Supplier Code of Conduct


The Supplier shall comply and ensure that all of its subcontractors, suppliers and their respective factories comply with the following:

  • Child Labour: The Supplier shall not utilise child labour. The word "child" shall be defined as a person younger than fifteen (15), (or fourteen (14) where local law allows) or, if higher, the local legal minimum age for employment or the age for completing compulsory education. Irrespective of age, the Supplier shall treat all Personnel in compliance with all applicable laws and regulations.
  • Coercion and Harassment: All Personnel shall be treated with dignity and respect. Actions such as corporal punishment, threats of violence and/or other forms of physical, sexual, psychological, verbal abuse and/or harassment will never be allowed or condoned.
  • Nondiscrimination: There shall be no discrimination by the Supplier with regard to hiring and employment practices, including salary, benefits, advancement, discipline, termination or retirement on the basis of race, religion, age, nationality, social or ethnic origin, sexual orientation, gender, political opinion or disability.
  • Health and Safety: The Supplier will provide Personnel with a safe and healthy workplace (and employee housing, if applicable) in compliance with all applicable laws and regulations. At a minimum, the Supplier will also ensure reasonable access to potable water, sanitary facilities, proper ventilation, adequate lighting and fire safety.
  • Association: The Supplier will respect the rights of Personnel to associate, organize and bargain collectively in a lawful and peaceful manner without penalty or interference.
  • Protection of the Environment: All applicable environmental laws and regulations will be adhered to by the Supplier.
  • Compensation: The Supplier will comply with all applicable wage and hour laws and regulations, including those relating to minimum wages, overtime, maximum hours, piece rates and other elements of compensation and provide legally mandated benefits. Where local industry standards are higher than applicable legal requirements, the Supplier will be expected to meet the higher standards.
  • Other Laws: The Supplier will comply with all applicable laws and regulations, including those pertaining to the manufacture, pricing, sale and distribution of goods. All references to “applicable laws and regulations” in this Code shall include local and national codes, rules and regulations as well as applicable treaties and voluntary industry standards.
  • Monitoring and Compliance: The Supplier acknowledges and agrees that Dunninghams and/or its agents shall have the right to engage in monitoring activities to confirm compliance with this Code of Conduct. Monitoring activities may include, without limitation, unannounced on-site inspections of manufacturing facilities (including those of any subcontractors) and employer-provided housing, reviews of books and records relating to employment matters and private interviews with the Supplier’s Personnel. The Supplier must, and agrees to, maintain on site all documentation that may be needed to demonstrate compliance with these policies.
  • Publication: The Supplier will take appropriate steps to ensure that the provisions of this Code of Conduct are communicated to Personnel, including the prominent posting of a copy of these provisions in the local language and in a place readily accessible to Personnel at all times.

Modern Slavery

  • The Supplier acknowledges that Dunninghams has obligations to comply with Modern Slavery Laws, and represents and warrants to Dunninghams that the Supplier:
    • (has no knowledge of any Modern Slavery Offence currently occurring within its organisation or supply chain; and
    • takes and will continue to take reasonable steps to identify the risk of, and prevent the occurrence of, Modern Slavery Offences within its organisation or supply chains.
  • Without limiting sub-clause 2(a) above, the Supplier represents and warrants to Dunninghams that in relation to any services or goods procured from, or subcontracted or outsourced to, third parties for the provision of the services or goods under this Agreement, the Supplier has taken, or will, prior to procuring, sub-contracting or outsourcing any such services or goods from or to a third party, take, and will continue through the contract term to take all reasonable steps to confirm that such third party is not engaging in Modern Slavery Offences.
  • The Supplier will notify Dunninghams in writing as soon as practicable and no later than 14 days upon becoming aware of any Modern Slavery Offence (or of any charges laid or orders made in relation to a Modern Slavery Offence) within its organisation or supply chain.
  • If requested by Dunninghams, the Supplier will, subject to any existing confidentiality requirements and any relevant law, take all reasonable steps to provide Dunninghams with any information, reports or documents in relation to any Modern Slavery Offence or any risk of a Modern Slavery Offence within the Supplier’s organisation or supply chain, including if required the completion of a self-assessment questionnaire.

For the purposes of this Code of Conduct:

“Personnel” means, in respect of the Supplier, any director, officer, employee, contract staff, subcontractors or other worker of the Supplier or the Supplier’s contractors or agents.

''Modern Slavery Laws” means the Modern Slavery Act 2018 (Cth), the Modern Slavery Act 2018 (NSW), the Modern Slavery Act 2015 (UK) and any relevant regulations or ancillary legislation published in respect of the above or any similar modern slavery legislation in another jurisdiction of which the Supplier is required to comply; and

“Modern Slavery Offence” means:

  • any offence set out in section 1 or section 2 of the Modern Slavery Act 2015 (UK);
  • any conduct which would constitute 'modern slavery' under the Modern Slavery Act 2018 (Cth); and
  • any other conduct or practices which amount to an offence under any of the Modern Slavery Laws.