CODE OF CONDUCT FOR SUPPLIERS OF ALBAUGH LATAM SOUTH.
Albaugh Latam South (hereinafter "Albaugh") expects its suppliers, contractors, subcontractors, and third parties with whom it interacts to comply with all applicable national, provincial, and/or municipal laws and regulations applicable to the locations and workplaces where they own and carry out their operations. Similarly, such third parties must adhere to internationally recognized standards regarding labor, ethics, and environmental care.
Albaugh expects its suppliers, contractors, subcontractors, and third parties with whom it interacts to comply with the following guidelines when providing their services:
(i) Human Rights and Labor Practices
• Support the protection of internationally recognized human rights, including respect for minimum wage, working hours, and freedom of association;
• Prevent forced labor, child labor, harassment, discrimination, and other unlawful behaviors in the workplace; and
• Refrain from retaliating against any person who files a complaint or cooperates in an investigation regarding a breach of this Code.
(ii) Anti-Corruption, Ethics, and Transparency
• Respect and comply with prevailing regulations on competition defense and fair trade, as well as all anti-corruption regulations, including the Penal Code, the United Nations Convention against Corruption, and the U.S. Foreign Corrupt Practices Act (FCPA);
• Provide all documentation guaranteeing the safety of the products and/or services supplied and/or provided to Albaugh and their transportation;
• Avoid gifts, bribes, kickbacks, extortion, embezzlement, or other corrupt practices, whether directly or indirectly;
• Refrain from engaging in money laundering activities or any manipulation of illicitly acquired funds; and
• Ensure that all components used in the products and/or services supplied to Albaugh are legally obtained.
(iii) Occupational Safety, Health, and Environment
• Respect and comply with all environmental, health, and occupational safety regulations at the national, provincial, and/or municipal level applicable wherever they operate to ensure sustainable operations; and
• Guarantee that their activities will have the necessary environmental permits and licenses and will be conducted within a safe working environment that minimizes accidents and workers' exposure to risks.
(iv) Confidentiality and Intellectual Property
• Maintain confidentiality regarding all transactions carried out with Albaugh, committing to comply – directly and ensuring their dependents comply – with all confidentiality agreements and other agreements made with Albaugh related to the products supplied and/or services provided to Albaugh;
• Protect Albaugh's confidential information from unauthorized use; and
• Respect Albaugh's intellectual property rights, including trade secrets, trademarks, product registrations, and patent rights, among others.
• Ensure compliance with applicable data protection regulations.
As a result, Albaugh will consider the continuity of the contractual relationship with those suppliers who are not in full compliance with this Supplier Code of Conduct and may terminate the relationship with those who knowingly violate the provisions of this Supplier Code of Conduct and refuse to implement corrective measures.
Contact Information
Albaugh expects its suppliers, contractors, subcontractors, and third parties with whom it interacts in the course of its business to report any violations of this Code promptly. All communications related to this Code may be sent to the following email: requerimientosclientes@albaugh.com.ar
Statement on Supply Chain Transparency
Introduction
Albaugh, LLC ("Albaugh") makes this statement in accordance with Section 54 (1) of the Modern Slavery Act 2015, the UK Modern Slavery Act 2015, and similar laws. This statement outlines the actions Albaugh and its subsidiaries are taking to identify potential risks of modern slavery in our business operations and the steps implemented to ensure the absence of slavery or human trafficking in our supply chains. Integrity and responsibility are at the core of our values. We uphold high standards of ethics and exemplary behaviors in conducting our business. Albaugh is firmly opposed to any form of forced labor, human trafficking, and slavery, and will not condone any such prohibited and illegal conduct by its employees, suppliers, vendors, or other business partners.
Albaugh, LLC Organization
Albaugh is a privately held U.S. company specializing in the production and packaging of post-patent crop protection products. Albaugh's activities in the United States include the sale of its products nationwide. Albaugh operates as a global company with subsidiaries and manufacturing facilities located in the U.S., Mexico, Brazil, Argentina, and Europe, where it manufactures, distributes, and markets crop protection products.
Albaugh's Supply Chain
Albaugh's supply chain is managed by our Group Purchasing Department, which operates as a single global function structured across all business lines. We develop and implement the most appropriate strategies for each category to derive maximum value from the supply base in cost and risk management, sustainability, innovation, and growth. In addition to adhering to Albaugh's Supplier Code of Conduct, our key suppliers declare and guarantee that they will fulfill their obligations to Albaugh in compliance with all applicable foreign, federal, state, and local laws and regulations.
Relevant Albaugh Policies
Albaugh operates under a series of internal policies to ensure we conduct business in an ethical and transparent manner. Our Code of Ethics ("Code"), an internal company policy, provides important guidelines for Albaugh's interactions with customers, suppliers, and other business partners, and among each other. The Code summarizes the policies and principles by which we commit to safe, honest, thoughtful, and responsible operation of all our businesses and facilities. Our commitment to ensuring that no modern slavery or human trafficking exists in our supply chains or any part of our business is also reflected in the following Policies:
Supplier Code of Conduct
Responsible Conduct
Albaugh's Due Diligence Processes
Albaugh's Supplier Code of Conduct specifically addresses this aspect. The Supplier Code of Conduct is communicated to all current and new direct suppliers, and most of our purchase orders and contract templates have been updated to include compliance with it as a contractual requirement.
Albaugh expects suppliers to implement systems and controls to promote compliance with applicable legislation and the principles outlined in this Supplier Code of Conduct, including policies, training, and monitoring and auditing mechanisms. Suppliers must also apply these principles or similar ones to subcontractors and suppliers they work with to supply goods and services to Albaugh. Albaugh reserves the right to assess and monitor suppliers' compliance with this Supplier Code of Conduct. Suppliers who fail to comply with this Code of Conduct are expected to implement corrective actions, under the warning of not being considered for future business.
Currently, Albaugh does not conduct compliance audits of its suppliers; however, we have begun evaluating the possibility of requiring compliance certifications, self-assessments, and/or audits.
Albaugh provides all its employees and third parties with an anonymous hotline operated by third parties (by phone and via the Internet, available in several languages), which can be used to seek guidance on specific situations, report violations of Albaugh's Code of Ethics, including our Supplier Code of Conduct or other unethical business practices. Calls can be made anonymously in most countries, and callers are protected from retaliation.
Company Training
Albaugh strives to maintain an internal training curriculum that is reviewed annually for new compliance topics. We conduct internal training on our Code of Ethics ("Code") to ensure our employees understand our standards for conducting business with the highest degree of ethical behavior and in compliance with the law. All Albaugh employees and subsidiaries, including those with direct responsibility for supply chain management, are expected to know and comply with this Code. Violations of our Code may subject employees to corrective action, including termination. Albaugh takes all potential legal or Code violations seriously, investigates them thoroughly in a respectful, confidential, and fair manner, and takes actions commensurate with the severity of the violation.
Approved by the Board of Directors on August 19, 2020
Signed by Kurt Pedersen Kaalund, Chief Executive Officer and Manager
