasonable notice. Suppliers will maintain documentation on all workers leaving their employment in order to properly document their work history.

2.3 Child Labor: Suppliers must adhere to the minimum working age in any region where they operate, while prohibiting employment of anyone under the age of 15 or under the minimum age for employment as defined by Applicable Law and as aligned with ILO Convention 138. Suppliers will verify the age of young workers to ensure the age is above that of minimum employment. Suppliers will ensure that child labor will not be tolerated in any form.

2.4 Fair Wages and Working Hours: Suppliers shall provide fair wages, benefits, and working hours that comply with Applicable Laws and industry standards. Overtime must be voluntary and compensated accordingly. Compensation and benefits must at least comply with Applicable Laws, including overtime and legally mandated benefits. Employees must also be permitted to have adequate breaks and rest periods, and to take holiday and time off in accordance with Applicable Law.

2.5 Non-Discrimination: Suppliers must promote an inclusive work environment and shall not discriminate based on race, gender, color, age, religion, sexual orientation, gender, ethnicity, pregnancy, disability, political affiliation, marital status, or any other protected status.

2.6 Freedom of Association: Suppliers shall recognize and respect the rights of employees to freely associate, join trade unions, and engage in collective bargaining. Suppliers will ensure workplace environments enable workers to pursue alternative forms of organizing including worker councils or worker-management dialogues where there are regulatory constraints.

2.7 Humane Treatment/Anti-Harassment: Harassment, abuse, or any form of inhumane treatment, including sexual harassment or coercion, is strictly forbidden in accordance with Applicable Laws. Suppliers shall:

  • Respect the basic human rights of their employees.
  • Not allow physical, sexual, psychological, or verbal harassment or abuse.
  • Not allow discrimination based on race, origin, color, gender, disability, sexual orientation, political or religious convictions, age, world view, or any other category protected by Applicable Law.
  • Not use forced, bonded, indentured, or involuntary labor.

3. Health, Safety, and Wellbeing

Suppliers must provide a safe and healthy workplace. This shall include requirements to:

  • Comply with applicable occupational health and safety laws.
  • Provide appropriate personal protective equipment (PPE) based on the work environment.
  • Identify and mitigate health and safety risks.
  • Ensure employees receive health and safety training.
  • Maintain clean and accessible facilities, including restrooms, drinking water, and food areas.
  • Provide Hazmat or similar awareness training on handling, movement, storage, disposal, and spill response in accordance with international, national, or local laws.

4. Environmental Stewardship

Suppliers shall operate in an environmentally responsible and sustainable manner. This may include minimizing detrimental environmental impact of their operations, supply chain, products, and services, as much as possible towards environmental neutrality. This may also include:

  • Comply with applicable environmental laws and regulations.
  • Work to reduce emissions, water consumption, energy use, and waste, and to recycle effectively.
  • Promote circular economy practices whenever possible.
  • Monitor, and where possible report, Greenhouse Warming Gases
  • Reducing and eliminating practices that lead to deforestation, or the loss of natural forest due to conversion to agriculture or non-forest land use.
  • Avoid the use of restricted substances and ensure proper handling of hazardous waste.

5. Ethical Business Practices

5.1 Anti-Corruption and Bribery: Suppliers must comply with the anti-corruption laws, directives, and regulations that govern operations in the countries in which they do business, regardless of local customs, including, without limitation, the U.S. Foreign Corrupt Practices Act and the UK Bribery Act of 2010. Suppliers must not engage in any form of corruption, fraud, bribery, money laundering, extortion, or embezzlement. Suppliers must not offer, directly or indirectly, any illegal or improper payments, gifts, or hospitality intended to exert undue influence or impact business decisions.

5.2 Fair Competition: Suppliers must comply with all antitrust and fair competition laws and refrain from collusion, price fixing, bid-rigging, or market manipulation. Suppliers should also respect the intellectual property of others.

5.3 Conflicts of Interest: Suppliers must avoid actual or perceived conflicts of interest and disclose any that may arise in their business dealings with CAPP. Supplier employees and immediate family members (spouse, domestic partner, parents, children, siblings, and their spouses) may not serve as officers, directors, employees, agents, or consultants who may affect business decisions that may appear improper. Any appearance of impropriety shall be disclosed to CAPP. In addition, Suppliers shall:

  • Maintain the highest standards of integrity in all interactions with CAPP.
  • Not offer improper gifts or services that may appear as undue or improper business advantages.
  • Refrain from providing charitable donations on behalf of CAPP which may appear as inappropriate business advantages.

5.4 Intellectual Property, Product Quality and Counterfeit Parts: Suppliers must respect intellectual property rights, product quality, and prevention of counterfeit parts in the supply chain in accordance with the following:

  • A commitment to preventing the introduction of counterfeit parts and components into the supply chain.
  • Enhancing quality assurance processes to identify defects while implementing corrective actions and continuous improvements to prevent re-occurrences.
  • Monitoring processes to minimize the risk of introducing counterfeit parts and materials into deliverable products.
  • Avoiding compromises to intellectual property rights and properties within the international supply chain.

6. Responsible Sourcing, Conflict Minerals and Supply Chain Management

CAPP seeks supply chain partners that utilize sustainable and responsibly sourced energy, minerals and raw materials and implement supply chain practices that do not cause or contribute to human rights violations and conflict. CAPP works collaboratively with supply chain partners to increase the transparency and traceability of products sold by CAPP. We also expect Suppliers to respect all internationally recognized human rights and conduct responsible supply chain management practices and conflict free sourcing practices. Suppliers shall comply with Applicable Laws requiring disclosure of the use of conflict minerals. The term “conflict minerals” refers to certain identified minerals that may have directly or indirectly contributed to the financing of armed groups in the Democratic Republic of Congo (“DRC”) and neighboring countries.

  • Suppliers must avoid sourcing materials from Conflict-Affected and High-Risk Areas that contribute to human rights violations or environmental harm.
  • Suppliers shall supply products to CAPP that do not contain conflict minerals that directly or indirectly finance, or benefit armed groups in DRC and any country that shares an internationally recognized border with DRC.
  • Suppliers are expected to ensure that their own supply chains adhere to the principles outlined in this Code of Conduct.
  • CAPP encourages inclusive sourcing practices and engagement with diverse and local suppliers within the confines of the lawful movement of goods.

7. Grievance Mechanism and Whistleblower Protection

Suppliers must provide a safe, accessible, and confidential grievance mechanism for workers to raise concerns or report violations without fear of retaliation. Whistleblowers must be protected from harassment, dismissal, or disciplinary action. Suppliers should also have the following:

  • A strong reporting procedure to eliminate miscommunication and misinterpretation.
  • No corporate retaliation.
  • A prompt investigation procedure.

8. Monitoring and Compliance

CAPP reserves the right to assess and monitor supplier compliance with this Code of Conduct through audits, site visits, and self-assessments. Non-compliance may result in corrective action requests, suspension, or termination of the business relationship. This includes:

  • Ensuring global compliance with applicable international trade law, without limitation, export controls, customs, and tax laws
  • Complying with global sanctions
  • Complying with international rules on embargoed countries and territories
  • Complying with conflict minerals laws

9. Confidentiality, Data Protection and Data Privacy

We expect Suppliers to safeguard confidential information with the most stringent information and data protection requirements and ensure data is managed responsibly and securely. Suppliers shall have processes and procedures in place to protect data, including personal data, from unauthorized access, use, or disclosure.

  • Trade and business secrets and confidential information must be managed discretely and confidentially and must not be shared with or made accessible to unauthorized parties.
  • The protection of the intellectual property of third parties, or customers of CAPP, which may be required to be shared with a Supplier on a case-by-case basis, must also be respected with the Supplier using at least the same degree of care it exercises to protect its own confidential information.
  • All confidential information must be maintained in confidence and stored properly or as agreed to by CAPP and not altered, copied, or misused.
  • Suppliers shall protect the privacy expectations of individuals with respect to the access, collection, use, processing, transmission, and storage of personal data.
  • Supplier must comply with privacy and information security laws and requirements when personal information is collected, stored, processed, transmitted, and shared. Suppliers shall also ensure the security of all business data.

A Shared Commitment

Suppliers are encouraged to go beyond compliance by adopting sustainable practices, adhering to Applicable Laws, providing safe working conditions, promoting continuous improvement, and partnering with CAPP to create long-term value for society, the environment, and our mutual business success.

Non-Compliance Reporting: Violations of the Code of Conduct can be reported in any of the following ways:

  • Email: legal@cappusa.com
  • Mail: CAPP, ATTN: Legal & Compliance Dept. 3025 Highland Parkway #550, Downers Grove, IL 60515

Modification: CAPP may at any time update, modify or change the information or application of the policies described in this Code of Conduct as required to meet changing circumstances.

CAPP Human Rights Policy

1. Policy Statement

CAPP and its global subsidiaries (collectively “CAPP”) is committed to conducting its business with honesty, integrity, and respect for the human rights of all individuals. We believe that business can only flourish in societies where human rights are protected and respected. This policy outlines our commitment to upholding human rights in our relationships with our employees, suppliers, customers, and the communities in which we operate.

2. Our Commitment to International Principles

Our policy is guided by internationally recognized standards, including the United Nations Universal Declaration of Human Rights, the International Labor Organization’s Declaration on Fundamental Principles and Rights at Work, and the United Nations Guiding Principles on Business and Human Rights. Where national law and international human rights standards differ, we will follow the higher standard; where they conflict, we will adhere to national law while seeking ways to honor the principles of internationally recognized human rights.

3. Key Commitments

  • Diversity, Equity, and Inclusion: We are committed to a work environment free from discrimination and harassment. We provide equal employment opportunities to all applicants and employees regardless of race, color, religion, gender, age, national origin, sexual orientation, gender identity, disability, or any other status protected by applicable law. The basis for recruitment, hiring, placement, training, and advancement is qualification, skill, experience, and performance.
  • Prohibition of Forced Labor and Human Trafficking: We prohibit and will not tolerate any form of forced, bonded, or involuntary labor, including debt servitude and human trafficking, within our operations or supply chain.
  • Prohibition of Child Labor: We are committed to the abolition of child labor. We prohibit the hiring of individuals under the legal minimum working age in the jurisdictions in which we operate, or under the age of 18, for any hazardous work. We support legitimate workplace apprenticeships, internships and other similar programs that comply with applicable laws and regulations.
  • Safe and Healthy Workplace: We are dedicated to providing a safe and healthy workplace. We operate in full compliance with applicable safety and health laws and are committed to minimizing the risk of accidents, injury, and exposure to health risks for all employees and contractors. This includes low negative environmental impact, no dangerous noise emissions, extreme heat or cold, and ample access to drinking water, sanitation, and safety and/or first aid stations. The Health & Safety Team will coordinate the policies and procedures to ensure and mitigate risk.
  • Workplace Security: We seek to prevent any acts or threats of violence in our workplaces. Individuals who engage in violence or threats of violence may be subject to disciplinary action, up to and including termination of employment, as well as possible criminal prosecution.
  • Data Protection and Privacy: Management, suppliers/vendors, and senior staff shall protect personal data and respect the right to privacy. This means that employees, personnel, and customers’ personal data should be collected, used, and processed responsibly and lawfully. The organization shall implement appropriate safeguards to protect personal data against unauthorized use and disclosure.
  • Freedom of Association and Collective Bargaining: We respect our employees’ right to join, form, or not to join a labor union without fear of reprisal, intimidation, or harassment. Where employees are represented by a legally recognized union, we are committed to establishing a constructive dialogue and bargaining in good faith.
  • Wages, Benefits, and Working Hours: We compensate employees competitively and comply with all applicable laws for wages, work hours, overtime, and benefits.
  • Supplier Conduct: We expect our suppliers and business partners to adhere to principles consistent with our own. Our Supplier Code of Conduct requires our suppliers and business partners to uphold the human rights of their workers and to operate in an ethical and responsible manner.

4. Implementation and Due Diligence

We are committed to identifying, preventing, and mitigating any adverse human rights impacts related to our business activities. We will conduct human rights due diligence to assess and address risks in our operations and supply chain. This includes integrating human rights considerations into our standard business processes, providing training for relevant employees, and continuously evaluating our approach.

5. Governance and Reporting Responsibility

Our leadership is responsible for the implementation of this policy. We are committed to creating workplaces where open and honest communication is valued. Any employee, supplier, or other stakeholder can report a human rights concern or potential violation through our established grievance channels, including options for anonymous reporting, without fear of retaliation. We are committed to investigating all reports promptly and taking appropriate corrective action. Annual review and audits will be conducted to ensure continued integrity, efficacy, and updates to the Human Rights Policy.

Non-Compliance Reporting

  • Email: legal@cappusa.com
  • Mail: CAPP, ATTN: Legal & Compliance Dept. 3025 Highland Parkway #550, Downers Grove, IL 60515

Modification: CAPP may at any time update, modify or change the information or application of the policies described in this Code of Conduct as required to meet changing circumstances.