Human Rights Commitment
1. INTRODUCTION
1.1 BroadGrain Commodities Inc., and its affiliated companies, BroadGrain Holdings Inc., BroadGrain Argentina S.A., BroadGrain Africa Ltd., BG Commodities DMCC, Bogu (Tianjin) International Trading Ltd., Everdere Logistics (Barbados) Ltd., and BroadGrain’s participation in its joint venture La Societe d’Importation et de Fabrication des Aliments de Bétails SPA (collectively, “BroadGrain”) is committed to treating people with dignity and respect in the workplace and in the communities where we do business.
1.2 We take guidance from the International Labour Organisation Declaration on Fundamental Principles and Rights at Work. This Commitment contains overarching principles that affect our operations.
1.3 It is the duty of governments to protect and fulfill human rights. As a private company, we are committed to respecting human rights, starting with areas where we have the most control and influence, and where we can have the greatest impact. All our employees have a role to play in respecting human rights.
1.4 No matter where we operate, BroadGrain strives to comply with the spirit and the letter of the law. Where local laws are less stringent than our Commitment, we will seek to operate in accordance with this Commitment.
2. PROMOTION OF WORKPLACE THAT IS SAFE, EQUITABLE AND FREE FROM DISCRIMINATION AND HARASSMENT
2.1 Our Respect in the Workplace Policy, available locally in each BroadGrain company, serves as the foundation for the behaviors expected from all our employees. Every employee of each BroadGrain company receives a copy of this policy.
2.2 In this Commitment, we extend on this foundation with the following:
2.2.1 Health & Safety: We are committed to conducting all our business activities in a manner that protects the health and safety of our people.
2.2.2 Equitable: We apply equitable hiring practices and meet or exceed all applicable laws regarding working conditions. We respect the freedom of association and employees’ right to choose to form or voluntarily join trade unions and collectively bargain. Migrant or temporary foreign workers are accorded treatment and protection equal to other workers. BroadGrain does not use or tolerate the use of human trafficking, forced labor or child labor. In particular:
the recruitment, harboring, transportation, provision, or obtaining of a person for work or services through force, fraud or coercion for the purpose of involuntary servitude or slavery;
any work or service not of free will, exacted under threat of penalty, including practices such as restricting movement or imprisonment, withholding wages or identity documents to force a worker to stay on the job, or entangling workers in fraudulent debt; and
any work or service by children exposing them to risks that can harm physical, mental or educational development.
2.2.3 No discrimination or harassment: We foster an inclusive work environment free of harassment and discrimination. We value the full range of perspectives and talents of our diverse employees. This includes, for example, diversity of ethnicity, gender, disability, race, religion, sexual orientation, gender identity and expression and national extraction. We make every reasonable attempt to provide religious accommodation to all employees.
3. REPORTS AND REMEDIES
3.1 We take all stakeholder concerns seriously and handle them promptly, fairly, and as confidentially as possible. Any concern or report from external parties may be submitted using contact information that is on the company website. Employees can also raise issues with their local manager or human resources representative. BroadGrain will not tolerate retaliation against anyone who, in good faith, raises a concern or participates in an investigation.
Supplier Code of Conduct
BroadGrain’s Supplier Code of Conduct (“the Code”)
In the below, “Supplier” means you as well as your sub-contractors, including self-employed workers, agents, brokers and traders. “BroadGrain” means BroadGrain Holdings Inc. and its subsidiaries BroadGrain Commodities Inc., BroadGrain Argentina S.A., BroadGrain Africa Ltd., BG Commodities DMCC, Bogu (Tianjin) International Trading Ltd., Everdere Logistics (Barbados) Ltd., and BroadGrain’s participation in its joint venture La Société d’Importation et de Fabrication des Aliments de Bétails SPA.
Compliance with laws
- All laws are complied with and required permits are held, for the countries where the Supplier operates, as well as for all other applicable international laws and regulations.
Forced labour and child labour
- Under no circumstances will forced labour or child labour be used, including trafficked labour, indentured labour, bonded labour, prison labour or other forms of slavery.
- Workers enter and leave employment freely and are not required to surrender any identity or personal papers, pay a deposit for their employment or be confined to Supplier premises, eg. in dormitories.
- Workers are free to terminate their employment after a reasonable notice period without penalty, as agreed in the terms and conditions of employment.
- Under no circumstances are individuals employed under the local legal minimum age for work or mandatory schooling, whichever is applicable.
Anti-bribery & corruption
- All forms of corruption, including bribery, extortion, embezzlement, kickbacks, bid-rigging and fraud are prohibited and prevented through adequate procedures. Bribery of public officials or private organization officials as well as facilitation payments are covered by this prohibition.
- The Supplier must maintain the highest ethical standards. The Supplier is prohibited from offering anything of value to BroadGrain employees to improperly obtain or retain business. This does not apply to de minimis gifts in line with BroadGrain’s internal policies.
Working environment
- Supplier shall provide a safe, healthy, and sanitary working environment compliant with local employment law, including standards on working hours, minimum wages and health and safety.
- Supplier shall implement procedures to prevent workplace hazards, and work-related injuries.
- Supplier shall ensure any facilities used meet applicable building codes and construction standards, in particular without limitation covering proper fire, water, lighting, sanitary and emergency exit standards.
- Supplier shall operate in compliance with all applicable environmental laws relating to waste disposal, emissions, discharges, and hazardous materials.
- Supplier shall respect, and shall not interfere with, the right of workers to decide whether to lawfully associate with groups of their choice, including the right to form or join trade unions and to engage in collective bargaining.
Discrimination and harassment
- Supplier shall not discriminate in hiring, compensation, or any other employment practice based on race, national origin, gender, sexual orientation, religion, age, family status or disability.
- Supplier shall not subject workers to corporal punishment, or physical, verbal, sexual, or psychological abuse or harassment or condone or tolerate any of the above behaviours.
If it is established that a Supplier is involved in breach of this Code, then BroadGrain will review the continuation of business with such Supplier and retains the right to cease business with them. Supplier agrees:
- a) that all entities affiliated with the Supplier will comply with this Code; and
- b) to take at its own cost any action reasonably required by BroadGrain to:
(i) verify compliance by all entities of the Supplier group with this Code; and
(ii) rectify any non-compliance by an entity of the Supplier group within the timeframe stipulated by the BroadGrain.
If BroadGrain terminates a contract with Supplier due to a breach of this Code, without prejudice to any amounts owing or any other pre-existing liabilities to BroadGrain, neither the Supplier nor any affiliate of the Supplier is entitled to claim compensation or any further remuneration, regardless of any activities or agreements with additional third parties entered into before termination.