This policy is intended to reflect the extension of Brooks’ commitment to corporate responsibility to our supply base. While Brooks recognizes that there are different legal and cultural environments in which suppliers operate throughout the world, these policies establish a framework that Brooks considers important to the management of manufacturing and distribution operations to minimize adverse impact to the environment, to a healthy and safe workplace, to the maintenance of fair and reasonable labor practices and to the content of materials supplied to Brooks. We expect Brooks’ suppliers to conduct their operations in a socially and environmentally responsible manner, and we will work collaboratively with our suppliers to encourage compliance with the following principles:
- Legal and Regulatory Compliance: Suppliers are to ensure their operations and the products and services supplied to Brooks comply with all national and other applicable laws and regulations.
- Environmental, Health and Safety (EHS): Suppliers are expected to provide workers with a safe and healthy work environment and to manage their operations to minimize impact to the environment and community. Suppliers are expected to establish and maintain a management system or program that encourages continual improvement in EHS performance.
- Conflict Minerals: Suppliers are expected to ensure that parts and products supplied to Brooks are DRC conflict-free (do not contain metals derived from “conflict minerals”; columbite-tantalite (tantalum), cassiterite (tin), gold, wolframite (tungsten), or their derivatives such that they do not directly or indirectly finance or benefit armed groups through mining or mineral trading in the Democratic Republic of the Congo or an adjoining country). Suppliers are to establish policies, due diligence frameworks, and management systems, consistent with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, that are designed to accomplish this goal.
- Labor and Human Resources: Suppliers are expected to comply with all local country labor and human resource laws and regulations, including those related to wages, hours worked, working conditions and child labor. Suppliers are also expected to adopt sound labor and human resource practices and treat their workers fairly. Specifically:
- Employment Practices. Suppliers must hire and employ workers in compliance with applicable laws. Wages, benefits, and working hours are expected to be fair and reasonable in the local labor market.
- Child Labor. Suppliers must comply with the applicable local laws with regard to the minimum hiring age for employees.
- Forced Labor. Brooks expects suppliers to not use labor that is a result of mental or physical coercion, physical punishment, slavery or other oppressive labor conditions. Suppliers and their employees cannot engage in any form of human trafficking.
- Freedom of Association. Suppliers must respect workers’ right to associate freely, in compliance with existing local laws and without intimidation, reprisal or harassment.
- Management Systems: Suppliers are to maintain effective management systems that integrate environmental, occupational health and safety, human rights and labor policies, and ethics into their business and decision-making processes. This includes establishing appropriate objectives and targets, regularly measuring and assessing performance, and practicing continual improvement.
- Information Access: Suppliers are to provide clear, timely, accurate and appropriate reporting to Brooks upon request. This includes information pertaining to country of manufacturer (country of origin) as well as any additional product information Brooks may require to ensure compliance with import/export Regulations.
In selecting and retaining qualified suppliers, Brooks will show preference to suppliers that meet the above requirements.