SUPPLY CHAIN CODE OF CONDUCT
UCEL recognizes that forced labour and child labour risks occur through the global supply chains of private businesses. We acknowledge we have a vital role to play in ensuring that goods we import and distribute in Canada are produced without forced labour or child labour.
UCEL is committed to maintaining the highest ethical standards as a responsible and transparent business entity, and to ensuring our moral and legal obligations are met. This applies to all employees, contractors, suppliers, and partners associated with the company, and covers all business activities and interactions – both within UCEL and throughout our entire supply chain.
DEFINITIONS
Corruption: Any form of unethical behavior, including bribery, extortion, embezzlement, fraud, money laundering, and any other illicit practices.
Forced Labour: Any work performed involuntarily under menace of penalty, and/or when an individual is compelled against their will to provide work or services using force, fraud or coercion.
Child Labour: The exploitation of children through any form of work that is harmful to their development, interferes with their ability to attend regular school, or is mentally, physically, socially and/or morally harmful.
Supply Chain: All parties involved in the production, distribution, and delivery of goods and services, including ourselves and our suppliers, contractors, and service providers.
PRINCIPLES
Ethical Conduct: Employees and stakeholders are expected to uphold the highest ethical standards in all business dealings. This includes honesty, integrity, and fairness.
Zero Tolerance: UCEL has a zero-tolerance approach towards corruption. Any form of corrupt practice will result in severe consequences, including termination of employment or business relationships, and potential legal action.
Corporate Accountability: UCEL commits to increasing our knowledge of the materials and processes of manufacture, to establishing practical procedures for ensuring the integrity of the supply chain, and to denouncing all forms of improper business practice.
Compliance with Laws and Regulations: All employees, contractors, and business partners must comply with relevant local, national, and international laws and regulations related to anti-corruption.
Transparent Financial Transactions: All financial transactions must be accurately recorded and transparent. No off-the-books or undisclosed financial activities are permitted. Further, employees are prohibited from giving or receiving gifts, entertainment, or hospitality that could compromise their integrity or create a perception of impropriety.
PROCEDURES
Assessing Risks: UCEL will conduct yearly and as-needed risk assessments to identify and mitigate potential corruption risks within the company and the supply chain.
Due Diligence: UCEL will conduct due diligence on suppliers, contractors, and business partners to ensure they comply with anti-corruption laws and align with the company’s values.
Training and Awareness: A copy of this document and anti-corruption training is provided to all impacted employees and stakeholders to ensure they are aware and understand the importance of preventing corrupt practices.
Reporting: UCEL has establish a confidential reporting mechanism to encourage the reporting of any suspected corrupt practices. Retaliation against whistleblowers is strictly prohibited.
Monitoring and Enforcement: UCEL will regularly monitor and enforce compliance with this policy through internal audits and investigations. Non-compliance will result in appropriate disciplinary actions.
Review and Revision: This initiative is approved and endorsed by UCEL executive leadership. This initiative will be reviewed regularly to ensure its effectiveness and relevance. Any necessary revisions will be made to address emerging risks and changes in laws.