Responsible Business Alliance


The THEPI Responsible Business Alliance (RBA) Code of Conduct establishes standards to ensure that the working conditions are safe, that workers are treated with respect and dignity and that our manufacturing processes are environmentally responsible and conducted ethically..

Purpose

The purpose of this is to establish a guideline for all THEPI employees, suppliers, stake holders and customers on the RBA Code of Conduct.

This is also meant to cover all possible situations that may occur, it is designed to provide a frame of reference where in employees can seek guidance when they are in doubt about the proper course of action in a given situation.

Applicability

This policy applies to all employees, stake holders, suppliers, and customers of THEPI.

A. Labor

THEPI is committed to uphold the human rights of workers, and to treat them with dignity and respect as understood by the international community. This applies to all workers including temporary, migrant, student, contract, direct employees, and any other type of worker. Recognized standards have been used as references in preparing this Policy and are further amplified in our Employee Handbook.

The labor standards are :

  • Forced, bonded or indenture labor, involuntary or exploitative prison labor, slavery or trafficking of persons shall not be used.
  • No restriction on worker’s freedom of movement in facility.
  • Workers must be provided with a written employment agreement and there shall be no substitution or changes in the employment agreement unless these changes are made to meet local law and provide equal or better terms.
  • All work must be voluntary and workers shall be free to leave work at any time or terminate their employment.
  • Workers shall not be required to pay recruitment fees or other related fees for their employment.
  • THEPI does not utilize or promote forced or child labor of any kind. We adhere strictly to country laws governing labor standards.
  • Workweeks are not to exceed the maximum set by local law. Further, a workweek is not more than 60 hours per week, including overtime, except in emergency or unusual situations. Workers are allowed at least one day off every seven days
  • Workers shall comply with all applicable wage laws including those relating to minimum wages, overtime hours and legally mandated benefits. In compliance with local laws, workers shall be compensated for overtime at pay rates greater than regularly hourly rates. Deductions from wages as disciplinary measures shall not be permitted.
  • There is to be no harsh and inhumane treatment including any sexual harassment, sexual abuse, corporal punishment, mental or physical coercion of workers; nor is there to be the threat of any such treatment.
  • Workforce free of harassment and unlawful discrimination. Companies shall not engage in discrimination based on race, color, age, gender, sexual orientation, gender identity and expression, ethnicity or national origin, disability, pregnancy, religion, political affiliation, union membership, covered veteran status, protected genetic information or marital status in hiring and employment practices such as wages, promotions, rewards and access to training.
  • Workers and/or their representatives shall be able to openly communicate and share ideas and concerns with management regarding work conditions and management practices without fear of discrimination, reprisal, intimidation o harassment.
B. Health and Safety

THEPI recognizes that in addition to minimizing the incidence of work-related injury and illness, a safe and healthy work environment enhances the quality of products and services, consistency of production and worker retention and morale. The Company also recognizes that ongoing worker input and education is essential to identifying and solving health and safety issues in the workplace. Recognized management systems such as OHSAS 18001 and Guidelines on Occupational Safety and Health were used as references in preparing this Policy.

The health and safety standards are:

  • Worker potential for exposure to safety hazards are to be identified and assessed, controlled through proper designs, engineering and administrative controls, preventive maintenance and safe work procedures and on going safety trainings
  • Potential emergency situations and events are to be identified and assessed, and their impact minimized by implementing emergency plans and response procedures.
  • Procedures and systems are in place to prevent, manage, track and report occupational injury and illness including provisions to: encourage worker reporting; classify and record injury and illness cases; provide necessary medical treatment; investigate cases and implement corrective actions to eliminate their causes; and facilitate return of workers to work.
  • Exposure to chemical, biological and physical agents is to be identified, evaluated, and controlled according to the hierarchy of controls. Potential hazards are to be eliminated or controlled through proper design, engineering and administrative controls.
  • Worker exposure to the hazards of physically demanding tasks, including manual material handling and heavy or repetitive lifting, prolonged standing and highly repetitive or forceful assembly tasks is to be identified, evaluated and controlled
  • Production and other machinery have been evaluated for safety hazards. Physical guards, interlocks and barriers are provided and properly maintained where machinery presents an injury hazard to workers.
  • Workers are provided with ready access to clean toilet facilities, potable water and sanitary food preparation, storage, and eating facilities.
  • Health and safety related information shall be clearly posted in the facility or placed in a location identifiable and accessible by workers. Training is provided to all workers prior to the beginning of work and regularly thereafter

C. Environmental

THEPI recognizes that environmental responsibility is integral to producing world class products. In manufacturing operations, adverse effects on the community, environment and natural resources are minimized while safeguarding the health and safety of the public. Recognized management systems such as ISO 14001 and the Environmental Management System were used as references in preparing this Policy.

The environmental standards are:

  • All environmental permits (e.g. discharge monitoring), approvals and registrations are obtained, maintained and kept current and their operational and reporting requirements are followed where and when required.
  • The use of resources and generation of waste of all types, including water and energy, are reduced or eliminated at the source or by practices such as modifying production, maintenance and facility processes, materials substitution, conservation, recycling and re-using materials.
  • Chemicals and other materials posing a hazard if released to the environment are identified and managed to ensure their safe handling, movement, storage, use, recycling or reuse and disposal.
  • THEPI has implemented a systematic approach to identify, manage, reduce, and responsibly dispose of or recycle solid waste (non-hazardous). Wastewater generated from operations, industrial processes and sanitation facilities are characterized, monitored, controlled and treated as required prior to discharge or disposal. In addition, measures have been implemented to reduce generation of wastewater.
  • Air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting chemicals and combustion by-products generated from operations are characterized, routinely monitored, controlled and treated prior to discharge when and where required.
  • THEPI adheres to all applicable laws, regulations and customer requirements regarding prohibition or restriction of specific substances in products and manufacturing, including labeling for recycling and disposal.
  • The Company prevents illegal discharges and spills from entering storm drains.
  • The Company continuously looks for cost effective methods to improve energy efficiency and to minimize its energy consumption and greenhouse gas emissions.

THEPI shall provide an essential service to our community. We play a role in connecting people with each other, with our community and key community services. Our Corporate Social Responsibility touches on all members of the community with the potential to impact positively on protection of Environment. In line with our Core Values, our community strategy incorporates the following elements:

  • Engagement with the local communities in which we operate.
  • Offering employment opportunities to our nearby communities.
  • Promoting engagement between our staff and the community.
  • Improving the environment in and around our operations.
  • Support for employees effort in fund raising projects for the care of our environment.
  • Developed consciousness in our employees for the care of our environment.

We are committed to:

  • Manage company waste and the overall impact of our operations on the environment.
  • Maintain an internal management structure for the management of environmental issues which includes clearly defined responsibilities for environmental management capable of delivering this commitment.
  • Monitoring our waste management performance and setting objectives and targets for improvement.
  • Providing appropriate training and awareness program for our employees.

D. ETHICS

To meet social responsibilities and to achieve success in the industry, THEPI and its agents uphold the highest standards of ethics. Many of these topics are amplified in our Employee Handbook.

  • Shall have a zero tolerance policy to prohibit any and all forms or bribery, corruption, extortion and embezzlement
  • Bribes or other means of obtaining undue or improper advantage are not promised, offered, authorized, given or accepted. This prohibition covers promising, offering, authorizing, giving or accepting anything of value, either directly or indirectly through a third party, in order to obtain or retain business, direct business to any person, or otherwise gain an improper advantage.
  • Information regarding participant labor, health and safety, environmental practices, business activities, structure, financial situation and performance is disclosed in accordance with applicable regulations and prevailing industry practices. Falsification of records or misrepresentation of conditions or practices in the supply chain are unacceptable.
  • Intellectual property rights are respected; transfer of technology and knowhow is done in a manner that protects intellectual property rights; and, customer information is safeguarded.
  • Standards of fair business, advertising and competition are upheld. Appropriate means to safeguard customer information is available.
  • Programs that ensure the confidentiality, anonymity and protection of supplier and employee whistleblowers are to be maintained, unless prohibited by law. Participants should have a communicated process for their personnel to be able to raise any concerns without fear of retaliation
  • Participants shall exercise due diligence on the source and chain of custody of these minerals and make their due diligence measures available to customers upon customer request
  • THEPI is committed to protecting the reasonable privacy expectations of personal information of everyone it does business with, including suppliers, customers, consumers and employees. The Company complies with privacy and information security laws and regulatory requirements when personal information is collected, stored, processed, transmitted, and shared. Every employee shall respect any information which is confidential to the company and an individual. Confidential information consists of personal data and any information that is not or not yet public information. It includes trade secrets, business strategies, marketing plans, engineering and manufacturing ideas, product recipe, database, records, and salary information, personal and financial data.

E. MANAGEMENT SYSTEM

THEPI has established a management system whose scope is related to the content of this Policy. The management system is designed to ensure: (a) compliance with applicable laws, regulations and customer requirements related to Fine Metals’ operations and products; (b) conformance with this Policy; and (c) identification and mitigation of operational risks related to this Policy. It should also facilitate continual improvement.

THEPI Corporate Social and Environmental responsibility policy statements affirming our commitment to compliance and continual improvement, shall be posted inside THEPI facility.
  1. The principles contained in Responsible Business Alliance (RBA)Code of Conduct.
  2. Adhere to all the requirements of the RBA Code of Business Conduct including labor and wages, health and safety, environmental compliance and ethics.
  3. Communicate our Corporate Social Responsibility requirements to our suppliers and will require our suppliers to acknowledge and implement the RBA Code.
Objective and Target:
  1. To uphold the human rights of workers and treat with dignity and respect.
  2. To minimize the incidence of work related injury and illness, a safe and healthy work environment enhances the quality of products and services, consistency of production and worker retention and morale.
  3. To recognize that environmental responsibility is integral to producing world class products
  4. To meet social responsibilities and to achieve success in the industry
  • THEPI shall identify senior executive and company representative[s] responsible for ensuring implementation of the management systems and associated programs.
  • THEPI shall identify, monitor and understand applicable laws, regulations and customer requirements including the requirements of this code.
  • The RBA Team composed of Section Managers and Section Head shall conduct the necessary identification, review and updating of the legal compliance, environmental, health and safety, labour practice and ethics risk associated with THEPI operations and determine the relative significance of each risk and implement appropriate procedural and physical controls to control the identified risks and ensure regulatory compliance.
THEPI shall systematically identify major risk relating to labour rights and working conditions in our operations and activities through the use of risk assessment and audit tools.
  1. All Departments – Following HR policy, all departments are requested to perform a gap analysis against our HR policy and define action plans. The HR department closely monitors this assessment.
  2. The Company – THEPI update the self-assessment questionnaire (SAQ) annually. THEPI will define specific actions to improve based on the result of SAQ.
  3. THEPI manages a road map to ensure monitoring for continuous improvement.
  • THEPI will create programs for training all employees on policies, procedures, knowledge and awareness on labour and human rights.
  • The company’s top management ensures that appropriate and adequate communication is being practiced within the company to ensure the effective implementation of THEPI RBA Manual. Various applicable communication methods are utilized taking advantage of the prevailing technology (e.g. Training, seminar, orientation, focus group discussion, email, memo, etc.)
  • THEPI shall have an on-going process, including an effective grievance mechanism, to assess employees’ understanding and obtain feedback on practices and conditions covered by this Code and to foster continuous improvement.
  • THEPI shall have periodic self-evaluations to ensure conformity to legal and regulatory requirements, the content of the Code and customer contractual requirements related to social and environmental responsibility.
  • THEPI shall have a process for timely correction of deficiencies identified by internal or external assessments, inspections, investigations and reviews.
  • THEPI shall have a process on maintenance of documents and records to ensure regulatory compliance and conformity to company requirements along with appropriate confidentiality to protect privacy.
  • THEPI will have a process to communicate the Code requirements to our suppliers and to monitor supplier conformance to the Code.