Albaugh’s Standards for Supplier Partners
Labor Practices
to support the protection of internationally proclaimed human rights, including minimum wage and working hours;
to prevent forced labor, child labor, harassment, discrimination and other unlawful conduct at the workplace; and
not to retaliate or permit retaliation against any person making a report or complaint or cooperating in an investigation regarding a violation of this Code.
Ethics
to comply with all applicable national and international antitrust and trade control regulations and with all applicable global anti-corruption laws including the U.S. Foreign Corrupt Practices Act;
to comply with Importer Security Filing (“ISF”) rules and regulations where applicable, and in any case to ensure product and shipment security;
not to permit bribery, kickbacks, extortion, embezzlement, or other corrupt practices either directly or indirectly;
not to engage in money laundering or any other handling of illicitly acquired funds;
to ensure components utilized in supplied products are acquired legally.
to not offer gifts or invitations other than of a de minimis value in alignment with lawful market practices and not having the potential to influence a business decision; and
to not create or maintain any situation that poses or could be construed to pose a conflict between the interests of Albaugh and the personal interests of Albaugh's employees or agents.
Environmental and Safety
to comply with all applicable environmental, health and safety regulations wherever they operate to ensure a sustainable operation; and
to ensure a safe work environment that minimizes accidents and worker exposures to health risks.
Confidentiality and Intellectual Property
to maintain business confidentiality with respect to all transactions with Albaugh, LLC, including to comply with all confidentiality and other agreements with Albaugh, LLC that relate to the products supplied to Albaugh, LLC;
to protect Albaugh, LLC’s confidential and proprietary information from unauthorized use; and
to respect Albaugh, LLC’s intellectual property rights including trade secrets, trademarks, product registration, and patent rights.
Suppliers are expected to promptly report any violations of this Code to Albaugh, LLC. Albaugh, LLC may further ask Suppliers to verify their compliance with this Supplier Code of Conduct through self-assessments, third party assessment, or on-site audits by representatives of Albaugh, LLC. Albaugh, LLC will reassess its relationship with suppliers who do not fully conform with this Supplier Code of Conduct
Statement on Transparency in Supply Chains
Introduction
Albaugh, LLC (“Albaugh”) makes this statement pursuant to section 54(1) of the Modern Slavery Act 2015, the UK Modern Slavery Act of 2015, and similar laws. This statement delineates the actions Albaugh and its subsidiaries take to identify potential modern slavery risks in our business operations and the steps implemented which are aimed at ensuring there is no slavery or human trafficking in our supply chains. Integrity and responsibility are the center of our core values. We maintain high standards of ethics and role-model behaviors in conducting our business. Albaugh is firmly against any form of forced labor, human trafficking, and slavery and will not condone any type of this prohibited, unlawful conduct by its employees, suppliers, vendors, or other business partners.
Albaugh, LLC’s Organization
Albaugh is a privately-held U.S. company specializing in the production and packaging of post-patent crop protection products. Albaugh’s business in the United States comprises sales of its products throughout the country. Albaugh operates as a global business and has subsidiaries and manufacturing facilities located within the U.S, Mexico, Brazil, Argentina and Europe where we manufacture, distribute and market crop protection products.
Albaugh’s Supply Chains
Albaugh’s supply chain is managed by our Group Procurement department which operates as a single global function, structured across all business lines. We develop and implement best-fit strategies for each category to deliver maximum value from the supply base in the areas of cost and risk management, sustainability, innovation, and growth. In addition to adherence to the Albaugh’s Supplier Code of Conduct, our key suppliers represent and warrant to us that they will perform their obligations to Albaugh in compliance with all applicable foreign, federal, state and local statutes and regulations.
Albaugh’s Relevant Policies
Albaugh operates under a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. Our Code of Ethics (“Code”) internal company policy provides important guidelines for Albaugh’s interactions with customers, suppliers and other business partners, and one another. The Code summarizes the policies and principles by which we commit ourselves to the safe, honest, thoughtful and responsible operation of all our businesses and facilities. Our commitment to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business is also embodied in the following Policies:
Supplier Code of Conduct
Responsible Care
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 the majority of our purchase orders and contract templates have been updated to include compliance as a contractual requirement.
Albaugh expects suppliers to implement systems and controls to promote compliance with applicable laws and the principles set forth in this Supplier Code of Conduct, including policies, training, monitoring and auditing mechanisms. Suppliers also should apply these or similar principles to the subcontractors and suppliers they work with in providing goods and services to Albaugh. Albaugh reserves the right to assess and monitor suppliers' compliance with this Supplier Code of Conduct. Suppliers who are not in compliance with this Supplier Code of Conduct are expected to implement corrective actions or may not be considered for future business.
Albaugh does not currently audit suppliers for compliance, however we have begun to evaluate whether to require compliance certifications, self-assessments and/or compliance audits.
Albaugh provides an anonymous Ethics Reporting Hotline operated by a third-party (telephone and web-based is available in multiple languages) to all employees and third parties, which can be used to seek guidance on specific situations, report violations of Albaugh’s Code of Ethics conduct, including our Supplier Code of Conduct or other unethical business practices. Calls may 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 issues in compliance. We conduct internal training on our Code of Ethics (“Code”) to ensure our employees understand our standards of conducting business with the highest degree of ethical behavior and in compliance with the law. All employees of Albaugh and its subsidiaries, including those with direct responsibility for supply chain management, are expected to know and abide by this Code. Violations of our Code may subject the employee to corrective action, including termination of employment. Albaugh takes seriously and fully investigates all potential legal or Code violations, in a respectful, confidential and fair manner and takes action consistent with the severity of the violation.
Approved by the Board of Managers August 19, 2020
Signed by Kurt Pedersen Kaalund, Chief Executive Officer and Manager
