Corporate Code of Responsibilities
Lake Region Medical, Inc.
Company and Supplier
Environmental, Social and Governance Code of Responsibilities
Lake Region Medical, Inc. (“Lake Region Medical”) is committed to ensuring that working conditions in Lake Region Medical’s facilities and, to the extent possible, throughout its supply chain, are safe, that all employees are treated with respect and dignity, and that sourcing and manufacturing processes are managed in an environmentally and socially responsible fashion. The most fundamental aspect of these objectives is the need to understand and comply with the applicable laws, rules, and regulations of the legal federal, state and local jurisdictions in which an organization operates. This Code of Responsibilities (“Code”) goes beyond compliance, drawing upon internationally recognized standards and best practices, in order to advance social and environmental responsibility. Lake Region Medical is, to the best of its ability, committed to developing and implementing those relevant policies and procedures that will facilitate the execution of this Code. Likewise, Lake Region Medical expects that its suppliers will also strive in all regards to meet or exceed the standards and practices described within this document.
Lake Region Medical referenced various resources and examples in developing this Code, including the Electronic Industry Citizenship Coalition (EICC) Code, the International Labor Organization Standards (ILO), the Universal Declaration of Human Rights (UDHR), Social Accountability International (SAI) guidelines, and the Ethical Trading Initiative (ETI). Lake Region Medical will continue to develop and/or maintain detailed standards that serve to clarify the manner in which we will operate our business relative to this Code along with expectations for compliance among our suppliers and other affected partners.
Section I: Labor and Human Rights
Lake Region Medical and its suppliers must uphold the human rights of all employees, whether full-time, part-time, temporary, student, contract or other employment status, and treat them with dignity consistent with standards and practices recognized by the international community.
Lake Region Medical and its suppliers will not discriminate against any employee based on family status, civil status, race, color, age, gender, sexual orientation, ethnicity, disability, religion, political affiliation, union membership, national origin, marital status, veteran status, genetic disposition or carrier status, or any other legally protected basis, in hiring and employment practices such as applications for employment, promotions, rewards, access to training, job assignments, wages, benefits, discipline and termination. Lake Region Medical and its suppliers will not discriminate against pregnant employees or require a pregnancy test except where required by applicable laws or regulations or deemed prudent for protecting individual well-being or overall workplace safety. In addition, Lake Region Medical and its suppliers will not utilize medical testing of employees or potential employees for discriminatory purposes. Lake Region Medical and its suppliers may require certain medical testing where specified by applicable law or regulation or deemed prudent for protecting individual well-being or overall workplace safety.
Lake Region Medical and its suppliers must be committed to a workplace free of harassment. Lake Region Medical and its suppliers will not threaten employees with, or subject them to inappropriate behavior or practices, including sexual harassment, sexual abuse, corporal punishment, mental coercion, physical coercion, verbal abuse or unreasonable restrictions on entering or exiting company provided facilities.
Prevention of Involuntary Labor
Lake Region Medical and its suppliers will not use any form of forced, bonded, indentured, or prison labor. All work must be voluntary and employees will be free to leave work or terminate their employment. Employees must not be required to surrender any government-issued identification, passports, or work permits as a condition of employment. Lake Region Medical and its suppliers will ensure that third party labor agencies providing employees are compliant with the provisions of the Code and applicable laws and regulations. Lake Region Medical and its suppliers will ensure that contracts for both direct and contract employees clearly convey the conditions of employment in a language understood by the employee. Where applicable, employees will not be charged any excessive fees and all fees charged to employees must be fully disclosed.
Prevention of Under Age Labor
Child labor is strictly prohibited. Lake Region Medical and its suppliers will adhere to the Lake Region Medical Policy on Employment of Young Persons. The minimum age for employment or work will be 16 years of age. No person between the ages of 16 and 18 will be employed unless such employment is in compliance with the health, safety and morals provisions of the International Labour Organization (“ILO”) Convention No. 138.
Work weeks are not to exceed the maximum set by law within the operating region. Further, a workweek should not be more than 60 hours per week, including overtime, except in emergencies or when unusual business/customer situations so warrant.
Wages and Benefits
Lake Region Medical and its suppliers must pay all employees at least the minimum wage required by applicable laws and regulations and provide all legally mandated benefits. In addition to their compensation for regular hours of work, employees must be compensated for overtime hours at the rate required by applicable laws and regulations at a minimum. Lake Region Medical and its suppliers will not use deductions from wages as a disciplinary measure, except where permissible by law and then only after documented due process indicates such measures are warranted and appropriate. Employees must be paid in a timely manner, and the basis on which employees are being paid must be clearly conveyed to employees in a timely manner.
Freedom of Association
Lake Region Medical and its suppliers must respect the right of employees to associate freely, form and join employees organizations of their own choosing, seek representation, and bargain collectively, as permitted by and in accordance with applicable laws and regulations. Lake Region Medical and its suppliers will not specify non-union membership as a condition of employment. Lake Region Medical and its suppliers must protect against acts of interference with the establishment, function, or administration of employees’ organizations in accordance with applicable laws and regulations. All employees must be able to openly present grievances concerning the work environment or management practices without fear of reprisal.
Section II: Health and Safety
Lake Region Medical recognizes that integrating sound health and safety management practices into all aspects of business is essential in effectively managing risks and minimizing work related incidents while enhancing the quality of products and improving employee morale and retention. Suppliers must also be committed to creating safe working conditions and a healthy work environment for all of their employees.
Occupational Injury Prevention
Lake Region Medical and its suppliers must eliminate physical hazards where possible. Where physical hazards cannot be eliminated, Lake Region Medical and its suppliers must provide and maintain appropriate engineering controls such as physical guards, interlocks, and barriers where machinery and equipment present a risk of injury to employees and operators. Where engineering controls are not possible or feasible, Lake Region Medical and its suppliers must establish appropriate administrative controls such as safe work procedures. In all cases, Lake Region Medical and its suppliers must provide employees appropriate personal protective equipment relative to the physical hazards in the workplace that cannot be adequately minimized through engineering and/or administrative controls. Employees must have the right to refuse unsafe working conditions without fear of reprisal until management adequately addresses their concerns.
Industrial Hygiene/Prevention of Chemical Exposure
Lake Region Medical and its suppliers must identify, evaluate, and control employee exposure to hazardous chemical, biological, and physical agents. Lake Region Medical and its suppliers must eliminate chemical hazards where possible. Where chemical hazards cannot be eliminated, Lake Region Medical and its suppliers must provide appropriate engineering controls such as closed systems and ventilation. Where engineering controls are not possible or feasible, Lake Region Medical and its suppliers must establish appropriate administrative controls such as safe work procedures. In all cases, Lake Region Medical and its suppliers must provide employees appropriate personal protective equipment relative to chemical hazards in the workplace that cannot be eliminated or minimized through engineering and/or administrative controls.
Emergency Prevention, Preparedness, and Response
Lake Region Medical and its suppliers must anticipate, identify, and assess emergency situations and events and minimize their impact by implementing emergency plans and response procedures that include emergency reporting, employee notification and evacuation procedures, employee training and drills, provision of appropriate first-aid supplies, fire detection and suppression equipment, adequate exit facilities, and recovery plans.
Occupational Safety Procedures and Systems
Lake Region Medical and its suppliers must establish procedures and systems to manage, track, and report occupational injury and illness. Such procedures and systems should encourage incident reporting, classification and recording of all work-related injuries and illnesses, incident analysis to determine root cause and implementation of corrective measures to eliminate or minimize the likelihood of recurrence, provision of necessary medical treatment, and facilitation of the employees’ return to work.
Ergonomics/Physically Demanding Work
Lake Region Medical and its suppliers must identify, evaluate, and control employee exposure to physically demanding tasks, including manual material handling, heavy lifting, prolonged standing, extended work in awkward posture(s) and highly repetitive tasks or tasks requiring forceful exertions. Such hazards will be addressed through engineering controls wherever feasible, such as lift assist devices and features that allow for appropriate workstation adjustability. Administrative controls, such as job rotation and training, will also be considered and implemented in addition to engineering controls to ensure a comprehensive approach to managing recognized risk. Employee engagement is an essential element within the process of identifying effective ergonomic risk controls and will be integral to the overall ergonomic program strategy.
Dormitory and Dining
Lake Region Medical and its suppliers must provide employees with clean sanitation facilities, access to potable water, and sanitary food preparation and storage facilities. Worker dormitories provided by the employer or a labor agent must be clean and safe and provide adequate emergency egress, adequate heat and ventilation, reasonable personal space, and reasonable entry and exit privileges.
In order to foster a safe work environment, Lake Region Medical and its suppliers will ensure that employees receive appropriate workplace health and safety information and training, including written health and safety information and warnings in the primary language of its employees. Lake Region Medical and its suppliers must provide (Material) Safety Data Sheets in the primary language of its employees for any hazardous or toxic substances used in the workplace and properly train employees who will come into contact with such substances in the workplace.
Employee Environmental, Health and Safety Committees
Lake Region Medical and its suppliers are encouraged to initiate and support employee environmental, health and safety committees to enhance ongoing environmental, health and safety education and to encourage employee input regarding environmental, health and safety issues in the workplace.
Section III: The Environment
Lake Region Medical and its suppliers must recognize environmental responsibility as an integral part of all business practices. Lake Region Medical expects its suppliers to actively support objectives and initiatives focused on reducing the environmental impact associated with product and process design, facility operation, and waste generation/emission.
Hazardous Substance Management and Restrictions
Lake Region Medical and its suppliers must comply with the most recent version of any applicable laws, directives and regulations prohibiting or restricting specific substances. To ensure safe handling, movement, storage, recycling, reuse, and disposal, Lake Region Medical and its suppliers must identify and manage substances that pose a hazard if released to the environment and comply with applicable labeling laws and regulations for recycling and disposal.
Wastewater and Solid Waste Emissions
Wastewater and solid waste generated from operations, industrial processes, and sanitation facilities must be monitored, controlled, and treated as required by applicable laws and regulations before discharge or disposal.
Air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting chemicals, and combustion by-products generated from operations must be characterized, monitored, controlled, and treated as required by applicable laws and regulations before discharge.
Environmental Permits and Reporting
Lake Region Medical and its suppliers must obtain and maintain all required environmental permits and registrations (e.g. air emissions, waste water discharge, stormwater control, hazardous waste disposal) and adhere to all operational and reporting requirements.
Pollution Prevention and Resource Preservation
Lake Region Medical and its suppliers must endeavor to reduce or eliminate waste of all types, including hazardous, non-hazardous, water and energy wastes, by implementing appropriate measures in their facilities, and in their maintenance and production processes, with specific focus on opportunities to recycle, re-use, or substitute potentially harmful materials. Life cycle analysis throughout the supply chain is encouraged to facilitate resource preservation and overall sustainability.
Product Content/Origin Restrictions
Lake Region Medical and its suppliers will adhere to all applicable laws, directives, regulations regarding prohibition or control of restricted substances and origin of raw materials used in the manufacture of products, including those related to labeling, packaging, recycling and disposal. Lake Region Medical and its suppliers will practice reasonable due diligence, as defined or represented within current and recognized industry practices, in the characterization of applicable parts and products relative to restricted substance or sourcing regulations, requirements and reasonable customer requests, examples of which include REACH, RoHS and Section 1502 of the Dodd-Frank Act. Documentation of such efforts will be compiled and maintained according to specified timeframes within pertinent regulations and/or agreements. Lake Region Medical suppliers are expected to fully cooperate in the product characterization process upon request, particularly with respect to provision of compliance statements and other forms of recognized documentation of product composition. Any expenses associated with the characterization process are to be considered a cost of doing business and may not be passed on to Lake Region Medical unless contractually specified.
Section IV: Ethics
Lake Region Medical and its suppliers must be committed to the highest standards of ethical conduct when dealing with employees, suppliers, and customers. Lake Region Medical has adopted a zero tolerance policy regarding violations of certain business ethics and will take immediate and appropriate measures to address non-compliance with stated requirements and expectations.
Corruption, Extortion, or Embezzlement
Corruption, extortion and embezzlement, in any form, are strictly prohibited. Lake Region Medical and its suppliers will not engage in corruption, extortion or embezzlement in any form. Violations of this prohibition may result in immediate termination as a Lake Region Medical employee or supplier. Lake Region Medical reserves the right to take legal action in connection with any violation of these prohibitions.
Disclosure of Information
Lake Region Medical and its suppliers must disclose information regarding business activities, structure, financial situation and performance in accordance with applicable laws and regulations and prevailing industry practices. Falsification of records or intentional misrepresentation of conditions or practices is unacceptable and will result in appropriate corrective action.
Lake Region Medical and its suppliers must be committed to protecting the reasonable privacy expectation of personal information within all levels of business including suppliers, customers, consumers and employees. Lake Region Medical and its suppliers must comply with privacy and information security laws and regulatory requirements wherever personal information is collected, stored, processed, transferred and shared.
No Improper Advantage
Lake Region Medical and its suppliers must not offer or accept bribes or other means of obtaining undue or improper advantage, including personal fees, gifts or favors. Lake Region Medical is sensitive to even the potential appearance of improper interactions. Lake Region Medical employees who fail to comply with these requirements will be promptly disciplined as appropriate, up to and including termination. Suppliers failing to comply with this guidance may be disqualified from conducting business with Lake Region Medical.
Fair Business, Advertising, and Competition
Lake Region Medical and its suppliers must uphold fair business standards in advertising, sales and competition.
Whistleblower Protection and Anonymous Complaints
Lake Region Medical and its suppliers must create programs to ensure the protection of whistleblower confidentiality and prohibit retaliation against employees who participate in such programs in good faith or refuse an order that is in violation of their respective Codes of Conduct Lake Region Medical and its suppliers will provide an anonymous complaint mechanism for employees to report actual or perceived accounting or auditing improprieties in accordance with local laws and regulations.
Lake Region Medical and its suppliers are encouraged to engage the community to help foster social and economic development and to contribute to the sustainability of the communities in which they operate.
Lake Region Medical and its suppliers must define processes and practices that establish a fair, open and inclusive business environment that ensures a diverse supply chain of capable, qualified business partners. Lake Region Medical may periodically require its suppliers to report activities that support Supplier Diversity initiatives within their specific supply chains.
Protection of Intellectual Property
Lake Region Medical and its suppliers must respect intellectual property rights; safeguard customer information; and transfer of technology and know-how must be done in a manner that protects intellectual property rights.
Responsible Sourcing of Materials
Lake Region Medical and its suppliers must take all reasonable measures to assure that conflict minerals are not supplied nor used in the manufacturing of parts of products. Conflict minerals include, but are not limited to, tin, tantalum tungsten and gold that originate from the Democratic Republic of the Congo and adjoining countries or other regions where the purchase of specific minerals may benefit groups that perpetuate the abuse of serious human rights. Lake Region Medical and its suppliers will practice an appropriate level of due diligence to ascertain the origin of conflict minerals.
Section V: Management Systems
Lake Region Medical and its suppliers must adopt or establish a management system designed to ensure compliance with this Code and applicable laws and regulations, identify and mitigate related operational risks, and facilitate continuous improvement. ISO 14001, OHSAS 18001, Eco Management and Audit System (EMAS) are examples of useful resources in establishing an appropriate management system. The management system should contain the following elements:
A corporate social and environmental responsibility statement affirming the organization’s commitment to compliance and continual improvement. This statement should be posted or otherwise communicated in the primary local language at all worksites.
Management Accountability and Responsibility
Clear identification of company representatives responsible for ensuring implementation and periodic review of the status of the organization’s management systems.
Legal and Customer Requirements
A process to identify, monitor and understand applicable laws and regulations and the additional requirements imposed by this Code.
Risk Assessment and Management
A process to identify environmental, health and safety, business ethics, labor, human rights and legal compliance risks associated with their operations, determine the relative significance of each risk, and implement appropriate procedures and physical controls to ensure compliance and control the identified risks.
Performance Objectives with Implementation Plans and Measures
Written standards, performance objectives, targets and implementation plans, including a periodic assessment of the organizational performance against those objectives.
Programs for training managers and employees to implement the organization’s policies, procedures and improvement objectives.
A process for communicating clear and accurate information about the organization’s performance, practices, and expectations to its employees, suppliers, contractors, subcontractors and customers.
Employee Feedback and Participation
An ongoing process to obtain feedback on processes and practices related to this Code and to foster continuous improvement.
Audits and Assessments
Periodic self-evaluations and third party reviews to ensure that all levels of the supply chain are complying with this Code and with applicable laws and regulations. Lake Region Medical may request to visit and/or request that external monitors be permitted to visit supplier, contractor and subcontractor facilities, to assess compliance with this Code.
Corrective Action Process
Implementation of a process for timely correction of any deficiencies identified by an internal or external audit, assessment, inspection, investigation or review. This process will include specific consequences for those situations in which it is determined that a responsible party has not met or achieved the defined corrective actions in a timely and acceptable manner.
Documentation and Records
Creation of documents and records to ensure regulatory compliance and conformity to this Code, with appropriate confidentiality measures to protect privacy.
Eco Management & Audit System www.quality.co.uk/emas.htm
Electronic Industry Code of Conduct, October 2004
Ethical Trading Initiative www.ethicaltrade.org/
ILO Code of Practice in Safety and Health
ILO International Labor Standards
ISO 14001 www.iso.org
National Fire Protection Agency
OECD Guidelines for Multinational Enterprises www.oecd.org
United Nations Convention Against Corruption
www.unodc.org/unodc/en/crime convention corruption.html
United Nations Global Compact www.unglobalcompact.org
Universal Declaration of Human Rights www.un.org/Overview/rights.html
UN Norms on the Responsibilities of Transnational Corporations and other Business Enterprises with Regard to Human Rights