Code of Conduct
Bluegem Capital Partners LLP
SCOPE OF THE POLICY
The Code of Conduct is applicable to Bluegem Capital Partners LLP and all its consultants, suppliers, business partners, agents and contractors.
PURPOSE
The Code of Conduct is created for the purpose of ensuring that Bluegem Capital Partners LLP and its employees and members (hereafter referred to as ‘Bluegem’) and its consultants, suppliers, business partners, agents and contractors (hereafter referred to as ‘Third Parties’), adopt acceptable standards to operate responsibly by putting into place safe working conditions, treating their employees with respect, upholding human rights, and minimising environmental impact.
PRINCIPLES
These Principles apply to Bluegem and to all Third Parties that engage with Bluegem and/or provide services and goods to Bluegem.
Bluegem partners with third parties where appropriate to improve performance.
Bluegem asks for feedback from third parties on its performance as a customer.
Bluegem strongly encourages Third Parties to exceed the following minimum standards of compliance and to promote best practices and continuous improvement throughout their operations and facilities.
Minimum standards of compliance
Principle 1: Legal and Ethical Business Practices
Bluegem and its Third Parties must be ethical in their business practices and fully comply with all applicable laws of the countries in which they are located including all laws, regulations and rules relating to wages, hours, employment, labour, health and safety, the environment, immigration, and the applicable industry standards. They shall not engage in corruption, bribery or any activity (including improper payments) that may imply involvement in corruption or bribery when working for or with Bluegem.
Principle 2: Child Labour
No person shall be employed at an age younger than 15 (or 14 where consistent with International Labour Organization guidelines) or younger than the age for completing compulsory education in the country of operation where such age is higher than 15. Bluegem and Third Parties must observe all legal requirements for work of employees under 18 years of age, particularly those pertaining to hours of work and working conditions.
Principle 3: Forced Labour
Bluegem and Third Parties will not use involuntary or forced labour - indentured, bonded or otherwise.
Principle 4: Wages and benefits
Bluegem and Third Parties must compensate their employees fairly by providing compensation packages comprising wages and benefits that, at the very least, comply with legally mandated minimum standards or the prevailing industry wage, whichever is higher, and shall provide legally mandated benefits. Employees must be fully compensated for overtime according to local law and each employee must be provided with a clear, written accounting for each pay period.
Principle 5: Hours of work
Bluegem and Third Parties must ensure employees’ hours worked shall not, on a regularly scheduled basis, exceed the lesser of (a) the legal limitations on regular and overtime hours in their jurisdiction or (b) 60 hours per week including overtime (except in extraordinary business circumstances). All employees will be entitled to at least one day off in every seven-day period.
Principle 6: Freedom of association and collective bargaining
Bluegem and Third Parties shall comply with local and national laws and regulations regarding Freedom of Association and Collective Bargaining. No employee shall be subject to harassment, intimidation or retaliation in their efforts to freely associate or bargain collectively.
Principle 7: Health and safety
Bluegem and Third Parties must provide their employees with a clean, safe and healthy work environment, designed to prevent accidents and injury to health arising out of or occurring during the course of work. They are required to comply with all applicable, legally mandated standards for workplace health and safety in the countries and communities in which they operate.
Principles 8: Non-discrimination
Whilst Bluegem recognizes and respects cultural differences, employment including hiring, remuneration, benefits, advancement, termination and retirement, should be based on ability and not on belief or any other personal characteristics. Bluegem and Third Parties shall not discriminate on the basis of race, age, colour, national origin, gender, gender expression, religion, sexual orientation, disability, marital status, political opinion, or social or ethnic origin.
Principle 9: Harassment
Bluegem and Third Parties must treat all employees with respect and dignity, and may not subject employees to corporal punishment, physical, sexual, psychological or verbal harassment, bullying, intimidation or abuse. In addition, they may not use monetary fines as a disciplinary practice.
Principle 10: Women’s rights
Bluegem and Third Parties must ensure that women workers will receive equal remuneration, including benefits, equal treatment, equal evaluation of the quality of their work, and equal
opportunity to fill all positions open to male workers. Pregnancy tests will not be a condition of employment, nor will they be demanded of employees. Workers who take maternity leave (of a duration determined by local and national laws) will not face dismissal nor threat of dismissal, loss of seniority or deduction of wages, and will be able to return to their former employment at the same level of pay and benefits. Workers will not be forced or pressured to use contraception. Workers will not be exposed to hazards that may endanger their safety, including their reproductive health.
Principle 11: Environment
Bluegem and Third Parties must comply with all laws and regulations relating to environmental protection in the countries in which they operate. Facilities should have procedures in place to ensure environmental impacts are minimized with respect to energy, air emissions, water, waste, hazardous materials and other significant environmental risks. Bluegem is committed to making sustainable improvements in environmental performance and requires the same of its suppliers and sub- contractors.
Principle 12: Informed workplace
Bluegem and Third Parties should inform employees about the workplace standards on a regular basis.
DUE DILIGENCE AND MONITORING
Bluegem is committed to monitoring compliance against its internal standards and policies, including the Code of Conduct. Compliance with its standards and policies is an important component to the success of Bluegem.
Bluegem expects Third Parties to have processes and controls in place to comply with this Code. Where appropriate, Bluegem may conduct risk-based due diligence on third parties as part of assessing its relationship with third parties.
Bluegem expects Third Parties to provide complete and accurate information to facilitate due diligence efforts, where requested.
If Bluegem determines that a Third Party has breached this Code, it may require the third party to implement a remediation plan, or, in certain circumstances, it may suspend or terminate the relationship with the Third Party.