Hopkins Supplier Principles

Principles for Doing Business With Hopkins

Hopkins Manufacturing Corporation, including all its subsidiaries (hereafter collectively “Hopkins”), believes in doing business with those Supplier Partners that embrace high standards of ethical business behavior and that demonstrate commitment to those standards in their contractor, subcontractor, and other business relationships. Hopkins believes in conducting all business activities with honesty, integrity, fairness and in compliance with all applicable laws and regulations as well as practices of their industry. Our reputation as a company and our business is dependent upon these beliefs.

Hopkins has developed these Principles in alignment with our commitment to be a good global citizen showing respect to individuals and providing a high level of service to our customers whom we ultimately rely on for the prosperity of our joint business ventures. Applying these Principles enables us to select business partners whose workplace standards and business ethics are consistent with Hopkins’ values. This policy applies to Suppliers and their sub-tier sources. It is the responsibility of the Supplier to verify and monitor compliance of these Principles at their operations and sub-tier source operations.

In addition to the Principles outlined in this document, many of our customers have their own policies and standards and require the right to audit the factory that produces product for them; in the event that a customer policy is not the same as outlined here, the more stringent of the two will apply. We expect full and complete compliance with our customer’s requirements and policies along with these Principles.

Hopkins Supplier Partners Are Expected To:

Produce and deliver quality products that meet or exceed the specifications and requirements as provided by Hopkins using the best raw materials, equipment, and knowledge;
Comply with these Principles and all applicable local and international laws and regulations;
Be socially and environmentally compliant in all countries and communities in which they do business;
Deploy all required and appropriate security controls and procedures;
Comply with intellectual property laws; and
Comply with anti-bribery and anti-corruption laws.

Supplier Partner Compliance

SUPERIOR PRODUCT – Supplier Partner is expected to produce superior quality for all our sourced products. Hopkins has committed to its customers to deliver the best products at the right price where product features, form, and fit exceed expectations in terms of performance and durability.

Hopkins is committed to selling quality products that are safe for their intended uses, conform to all laws and regulations and meet required product safety standards.

LAWS AND REGULATIONS – Supplier Partners are required to understand and commit to full compliance with all applicable laws and regulations for the jurisdictions where they conduct business.

LABOR LAWS –

Working Hours and Compensation – Supplier Partners will maintain reasonable employee work hours and compensation and comply with the legal maximum working hours and wages and benefits as specified by localities and a country/jurisdiction standards and laws where they conduct business.

Child Labor – Supplier Partners will employ workers in compliance with local labor laws including employment age regulations, however in no case will Supplier employ workers under the age of 16.

Forced Labor – Supplier Partners will not use services or sell raw materials or finished products that have been produced by forced or prison labor. Forced labor includes, but is not limited to, all forms of workers in the workplace, or upon entry and exit, and labor subject to arbitrary abuse. Supplier Partners will periodically, but no less than annually, conduct an audit of its own supply chain and products to ensure compliance.

Discrimination & Disciplinary Practices – Supplier Partners will employ people based on job related requirements and not based on personal or cultural characteristics or beliefs. Supplier Partners will not discriminate based on race, color, national origin, gender, sexual orientation, religion, disability, or other similar factors.

Employment Status – Supplier Partners will be responsible for ensuring validate worker eligibility documentation are maintained which demonstrates they are legally able to work.

Corporal Punishment – Supplier Partners will not employ any type of corporal punishment or other forms of mental or physical coercion.

HEALTH AND SAFETY – Supplier Partners will demonstrate concern for and commitment to the health and safety of their employees. Supplier Partners will provide an environment where there is proper and adequate consideration for the health and safety of its employees and provides the necessary personal protective equipment to safely complete assigned work. Supplier Partners will maintain required building permits, proper exits for emergency access, firefighting equipment, and emergency aid kits adequate for the size and population of workers, including housing and dining facilities provided to employees.

ENVIRONMENTAL REQUIREMENTS – Supplier Partners will share Hopkins’ commitment to the environment and pursue practices that conform to applicable environmental standards. Supplier Partners will promptly develop and implement plans and programs to correct any non-compliant practices. Supplier Partners will be committed to full compliance with all environmental rules, regulations, and standards applicable to products purchased from international locations and incorporate such practices as the reduction of waste, re-use and recycling where appropriate.

CONFLICT MINERALS – Supplier Partners will not purchase Conflict Minerals or do business with anyone or any company that sells or consumes Conflict Minerals extracted from a Covered Country; Conflict Minerals are cassiterite, columbite-tantalite, gold and wolframite, as well as their derivatives and other minerals that the US Secretary of State may designate in the future from a Covered Country, as defined in Section 1502 of the Dodd–Frank Act.

SECURITY AND SHIPPING COMPLIANCE – Supplier Partners will maintain all required and appropriate security at production and warehousing facilities. Supplier Partners will meet or exceed industry standards and comply with policies related to security, access and loading processes, seal management, and human resources practices, and such other security standards as Hopkins may direct from time to time. All information provided on packing lists, bills of lading, export paperwork, invoices and other documentation shall be accurate and complete to allow Hopkins to be able rely on.

Supplier Partners who are shipping containers to or on behalf of Hopkins will be responsible for monitoring their shipping process until such time as the container has passed the ship’s rail at the named port of shipment, including closing the container and sealing it with a Supplier Partner provided seal. The seal number must be referenced and identified as the seal number on all copies of the Bill of Lading. If the Supplier Partner fails to seal a container, the carrier will seal the container on Supplier Partner’s behalf. The carrier will then document that seal number on the Bill of Lading before providing Supplier Partner with its copy. If a shortage occurs, Supplier Partner shall be liable for such shortage.

Supplier Partner shall ensure that the product is not tampered with, that no additional items are inserted into the shipping container and that the supply chain is secure. Supplier Partner shall control access to warehouse, storage and shipping areas, monitor employees and visitors that may have access to product and shipping containers and establish adequate security procedures. Supplier Partner shall comply with the requirements of the factory/container security requirement notification received with each order. Supplier Partner shall permit Hopkins, its agents, or employees to inspect security measures, and will improve security as requested by Hopkins, the U.S. Customs and Border Protection Agency or other governmental agencies.

Supplier Partner shall provide Hopkins or its agent with all documentation necessary for the international shipment, exportation from the exporting country, and importation into and full release for consumption into the customs territory of the United States, Canada, or the final country of importation. This includes compliance with laws that regulate global trade including compliance with all governmental agencies. Supplier Partners shall promptly respond to requests by U.S. Customs and Border Protection Agency, other U.S. Government agencies, other governmental agencies, or Hopkins for additional documentation.

Supplier Partners will ensure all product markings are true, accurate and complete with records retained as required by the country of export and import and US or other customs requirements, as applicable. Supplier Partners will validate import and export shipment information upon request by Hopkins.

BUSINESS DEALINGS – Hopkins does not permit illegal payments to any Hopkins employee, our customer’s employees or their agents, or any other person, organization, or government. Supplier Partners must not give funds, property, special discounts, services, or labor, directly or indirectly to anyone in order to obtain business or any special or unusual treatment for Hopkins. This includes maintaining the highest standards of integrity in all aspects of an audit process. Any and all forms of bribery, corruption, deception, and records falsification are strictly prohibited. In certain cases, our customers will have policies that are more stringent and will prohibit the giving of customary small gifts such as pens, product samples, meals, or any other items. If you are unsure what is acceptable, you should ask a Hopkins representative or the customer representative before offering and giving. This restriction will include our direct and indirect Supplier Partners and their agents, representatives, employees, factories, officers and directors, and U.S. or foreign government officials or agents.

Hopkins is required to comply, and its Supplier Partners will comply with the United States Foreign Corrupt Practices Act of 1977 (FCPA) and the Canadian Corruption of Foreign Public Officials Act (CFPOA). The anti-bribery provisions of the FCPA, as amended in 1998, apply to any person who has a certain degree of connection to the United States and engages in foreign corrupt practices. The FCPA also applies to any act by U.S. businesses, foreign corporations trading securities in the United States, American nationals, citizens, and residents acting in furtherance of a foreign corrupt practice whether or not they are physically present in the United States. In the case of foreign natural and legal persons, the FCPA covers their actions if they are in the United States at the time of the corrupt conduct. Further, the FCPA governs not only payments to foreign officials, candidates, and parties, but any other recipient if part of the bribe is ultimately attributable to a foreign official, candidate, or party. These payments are not restricted to just monetary forms and may include anything of value. The FCPA applies to foreign firms and persons who cause, directly or through agents, an act in furtherance of such a corrupt payment to take place within the territory of the United States. The CFPOA provides that any person that commits an offence who, in order to obtain or retain an advantage in the course of business, directly or indirectly gives, offers or agrees to give or offer a loan, reward, advantage or benefit of any kind to a foreign public official or to any person for the benefit of a foreign public official (a) as consideration for an act or omission by the official in connection with the performance of the official’s duties or functions; or (b) to induce the official to use his or her position to influence any acts or decisions of the foreign state or public international organization for which the official performs duties or functions.

Supplier Partners will have a reporting mechanism for its employees to report workplace grievances in a confidential manner; an anonymous reporting mechanism is preferred and shall be in place where required by law. Supplier Partners shall not permit retaliation against workers who report workplace grievances in good faith.

Supplier Partners will maintain accurate books and records in reasonable detail to verify compliance with all agreements with Hopkins, including these Supplier Principles. Supplier Partners will promptly provide such records for inspection upon request by Hopkins. Supplier Partners will have a policy in place to retain, dispose or destroy business records that complies with applicable laws and requirements and in such a manner to protect confidential and proprietary information.

Supplier Partners shall promptly disclose to Hopkins all actual or potential conflicts of interest, whether business or personal, relating to their associates, suppliers, factories, and competitors of Hopkins.

Supplier Partners will ensure that its employees, agents, and subcontractors who perform work on Hopkins’ behalf understand the expectations agreed to in these Supplier Principles and Hopkins’ policies. Supplier Partners will retain records for Hopkins’s inspection that such training and communication has taken place.

INTELLECTUAL PROPERTY – Supplier Partners will comply with international Intellectual Property (IP) laws. We believe that compliance with IP laws fosters economic growth, provides incentives for technological innovation, and attracts investments that may create new jobs and opportunities. Supplier Partners should not knowingly infringe on another company or individual’s patent or trademark while producing any products for Hopkins.

Hopkins’ intellectual property, including trademarks, patents and information and knowledge about Hopkins’ systems, products and services belongs to Hopkins. Hopkins is the sole and exclusive owner of any intellectual property made, conceived or developed by a Supplier Partner in the course of its business relationship with Hopkins. This includes but is not limited to original artwork, photographs, written material, and inventions, patented or otherwise. Hopkins expects its Supplier Partners to use their best efforts protect its IP from unauthorized disclosure, to use only in the course of business associated with Hopkins and to respect the IP of other companies.

Supplier Partners will establish processes and programs to detect and prevent the use of materials of exact imitation with fraudulent brands or manufacturer’s names, or creation of counterfeit goods displaying unlicensed brands, trademarks or fraudulent manufacturer’s names.

PURCHASE ORDERS, INVOICING & PRICING – Supplier Partner will not ship any product or merchandise without a valid purchase order from Hopkins and will include that purchase order number on all documentation for shipments, packing lists and invoices. Purchase orders will be based on Hopkins’s record of the Supplier Partner’s prices and terms. The Supplier Partner must provide Hopkins with an accurate invoice reflecting the same pricing and terms as on our purchase order; in the event of any discrepancy, the terms and pricing on the Hopkins purchase order will prevail. Supplier Partner must provide Hopkins with proper documentation and support in writing 120 days in advance of any proposed change in terms or price; in no event will a price increase be effective with respect to an order pending at the time an increase is proposed. Supplier Partner will not change the factory approved by Hopkins to produce the product or merchandise or change any specifications of the product or merchandise or the source for materials deemed critical by Hopkins without the written approval from Hopkins in advance of any change; Supplier Partner will be required to submit sample parts and drawings reflecting such change as first articles to obtain approval for the proposed change. Any deviation from the above will result in delayed or denied payment or cancellation of the purchase order.

CONFIDENTIALITY – Supplier Partners agree to not disclose to others and will not use for its own purposes or the purpose of others any trade secrets, confidential information, knowledge, designs, data, skill, or any other information considered by Hopkins as “confidential”. Supplier Partners will not disclose personal information collected, used, or disclosed in the course of doing business with Hopkins.

TOOLING – Supplier Partners will not use any Hopkins owned tooling or Hopkins owned designs for product or packaging other than for the benefit of Hopkins without the express written permission of Hopkins. Any tooling paid for will be owned by Hopkins and clearly marked as “Property of Hopkins”; Supplier Partner shall use its best efforts to perform normal and customary maintenance to keep the tools in good working order and repair and protect them from damage.

To implement and monitor these standards for conducting business, Supplier Partner agrees that all factories supplying merchandise shall be subject to inspection by Hopkins, its customers, agents, or employees and, if applicable, governmental agencies. Supplier Partner shall notify Hopkins immediately if a Hopkins customer, U.S. Customs or Border Protection Agency schedules a visit or makes an unannounced visit to the production facilities of Supplier Partner or Supplier Partner’s Subcontractor(s) or factories and will allow Hopkins to be present for the visit when possible. Failure to notify Hopkins in advance of a scheduled visit, or immediate notification of an unannounced visit, shall be grounds for Hopkins to cancel any unshipped orders placed with the Supplier Partner.

Within 48 hours following such a visit, Supplier Partner will provide Hopkins a written summary of the visit or audit, including any issues that came up and how they were dealt with. In the event that an audit has unresolved issues, within ten days of the visit, Supplier Partner shall provide Hopkins a Corrective Action Plan to address the unresolved issues. Such Corrective Action Plan will include the specific actions, the dates to complete and the person who is to be responsible for completion. Supplier Partner will advise Hopkins of completion of the Corrective Action Plan and any deviation from the plan as provided.

Hopkins shall have the right, on its own or through an independent agent to: (i) inspect at any time during normal business hours all production facilities where the merchandise is being produced or being stored and any merchandise being produced or stored; (ii) inspect and/or test merchandise prior to shipment; (iii) inspect and review any documentation and procedures in place for production, quality assurance and compliance with these Principles; and (iv) compliance with any Corrective Action Plans submitted to Hopkins. Supplier Partner shall cooperate with such inspections and/or tests and provide all reasonable assistance for the safety and convenience of such inspectors in the performance of such inspections, including providing adequate support and cooperation at the production facilities.

Hopkins, on its own or through an agent, shall have the right to make unannounced visits to Supplier Partner’s production facilities, and those of any subcontractor(s), for purposes of reviewing production records, and any other documents requested by Hopkins.