Research Institute for Aging
Research Institute for Aging

Code of Conduct


Code of Conduct

  • Scope

This policy establishes the requirements of  Schlegel-UW Research Institute for Aging Foundation and its Affiliates (in this Schedule Schlegel-UW Research Institute for Aging Foundation and its Affiliates are together called “RIA”) for, and sets out Supplier’s obligations in relation to, labour, social, environmental and ethical compliance. All terms used in this Schedule and not otherwise defined herein will have the meanings ascribed to such terms in the Agreement. RIA Supplier Code of Conduct is designed to promote safe and fair working conditions and the responsible management of social, ethical and environmental issues within RIA supply chain. Recognized standards such as the Universal Declaration of Human Rights (UDHR), Social Accountability International (SAI) and the Ethical Trading Initiative (ETI), as well as recognized management systems such as The Occupational Health and Safety Assessment Series 18001 (OHSAS 18001), International Organization for Standardization for Environmental Management (ISO 14001), the Eco Management and Audit System (EMAS), Web Content Accessibility Guidelines (WCAG), and International Labour Organization (ILO) Guidelines on Occupational Safety and Health were used as references in preparing RIA Supplier Code of Conduct. 

RIA may audit Supplier and its Subcontractors in accordance with the provisions relating to Audit in this Agreement. Audits will be conducted by an Auditor, and may include the assistance of an industry representative, or relevant non-governmental organization. [For the purposes hereof “Agreement” means and includes any agreement between the RIA and the Supplier]

Supplier, including its personnel and Subcontractors, is obligated to report any instances of behaviour which contradict the requirements of this Schedule in confidence. 

  • Policy

The following is the policy of RIA:

  1. Supplier hereby agrees to RIA Supplier Code of Conduct as a condition of conducting business with RIA and entering into this Agreement and shall make all reasonable efforts to promote RIA Supplier Code of Conduct to its Supplier Representatives and Subcontractors.
  2. Failure to adhere to RIA Supplier Code of Conduct may result in the termination of this Agreement and/or legal action.
  • Labour

Supplier is committed to uphold the human rights of workers, and to treat them with dignity and respect as understood by the international community.

The labour standards to be adhered to are as follows:

  1. Freely Chosen Employment

Forced, bonded or indentured labour or involuntary prison labour is prohibited. All work will be voluntary, and workers should be free to leave upon reasonable notice. Workers shall not be required to hand over government-issued identification, passports or work permits as a condition of employment.

  • Child Labour Avoidance

Child labour is prohibited in any stage of manufacturing or production. The term “child” refers to any person employed under the age of 15 (or 14 where the law of the country permits), or under the age for completing compulsory education, or under the minimum age for employment in the country, whichever is greatest. The use of legitimate workplace apprenticeship programs, which comply with all laws and regulations, is supported. Workers under the age of 18 must not perform hazardous work and may be restricted from night work with consideration given to educational needs.

  • Working Hours

Workweeks are not to exceed the maximum set by local law. In the event that there are no local laws regulating workweeks, Supplier will not require, except in emergency or unusual situations, workers to work more than six consecutive days without at least one rest day.

  • Wages and Benefits

Compensation paid to workers shall comply with all applicable wage laws, including those relating to minimum wages, overtime hours and legally-mandated benefits. In compliance with local laws, workers shall be compensated for overtime at pay rates greater than regular hourly rates. Deductions from wages as a disciplinary measure is not permitted. The basis on which workers are being paid is to be provided in a timely manner via pay stub or similar documentation.

  • Humane Treatment

There is to be no harsh and inhumane treatment or tolerance thereof, including any sexual harassment, sexual abuse, corporal punishment, mental or physical coercion or verbal abuse of workers, nor is there to be the threat of any such treatment.

  1. Respect, Dignity, Diversity and Inclusivity in the Workplace

Supplier shall be committed to a workforce free of harassment and unlawful discrimination. Supplier shall not engage in discrimination based on race, colour, age, gender, sexual orientation, ethnicity, disability, pregnancy, religion, political affiliation, union membership or marital status in hiring, or employment practices such as promotions, rewards, and access to training. In addition, workers or potential workers should not be subjected to medical tests that could be used in a discriminatory way. RIA has the right to request that a Supplier Representative who engages in such behaviour be removed from a RIA project or facility if the conduct of the Supplier Representative requires, and Supplier will fulfil the request IMMEDIATELY after receiving written notification from RIA.

In choosing and evaluating its Suppliers, RIA will take into account Supplier’s commitment to, and history of, fostering fair and inclusive work environments, as well as the inclusion of minority, women, disabled veterans and others, and lesbian, gay, bisexual and transgender-owned businesses in the provision of Products and Services that RIA buys. Upon RIA request, Supplier will provide RIA with information concerning its diversity and inclusion policies, programmes and initiatives, workforce, and Subcontractors’ representation. Suppliers who do not meet RIA diversity expectations, or that fail to comply with applicable laws regarding diversity, human rights, accessibility, anti-harassment or non-discrimination, may become ineligible to do business with RIA.

  • Freedom of Association

Open communication and direct engagement between workers and management are the most effective ways to resolve workplace and compensation issues. Supplier will respect the rights of workers to associate freely, join or not join labour unions, seek representation, and join workers’ councils in accordance with local laws. Workers shall be able to communicate openly with management regarding working conditions without fear of reprisal, intimidation, or harassment.

  • Health and Safety

Supplier recognizes that the quality of Products and Services, consistency of production, and workers’ morale, are enhanced by a safe and healthy work environment. Supplier must also recognize that ongoing worker input and education are key to identifying and solving health and safety issues in the workplace.

The health and safety standards to be adhered to are as follows:

  • Occupational Safety

Worker exposure to potential safety hazards (e.g., electrical and other energy sources, fire, vehicle, and fall hazards) will be controlled through proper design, engineering and administrative controls, preventative maintenance and safe work procedures (including lockout/tag-out). Where hazards cannot be adequately controlled by these means, workers will be provided with appropriate personal protective equipment. Workers shall not be disciplined for raising safety concerns.

  • Emergency Preparedness

Emergency situations and events will be identified and assessed, and their impact minimized by implementing emergency plans and response procedures, including emergency reporting, employee notification and evacuation procedures, worker training and drills, appropriate fire detection and suppression equipment, adequate exit facilities and recovery plans.

  • Occupational Injury and Illness

Procedures and systems will be in place to manage, track and report occupational injury and illness, including provisions to: (a) encourage worker reporting; (b) classify and record injury and illness cases; (c) provide necessary medical treatment; (d) investigate cases and implement corrective actions to eliminate their causes; and (e) facilitate return of workers to work.

  • Industrial Hygiene

Worker exposure to chemical, biological and physical agents will be identified, evaluated, and controlled. When hazards cannot be adequately controlled by engineering and administrative means, workers will be provided with appropriate personal protective equipment.

  • Physically Demanding Work

Worker exposure to physically demanding tasks, including manual material handling and heavy lifting, prolonged standing and highly repetitive or forceful assembly tasks will be identified, evaluated and controlled.

  • Machine Safeguarding

Physical guards, interlocks and barriers will be provided and properly maintained for machinery used by workers.

  1. Dormitory and Canteen

Workers will be provided with clean toilet facilities, access to potable water and sanitary food preparation and storage facilities. Worker dormitories provided by Supplier or a labour agent will be clean and safe, and will provide emergency egress, adequate heat and ventilation and reasonable personal space.

  • Alcohol and Drugs

Supplier and Supplier Representatives shall not possess, consume and/or traffic in alcoholic beverages, illegal drugs or restricted substances or any substance deemed to impair the ability to safely perform Services for RIA, including cannabis.

  • Environmental

Supplier recognizes that environmental responsibility is integral to producing world class products. In manufacturing operations, and/or in the delivery of Products and Services, adverse effects on the community, environment and natural resources will be minimized while safeguarding the health and safety of the public.

The environmental standards are as follows:

  • Environmental Compliance

Supplier will comply with all applicable environmental legal requirements that apply to its operations, business activities and services.  

  • Environmental Programs and Initiatives 

Supplier will maintain programs and initiatives aimed at reducing its material environmental impacts.  Programs must include, without limitation:

  1. Climate Change: address climate change risks and opportunities across its business and strive to manage its carbon emissions and pollution to support the transition towards a low carbon economy. Supplier is encouraged to take actions to reduce its carbon emissions, including making a commitment to set a science-based target in alignment with the Science Based Target initiative (SBTi) requirements
  2. Energy: reduction of all energy consumption through operating, transportation and production efficiencies.
  3. Waste: reduction of all wastes, through product and service design, the use of non-virgin materials during production (if possible), and end-of-life material recycling, and reuse alternatives. Best efforts should be made to avoid use of chemical and other materials posing a hazard if released to the environment. If unavoidable, such chemicals and materials will be identified and properly managed to ensure safe handling, transport, storage, recycling, reuse, and safe disposal.
  4. Air Emissions: air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone-depleting chemicals and combustion by-products generated from operations will be characterized, monitored, controlled and treated as required prior to discharge to maximize reduction of such discharge.
  5. Pollution Prevention: prevention of pollution and biodiversity loss, incorporating traditional ecological knowledge whenever possible. Responsible use of natural resources, including minimizing water use and generation of wastewater.
  • Product Content Restrictions

Supplier will adhere to all applicable laws and regulations regarding prohibition or restriction of specific substances including labelling laws and regulations for recycling and disposal. Supplier will also adhere to processes to comply with each agreed-upon RIA-specific restricted and hazardous materials list.

Supplier will eliminate any conflict materials from their product(s) and avoid doing business with suppliers from identified world conflict zones, in the delivery of Products or Services to RIA.

(vi)  Disclosure

Supplier will publicly disclose its environmental strategy, programs, and key performance metrics in accordance with all applicable laws and with a view to industry best practices and frameworks.

  • Protection of Data

Supplier and its Subcontractors must operate in accordance with the Personal Information and Electronics Documents Act (Canada) and Canada’s Anti-Spam Legislation. Supplier and its Subcontractors shall employ the following principles to ensure secure and responsible collection, use and disclosure of RIA Data:

  • Partnership 

Supplier will work with Subcontractors who share RIA vision for responsible data use, to collaborate on data initiatives that provide value to RIA customers, employees and RIA business.

  • Transparency 

Supplier will be transparent with RIA and RIA customers and employees about how their data is managed. 

  • Control 

In accordance with applicable law, RIA customers will be given control and choice over how their Personal Information is used. 

  • Consideration

Supplier will be respectful in the management of RIA customer and RIA employee data, and guard against bias, discrimination and unjust impacts. The more sensitive the data, the greater scrutiny Supplier will provide around the management of that data.

  • Security and Protection 

Supplier will prioritize the protection of RIA customer and RIA employee data.

  • Innovation

Supplier will continually leverage developing technologies and practices to manage and use data in new and thoughtful ways that improve RIA business and to better serve RIA customers and RIA employees. 

  • Management System

Supplier shall adopt or establish a management system the scope of which is related to the content of this Schedule. The management system shall be designed to ensure (a) compliance with applicable laws, regulations and RIA requirements related to Supplier’s operations and products; (b) conformance with this Schedule; and (c) identification and mitigation of operational risks related to this Schedule.

The management system should contain the following elements:

  • Corporate Commitment

Corporate social and environmental responsibility statements affirming Supplier’s commitment to compliance, continual improvement, and the avoidance of damage to any protected biodiversity environments.

  • Management Accountability and Responsibility

Clearly identified Supplier Representative[s] responsible for ensuring implementation and periodic review of the status of the management systems.

  1. Legal and RIA Requirements

Identification, monitoring and understanding of applicable laws, regulations and RIA requirements and compliance with laws applicable to RIA and Supplier.

  • Accessibility
  1. Any product, service, information and technology with a user interface, including audio visual content, websites, web applications, mobile apps, software, and interactive and/or digital technology-enabled sales and information kiosks supplied by Supplier or used by Supplier while carrying out Services for RIA (“Digital Products”) must be in compliance with all applicable laws, including the  Canadian Human Rights Act
  2. Digital Products must comply with the accessibility requirements set out in the Web Content Accessibility Guidelines (WCAG v2.1 AA Level) and all updates thereto at Supplier’s expense.
  • Risk Assessment and Risk Management

Process to identify the environmental, health and safety and labour practice risks associated with Supplier’s operations. Determination of the relative significance for each risk and implementation of appropriate procedural and physical controls to ensure regulatory compliance to control the identified risks.

  1. Performance Objectives with Implementation Plan and Measures

Written standards, performance objectives, targets and implementation plans including a periodic assessment of Supplier’s performance against those objectives.

  • Training

Programmes for training managers and workers to implement Supplier’s policies, procedures and improvement objectives.

  • Communication

Process for communicating clear and accurate information about Supplier’s performance, practices and expectations to workers, suppliers and customers. Areas to be included in a risk assessment for health and safety are warehouse and storage facilities, plant/facilities support equipment, laboratories and test areas, sanitation facilities (bathrooms), kitchen/cafeteria and worker housing /dormitories.

  • Worker Feedback and Participation

Ongoing processes to assess employees’ understanding of and obtain feedback on practices and conditions covered by this Schedule and to foster continuous improvement.

  • Audits and Assessments

Periodic self-evaluations to ensure conformity to legal and regulatory requirements, the content of the Schedule, and RIA contractual requirements related to social and environmental responsibility.

  • Corrective Action Process

Process for timely correction of deficiencies identified by internal or external assessments, inspections, investigations and reviews all in keeping with all local, provincial and/or federal regulations or guidelines.

  • Documentation and Records

Creation of documents and records to ensure regulatory compliance and conformity to RIA requirements along with appropriate confidentiality to protect privacy.

  • Ethics

To meet social responsibilities and to achieve success in the marketplace, Supplier, Supplier Representatives, and Supplier’s Subcontractors will uphold the highest standards of ethics including:

  1. Business Integrity

The highest standards of integrity are to be expected in all business interactions, including with employees, customers, suppliers and the communities in which we operate. Any and all forms of corruption, extortion and embezzlement are strictly prohibited and may result in immediate termination and legal action.

  • No Improper Advantage

Bribes or other means of obtaining undue or improper advantage are not to be offered or accepted.

  • Disclosure of Information

Information regarding business activities, structure, financial situation and performance is to be disclosed in accordance with applicable regulations and prevailing industry practices, including restrictions on the communication of material non-public information and on the purchase and sale of securities under securities laws.

  • Intellectual Property

Intellectual property rights are to be respected; transfer of technology and know-how is to be done in a manner that protects intellectual property rights.

  1. Fair Business, Advertising and Competition

Standards of fair business, advertising, sales and competition practices are to be upheld through compliance with all applicable laws relating to competition standards, advertising and sales practices. The means to safeguard RIA information must be available.

  1. Fair Dealing

Supplier is required to act honestly, in good faith, and with professionalism. Supplier shall not take unfair advantage of a customer through unethical behaviour such as harassment, manipulation, abuse of privileged information, misrepresentation of material facts, or any other unfair practice.

  • Protection of Identity

Programs that ensure the protection of Supplier and employee whistleblower confidentiality will be maintained.

  1. Community Engagement

Community engagement is encouraged to help foster social and economic development.

  1. Conflict Minerals

Supplier shall evaluate the origin or source of its materials to verify that they have not been mined from any conflict zone. Supplier shall disclose whether any of its Products contain minerals that have been mined in conditions of armed conflict and human rights abuses or that are from any conflict zones. Where conflict minerals are found in a product or during manufacturing, Supplier commits that it will work to develop and implement processes and control mechanisms to avoid conflict minerals in future.

  • Conflict of Interest

A “conflict of interest” occurs when Supplier’s interests interfere, or may appear to interfere, with the interests of RIA. A conflict of interest can arise when Supplier or a Supplier Representative takes actions or has interests that may make it difficult for Supplier to perform the Services objectively and effectively. Supplier and Supplier Representatives must: (i) avoid activities or situations that involve real or perceived conflicts of interest which would interfere with the interests of RIA, and (ii) disclose potential conflicts of interest or any relationships that could reasonably be expected to give rise to a conflict of interest.

Any entertainment, hospitality, gift or favour made or received by Supplier or a Supplier Representative while performing the Services to procure an action or decision, or to recognize or reward an action or decision, is a conflict of interest and is prohibited. Supplier and Supplier Representatives transacting business for RIA should act and should be perceived by others to act, in RIA best interest and free of any conflicts of interest. The total value of (a) favours and gifts received by a RIA employee from Supplier shall not exceed $100 annually; and (b) entertainment and/or hospitality received by a RIA employee from Supplier shall not exceed $500 quarterly, all provided that the following criteria are met:

  1. they are in the course of a normal business relationship and are consistent with accepted business practice, except during a Request for Proposal event such as a competitive bid and/or during contract negotiation;
  2. they are not in cash, cash equivalents or securities;
  3. they are of sufficiently limited value so as not to be capable of being perceived or construed as an inducement, bribe, pay-off or other improper payment or endorsement;
  4. they are not repetitive or frequent; and
  5. they do not contravene any law and are made in accordance with generally accepted ethical standards and behaviour.
  • Supplier Representatives

RIA reserves the right to interview and approve or reject any or all prospective new Supplier Representatives on RIA projects prior to their being hired or engaged by Supplier. Supplier must (i) perform background checks, and (ii) verify all credentials and at least two references, for each prospective Supplier Representative prior to hiring or engagement. Supplier will maintain all interview notes of each Supplier Representative. RIA reserves the right to audit and receive confirmation of all documentation regarding all of the above requirements for prospective or hired Supplier Representatives who may provide Services to or on behalf of RIA. RIA reserves the right to require Supplier to remove specified personnel from any RIA project or facility at no additional cost to RIA.

Supplier and Supplier Representatives will adhere to applicable RIA policies and processes while performing Services in the field on behalf of RIA, and when working with RIA customers, including without limitation, security and access control at RIA facilities; health and safety procedures, including pre-screening assessments regarding travel history and exposure to health risks; and business travel and expense reimbursement practices. 

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