Blackberry Pallet
Code of Conduct

Blackberry Pallet’s (“Blackberry”) core values of Quality, Integrity, Safety, and Trust guide all aspects of our work. This commitment requires observance of the spirit and letter of all applicable laws, as well as the rigor of holding ourselves accountable and promoting these principles in all of our partnerships. Consistent with these values and as a committed partner in the supply chain, Blackberry’s Code of Conduct ("Code") sets forth Blackberry’s encouragement of its suppliers and business partners in the areas of business integrity, human rights, health and safety, and the environment. The principles set forth herein draw upon international standards, best practices, and applicable Blackberry policies, and are designed to provide Blackberry Suppliers with a clear understanding of how they can meet Blackberry’s values and conduct their business activities ethically and in compliance with the law.

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All suppliers of Blackberry are encouraged to adopt this Code. Blackberry's suppliers include all entities that provide goods and services to Blackberry regardless of where the service is being performed. Blackberry reserves the right to evaluate its continued partnership with its Suppliers in accordance with these principles.

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APPLICABILITY OF THE CODE

This Code sets standards of ethical conduct that Blackberry encourages of its Suppliers when doing business with or on behalf of Blackberry. Blackberry encourages its Suppliers to align with the Code and implement these principles in a manner that is appropriate and proportional to the nature and scale of their activities, the goods that they supply, and the services that they provide.

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While Blackberry recognizes that its Suppliers operate in different legal and cultural environments, the principles set forth in this Code operate as a benchmark for responsible conduct. Where applicable local laws impose less restrictive obligations on a Supplier, the Supplier is encouraged to adhere to the principles of this Code. Where applicable local laws impose greater obligations on a Supplier, the Supplier must comply with such laws and regulations.

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Blackberry Suppliers should strive for continuous improvement in performance and regularly review and update performance programs and practices in a manner that ensures ongoing compliance with law and industry standards.

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EXPECTATIONS OF SUPPLIERS

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ETHICS AND COMPLIANCE WITH THE LAWS

Blackberry Suppliers must comply with all applicable laws and regulations and conduct business responsibly and with integrity.

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Anti-Corruption

Blackberry Suppliers should not engage, directly or indirectly, in corruption, fraud, bribery, kickbacks, money laundering, embezzlement, extortion or any other form of corruption, to improperly influence any action or decision. Blackberry Suppliers should maintain accurate financial records and reports as required by applicable laws and regulations. Blackberry Suppliers must comply with all applicable laws and regulations preventing corruption and fraud and ensure that any third party they engage also agrees to abide by such standards.

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Confidentiality and Data Protection

Blackberry's business information is a valuable corporate asset. Blackberry Suppliers must safeguard and not improperly disclose any confidential, sensitive, and non-publicly available business information pertaining to Blackberry, including but not limited to financial information, intellectual property, and information relating to its employees, customers, and suppliers.

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Blackberry Suppliers must adhere to applicable information security, data protection and privacy laws, and regulatory requirements when personal information is collected, stored, processed, transmitted, and deleted. Suppliers must account for the need to protect the confidentiality, integrity, and accessibility of information.

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Blackberry Suppliers must comply with any contractual or other requirements regarding information security and data protection and destruction. This obligation to safeguard confidential and/or proprietary information continues even after an engagement has ended.

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Conflicts of Interest

Blackberry Suppliers must avoid any situation that may involve a conflict or the appearance of a conflict between their personal interests and the interests of Blackberry. As such, Blackberry Suppliers must not offer or provide excessive hospitality, entertainment, or more than nominal gifts to any Blackberry employee or their families to obtain or retain business or to influence a decision.

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Trade Compliance

Blackberry Suppliers must comply with all applicable trade compliance laws, including laws that control the import, export and re-export of Blackberry property, and laws that restrict dealings with sanctioned entities or individuals or in countries subject to trade embargoes or economic sanctions.

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Fair Competition

Blackberry Suppliers must comply with all competition and antitrust laws and must not participate in activities that have the effect of reducing or destroying competition, such as agreeing with competitors to charge certain prices to customers (price fixing), coordinating with competitors during the competitive bidding process (bid rigging), dividing up markets by region, product, or customer (market allocation), or otherwise unfairly excluding or foreclosing competitors from the marketplace.

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Honest and Accurate Dealings

Blackberry Suppliers must not make any false representations in connection with any Blackberry transaction including, but not limited to, oral misrepresentations of fact or the promotion or utilization of false documentation such as non-genuine, fraudulent, or forged contracts or other inaccurate records. All business dealings should be transparent and accurately reflected on the Supplier’s business books and records.

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HUMAN RIGHTS AND LABOR PRACTICES

Blackberry Suppliers must uphold the human rights of all workers, whether temporary, contract, student, or direct employee. All workers must be treated with dignity and respect. Blackberry suppliers should, prior to employing any worker, review all relevant documentation to ensure that such a worker has the legal right to work in that jurisdiction.

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Child Labor

Child labor is strictly prohibited. Blackberry Suppliers must adhere to the minimum employment legal age limit defined by applicable laws or regulations. In no instance will Suppliers permit children under the local legal age for completing compulsory education, perform work that exposes them to undue physical risks that can cause physical, mental, or emotional harm or improperly interfere with their schooling, except as may be permitted under apprenticeship or similar workplace learning programs in which the minor is lawfully participating. Blackberry encourages Suppliers to follow the International Labor Organization’s (ILO) definitions on the minimum age for employment (15 years of age) and hazardous work (18 years of age).

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Forced or Involuntary Labor, Human Trafficking

Any and all forms of forced or involuntary labor, human trafficking, or modern slavery are unacceptable, and have no role anywhere in Blackberry’s business. Blackberry Suppliers must not permit any form of forced or involuntary labor and human trafficking from occurring within its business and supply chain.

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Anti-Discrimination and Equality

Blackberry values and welcomes workers from all cultural, social and ideological backgrounds, promoting an environment where everyone is free of discrimination and harassment of any kind and where all workers are equal and their contributions are judged fairly based on work quality and productivity. Blackberry Suppliers must be committed to a workplace free of harassment and unlawful discrimination and must take appropriate steps to identify, prevent and mitigate any form of discrimination.

 

Suppliers must not discriminate on the basis of race, color, religion, gender, gender identity or expression, sexual orientation, age, national social or ethnic origin, maternity, disability, marital or family status, military status, criminal history status, or any other protected category in accordance with applicable federal, state, and local laws. Blackberry Suppliers must not engage in physical, mental, verbal, sexual or any other abuse, inhumane or degrading treatment, corporal punishment, or any form of harassment.

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Working Hours and Compensation

Blackberry Suppliers should recognize the challenge of managing a work-life balance. Suppliers must abide by all local laws and mandatory standards and must respect any applicable collective bargaining agreements regarding work hours. Blackberry encourages Suppliers to follow the ILO’s guidance for standard work hours of 48 hours per week and a maximum of 8 hours per day, while also providing overtime, a rest period of at least 24 consecutive hours every 7 days, and paid leave.

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Blackberry Suppliers must fairly compensate their employees and provide wages and any benefits in compliance with all applicable wage and hour requirements. If there is no local legal minimum wage, wages should be comparable to those of similar local companies and in conformity with international standards.

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Freedom of Association and Right to Collective Bargaining

Blackberry Suppliers must respect the right of all workers to join or refrain from joining worker organizations, including trade unions. Workers and/or their representatives must be able to openly communicate and share ideas and concerns with management regarding working conditions and management practices without fear of discrimination, reprisal, intimidation, or harassment.

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Health and Safety

Blackberry is committed to the health and safety of its workers. Blackberry requires a safe and hygienic work environment for all its workers and encourages its Suppliers to provide the same. Blackberry Suppliers should ensure that actual and potential risks to worker health and safety are identified, assessed, and eliminated, or managed to mitigate their impacts and ensure preparedness. Suppliers must implement appropriate safety procedures and preventative maintenance, deploying training, and providing Personal Protective Equipment (“PPE”), as required.

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ENVIRONMENTAL STANDARDS

Blackberry’s business of manufacturing quality hardwood pallets is built on the foundation of environmental sustainability. We source our lumber from companies with proven Appalachian Hardwood Verified Sustainable - as defined by AHMI is increasing annually and the growth to removal ratio is 2.4. Suppliers should recognize that protecting the environment is fundamental to protecting and respecting human rights of future generations. By providing high quality hardwood pallets, we contribute the high reusability of our pallets and longevity within the recycled pallets and reclaimed lumber programs used by recyclers. Wooden pallets have a proven high recyclability.

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Respect for the Environment

Blackberry Suppliers should conduct their operations in ways that are environmentally responsible and in compliance with all applicable environmental laws and regulations. Reasonable standards of care should be taken to protect the environment and to provide for the health and safety of the communities in which business operations are conducted. Blackberry Suppliers should take prudent steps to minimize waste by reducing, reusing, and recycling materials, encouraging conservation of resources and energy, and providing training and education for its employees, as appropriate. Suppliers should maintain appropriate documentary evidence of their efforts and provide it upon request.

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No Deforestation and No Peat Development

Suppliers should take appropriate steps to ensure their actions do not have any significant negative impact on forests and other protected territories. Additionally, Suppliers should not expand into High Carbon Stock (HCS) forests, High Conservation Value (HCV) areas, or legally protected areas. When establishing new operations or expanding existing ones, Suppliers must obtain all required legal approvals and permissions.

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Air Quality and Carbon Footprint

Suppliers should take appropriate steps to minimize air emissions and impact on air quality and implement practices to assess and reduce their carbon footprint.

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Water Management and Conservation

Suppliers should take appropriate steps to minimize its impact on water by reducing their consumption and ensuring groundwater quality is maintained or improved, as much as possible.

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Soil Quality

Suppliers should take appropriate steps to preserve soil quality and minimize impacts on soil, as much as possible. Suppliers should perform and promote re-use of organic matter, and regenerative agriculture.

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Sustainable Packaging

Suppliers should take appropriate steps to minimize the environmental impact of packaging. Suppliers should continuously strive to remove unnecessary packaging, select recycled materials whenever possible, and reduce the amount of materials used.

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Supplier Disclosures

All products offered for sale to Blackberry by a Supplier must comply with Blackberry's specifications and all applicable laws. Upon request, Blackberry Suppliers must be capable of disclosing potential sources of primary origin associated with the products or services provided to Blackberry.

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REPORTING CONTRAVENTIONS OF THE CODE

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Management Systems

Suppliers should take appropriate steps to maintain a management system that would include policies and procedures. Suppliers should provide appropriate training to workers to ensure that all sections of this Code of Conduct are understood and addressed consistently.

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Assessments

Blackberry reserves the right to assess its relationship with its Suppliers in accordance with these principles. To this end, Blackberry may request information, documentation and site visits to evaluate a Supplier’s alignment with the Code. In addition, Suppliers are encouraged to conduct periodic self-evaluations to ensure that it, as well as its own suppliers, are in alignment with this Code in all jurisdictions where business or services will be conducted or performed for Blackberry.

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Anyone who believes that a Blackberry Supplier has engaged in illegal, unethical or otherwise improper conduct, or conducted any other activity in violation of this Code is encouraged to speak up and report such conduct via our contact form located here: https://www.blackberrypallet.com/contact-blackberry-pallet#contact

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Reported concerns will be kept confidential.

Blackberry Suppliers must not retaliate against any person for reporting, in good faith, contraventions of this Code, or for filing a complaint, testifying, assisting, or participating in any manner in any investigation, proceeding, or hearing conducted by a government enforcement agency. Prohibited retaliation includes any action adversely affecting continued employment, working conditions, or otherwise denying any employment benefit because an employee has reported alleged prohibited conduct or participated in an investigation.

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Awareness and Monitoring

To achieve an appropriate level of understanding and knowledge, Blackberry encourages its Suppliers to communicate Blackberry’s values to its management and workers, including the principles of Blackberry’s Code of Conduct.

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ACKNOWLEDGEMENT

Blackberry is committed to fostering a strong partnership with each of its Suppliers, to support a fair, sustainable, and transparent supply chain. As such, Suppliers acknowledge that they have reviewed and understand this Code of Conduct and agree that their practices align with these principles.

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Notes:

• Suppliers are encouraged to distribute this Code to their employees, agents, subcontractors, suppliers, and sub-suppliers, to the extent they are involved in the provision of goods and/or services to Blackberry.

• This Code may be amended from time to time, and its enforcement and/or interpretation rests solely with Blackberry.

• This Code does not create any third-party beneficiary rights for the Supplier or any other third parties. The Code is in addition to and not in lieu of provisions of any legal agreement or contract between Suppliers and Blackberry.

• Blackberry reserves the right to evaluate its continued partnership with its Suppliers in accordance with these principles.