Supplier Code of Conduct

Purpose

Welch Foods Inc., A Cooperative (referred to as “we”, “our”, “us”, or “Welch”) is committed to building a better tomorrow for our planet and our people. This commitment comes to life through our sustainability strategy, Growing Tomorrow Together, which is deeply engrained in our values and operations.

For more than 150 years, Welch’s has operated with high ethical business standards and integrity in the communities where we work and live. We know that businesses acting sustainably, ethically, and with high moral standards is vital to the customers, consumers, and communities that we serve. We also know that Welch’s commitment does not end at our four walls but extends to our entire supply chain. It is the responsibility of all businesses, as corporate citizens of the world, to build a sustainable future.

Welch has created this Supplier Code of Conduct (“Supplier Code”) as an extension of our own Code of Ethics and Business Conduct to form the cornerstone of our commitment to responsibly source our goods and services. We expect our Suppliers across the globe to commit to and uphold the same high standards of social and environmental responsibility to which we hold ourselves and our Supplier Code reflects this.

Welch considers our Suppliers as a critical and necessary extension of our mission, operations, and future success, and we thank you for continuing to make compliance and ethics a top priority.

Scope

This Supplier Code applies to all third parties that provide goods or services to Welch (“Suppliers”, also referred to as “you” or “your”)

Policy Statement:

This Supplier Code sets forth the basic and minimal expectations that all Suppliers must meet to do business with Welch. We expect our Suppliers to conduct business responsibly, with integrity, honesty, and transparency and adhere to the following principles:

Business Ethics and Integrity

Compliance with Laws

Welch is committed to conducting business ethically and lawfully in countries where we operate across our supply chain. We conduct business with Suppliers who demonstrate a strong commitment to ethical behavior and expect our Suppliers to comply with applicable laws, rules, regulations, and codes of the countries and jurisdictions in which they do business. They must also comply with all other applicable international laws and regulations, including those relating to international trade, sanctions, export controls, antitrust/competition, and privacy and data protection. Where local law and this Code address the same topic, the Supplier shall meet the requirement which affords greater protection.

Bribery/Corruption

All forms of bribery, kickbacks, corruption, extortion, embezzlement and unethical practices are prohibited, and Suppliers must have a zero-tolerance policy and prohibit such behavior. Suppliers must not take any action that would violate, or cause Welch to violate, any applicable anti-bribery law or regulation, including the U.S. Foreign Corrupt Practices Act.

Competition

Suppliers’ business dealings should be fair, legal, and honest. Suppliers must not engage in illegal cooperation with competitors including bid rigging, price fixing, market allocations, or any other prohibited conduct that limits free and fair competition.

Books and Records

Suppliers must maintain accurate books and records in accordance with all applicable legal and regulatory requirements and accepted accounting practices. Suppliers must maintain necessary documentation to demonstrate compliance with this Supplier Code and all applicable laws, and make these documents available to Welch upon request.

Conflicts of Interest

Supplier will declare any conflict of interest in any business dealing with Welch and will actively seek to avoid such conflicts.

Confidential and Proprietary Information

Welch’s confidential information and intellectual property must be safeguarded and must not be shared with any third party unless expressly permitted by Welch. Any authorized transfer of confidential information shall be done in a way that protects intellectual property rights.

Gifts and Entertainment

Suppliers shall refrain from offering gifts and/or excessive hospitality to Welch employees or its designated representatives which may inappropriately influence, or perceive to influence, Welch’s business decisions or gain an unfair advantage.

Human and Labor Rights

Welch’s is committed to respecting the human rights of individuals across our supply chain. We expect Suppliers to treat all workers with respect and dignity. Harsh and inhumane treatment is prohibited, including any physical or sexual harassment or abuse, corporal punishment, mental or physical coercion or verbal abuse of workers, or the threat of any such treatment.

Forced Labor and Human Trafficking

Welch is committed to a work environment that is free from human trafficking, slavery, and forced labor. Suppliers must not engage in any practice that constitutes trafficking in persons or slavery and must only utilize voluntary labor by workers who are allowed freedom of movement. These prohibited practices include, but are not limited to, the following:

Engaging in any form of trafficking in persons.
Procuring commercial sex acts.
Using forced labor in the performance of any work.
Destroying, concealing, confiscating, or otherwise denying access by an individual to the individual’s identity or immigration documents, such as passports or drivers’ licenses, regardless of issuing authority.
Using misleading or fraudulent practices during the recruitment of candidates or offering of employment/contract positions.
Using recruiters that do not comply with local labor laws of the country in which the recruiting takes place.
Charging applicants/candidates recruitment fees.
If required by law or contract, failing to provide return transportation or failing to pay for the cost of return transportation upon the end of employment.
If required by law or contract, failing to provide or arrange housing that meets the host country’s housing and safety standards.
If required by law or contract, failing to provide an employment contract, recruitment agreement, or other required work document in writing.

Child Labor

Welch does not tolerate child labor in its supply chain. Suppliers must maintain documentation of each individual’s date of birth and must be able to confirm each individual’s age.

Working Hours, Compensation, and Benefits

Welch is committed to upholding applicable laws and collective bargaining agreements regarding working hours, wages, benefits, and paid leave for individuals employed throughout the supply chain. Suppliers shall fairly compensate all employees with wages, overtime premiums, and benefits that meet or exceed all applicable legal requirements or collective bargained agreements. Welch expects its Suppliers to comply with all applicable wage and hour laws, and rules and regulations, including minimum wage, overtime, and maximum hours. Where collective bargaining or other industry agreements set more favorable terms for employees, Suppliers must abide by these. Supplier also must comply with all applicable laws regarding regular working hours, rest periods, and overtime hours.

Fair and Equal Treatment

Welch is committed to a policy of equal opportunity and an environment free from harassment and discrimination prohibited by law. We expect our Suppliers to value human rights and provide a workplace in which all employees are treated with dignity and respect. Supplier must ensure fair and equal treatment of all employees. Harassment, including unwelcome verbal, physical, or other conduct of any kind that creates an intimidating, offensive, or hostile work environment is not tolerated.

Health and Safety

Welch is committed to operating its facilities in a manner that protects human health and safety as well as the environment. Suppliers are expected to provide a safe, clean, and healthy working environment that minimizes exposure to accidents and injuries to their employees and the communities in which they operate and that complies with all applicable laws pertaining to health and safety in the workplace. A management representative should be responsible for health and safety at all operating sites, and all employees should be provided with regular and updated training on health and safety as appropriate and required by law. All employees must have access to clean and sanitary toilets and handwashing facilities; be provided with free and safe drinking water, fire exits and essential fire safety equipment, emergency aid kits; and access to emergency response services including environmental, fire, and medical. If Suppliers make housing available to employees, all such housing must meet the country’s housing and safety standards, be safe, hygienic, and meet basic needs.

Environment

Welch is committed to reducing its environmental impact across our supply chain and to supporting sustainable operational and agricultural production practices. Environmental sustainability is one of Welch’s many responsibilities as a good corporate citizen, and it is a strategic focus of our company. Welch strives to develop relationships with Suppliers who share our concerns and commitment to improving the environment.

Suppliers must act in an environmentally responsible manner and comply with all applicable environmental laws, rules, codes, and regulations including those related to waste disposal (including hazardous waste), air emissions, greenhouse gas (GHG) emissions, wastewater and effluents, and toxic substances for the regions of the country, and the world, in which they conduct business. This includes compliance with all reporting, permitting, and environmental licensing requirements. Suppliers are encouraged to exceed the legal requirements and implement action plans for reducing environmental impacts.

Suppliers must identify and reduce the use of hazardous materials, chemicals, and substances and ensure their safe handling, storage, and disposal. All applicable employees must be aware of and trained in related safety procedures.

Quality and Food Safety Standards

Welch is committed to producing high quality and safe products. Suppliers involved in any aspect of developing, handling, manufacturing, packaging, transporting, or storing our products are expected to know and comply with the product quality standards, policies, specifications, and procedures that apply to the products produced at your location; follow and adhere to good manufacturing practices and testing protocols; and comply with all federal, state, and local food safety laws and regulations. Suppliers must immediately report to Welch any issues that could negatively affect the quality or safety of a Welch product.

Compliance

Suppliers are required to comply with this Supplier Code as a condition of doing business with Welch. Welch respects the law in its business operations and expects its Suppliers to do the same by complying with all laws that apply to your business and your work for us. If there is a conflict between what the law requires and the standards of this Supplier Code, we expect you to meet the higher standard.

Additionally, Supplier must be able to demonstrate compliance with this Supplier Code upon our request and we expect you to take action to correct any non-compliance. Welch reserves the right to verify compliance with the Supplier Code, at the Supplier’s own expense, through internal and external assessment mechanisms, such as self-assessment questionnaires and internal or third-party audits. If Welch determines that any Supplier has violated this Supplier Code, Welch may, at its discretion, either terminate its business relationship or require the Supplier to implement a corrective action plan within a timeframe agreed upon between the Supplier and Welch.

In the event a Supplier becomes aware of any non-compliance with this Supplier Code, or any other violation of applicable law, Supplier must timely disclose such information to the proper investigative authorities and, when appropriate, to Welch personnel necessary to permit a full and complete investigation of the suspected misconduct.

Suppliers must have systems in place to enable fair, confidential, and anonymous grievance reporting and follow-up without fear of reprisal. This grievance mechanism shall be transparent, understandable, and accessible to all workers and is meant to include worker whistleblower protections. Suppliers also are encouraged to actively solicit worker feedback.

Welch is committed to constant improvement in its business and operations and expects Suppliers to continuously improve their performance in line with this Supplier Code.