C6 Diamond LLC is committed to developing and growing our business in a sustainable fashion by providing our customers with products that satisfy their needs in a manner that is socially responsible. The Standards set forth in this Supplier Code of Conduct Manual (the “Standards”) have been influenced by many of the principles outlined by the International Organization for Standardization (“ISO”) and the International Labour Organization (“ILO”); the Standards operationalize our commitment to continuous improvement and collaboration with our supplier partners.
C6 Diamond LLC’ overarching goal is to ensure the production of goods in an ethical and transparent way that contributes to the health and safety of our employees and to the welfare of our society.
The ILO has maintained and developed a system of international labor standards aimed at promoting opportunities for women and men to obtain decent and productive work, in conditions of freedom, equity, security and dignity.
The Standards apply to all of our Suppliers and act as a guideline when doing business with C6 Diamond LLC.
In order to validate compliance with the Standards and to ensure that Suppliers and their factories have met their obligations, C6 Diamond LLC or its representatives may at any time conduct unannounced verification audits. Suppliers must cooperate fully with such audits and are expected to be transparent and collaborate with C6 Diamond LLC representatives (including C6 Diamond LLC approved third-party monitoring firms).
Social and Environmental Responsibility (SER)
C6 Diamond LLC expects all Suppliers to abide by all applicable international, federal, state, and local laws, rules and regulations in the manufacture, assembly, inspection, packaging, storage and handling of merchandise provided to C6 Diamond LLC. This may include, but not be limited to, maintaining building, fire and life safety, and securing proper certifications, licenses, agreements, patents and registrations. All Suppliers are strongly encouraged to exceed C6 Diamond LLC’ guidelines and to promote continuous improvement throughout their operations. All Suppliers must at all times be able to demonstrate compliance with these requirements at the request of C6 Diamond LLC or its designated representative(s).
C6 Diamond LLC may at its sole discretion and at any time (without advance notice) conduct Social and Environmental Responsibility (SER) audits at factories producing products for and/or selling products to C6 Diamond LLC. If a Supplier does not have an SER program or corporate responsibility program, C6 Diamond LLC will work with such Supplier to ensure that the Supplier is building internal capabilities to monitor compliance at its facilities, but the Supplier must still comply with the Standards as detailed in this manual. C6 Diamond LLC reserves the right to audit any Supplier’s operations involved in the manufacture, assembly, inspection, packaging, storage and handling of merchandise for C6 Diamond LLC. C6 Diamond LLC expects that any changes to the Supplier’s company, factory or manufacturing location will be communicated in writing to C6 Diamond LLC for evaluation. In addition, the manufacture of C6 Diamond LLC products must not be relocated from approved facilities without our prior approval.
Suppliers are required to provide transparency into their physical factory environments, operations, policies, processes, and relevant records to C6 Diamond LLC or its designated representative.
Minimum Age for Employees/Child Labor
C6 Diamond LLC will not accept or tolerate the use of any forced or involuntary labor, either directly or indirectly, by our Suppliers, contractors or subcontractors.
Suppliers must compensate all employees with wages, overtime premiums, maximum hours, production rates and other elements of compensation and benefits that meet or exceed legal standards, local industry standards or collective agreements, whichever are higher. Suppliers are encouraged to provide wages and benefits that are sufficient to meet an individual’s basic needs and provide some discretionary income for employees and their families.
Suppliers must provide employees with humane working conditions and hours.
Employment should be based solely on the individual’s ability and willingness to perform the job requirements and not based on personal characteristics. This standard should apply to all aspects of employment, including, but not limited to, hiring, salary, benefits, training, promotion, advancement, discipline, termination or retirement.
Freedom of Association and Collective Bargaining
Suppliers must recognize and respect the right of employees to freely associate and collectively bargain as required by law.
Health and Safety
C6 Diamond LLC requires that its Suppliers provide a safe and healthy working environment in accordance with applicable local laws and shall have a comprehensive set of employment/personnel policies and procedures that are fully communicated to their workforce.
Suppliers must ensure every manufacturing facility complies with national and local environmental laws, including all laws related to waste disposal, air emissions, discharges, toxic substances and hazardous waste disposal. Suppliers must validate that all input materials, including wood and “conflict materials,” were obtained from permissible sources, consistent with international treaties and protocols in addition to local laws and regulations.
Suppliers must foster conditions in which factory employees can freely communicate grievances and complaints and expect prompt and reasonable action. A formal grievance mechanism process must be accessible and communicated to all employees in the facility.
The grievance mechanism must make it easy for employees to report complaints anonymously, as well as ensure that no negative consequences and/or punishments result from employees voicing their concerns.
Corporate Compliance and Ethical Standards
C6 Diamond LLC has a strong commitment to ethics and integrity, and we conduct our business in a responsible manner. C6 Diamond LLC expects that Suppliers will abide by all applicable laws, rules and regulations in the manufacture, assembly, inspection, packaging, storage and handling of merchandise for C6 Diamond LLC. Ethics and integrity are the foundation of our Supplier relationships, and all Suppliers are required to meet or exceed C6 Diamond LLC’ Corporate Compliance and Ethical Standards. The guidelines below detail these standards and are part of all new and/or renewed commercial agreements with C6 Diamond LLC.
Conflicts of Interest
Suppliers and C6 Diamond LLC employees must not enter into transactions or other relationships that create a conflict of interest or the appearance of a conflict of interest.
Gifts and Entertainment
C6 Diamond LLC has a zero tolerance policy for receiving gifts and entertainment when such conduct is intended to or could reasonably give the appearance of intent to influence the recipient, violate C6 Diamond LLC’ Policies or violate the law. This policy does not change during traditional gift-giving seasons or during events sponsored by C6 Diamond LLC. Gifts and entertainment apply to anything received as a result of an actual or potential business relationship and for which the recipient does not pay face value. Examples of gifts and entertainment include: meals, travel and travel accommodations for business or vacation purposes, cash (including seasonal red envelopes), tickets to sporting or cultural events, discounts not available to the general public, gift certificates, supplier product samples for personal use, wine or alcohol and any other merchandise or services.
Suppliers must not willfully conspire to deceive anyone while doing business with C6 Diamond LLC.
Foreign Corrupt Practices Act
The U.S. Foreign Corrupt Practices Act (the “FCPA”) is a criminal statute that prohibits the corrupt payment of money or giving of things of value, i.e., “bribes,” to foreign officials in order to obtain or retain business. C6 Diamond LLC’ strong commitment to ethical conduct and to open and fair business conducted worldwide encompasses compliance with applicable U.S. and international laws, including the FCPA. C6 Diamond LLC employees and agents should understand that any actions taken by them on behalf of C6 Diamond LLC in violation of the FCPA create criminal exposure for themselves, the company and, in certain circumstances, its foreign subsidiaries. C6 Diamond LLC expects each of its employees to comply willingly and completely with the FCPA and this Policy.
Suppliers may not offer or give anything of value to a foreign official, a foreign political party official, a foreign political party or a candidate for foreign political office that might be considered a bribe. Suppliers must make accurate and complete entries in their records and follow generally accepted accounting procedures as required by local law. Suppliers may not make any false or misleading entries on their books and records.
C6 Diamond LLC encourages Suppliers to contact us if an employee ever asks the Supplier to do anything that infringes upon these standards. C6 Diamond LLC provides an e-mail address to be used by Suppliers to report violations of company policy pertaining to receiving or soliciting gifts, bribes or kickbacks, disclosure of confidential information, or a conflict of interest.
If any Supplier is aware of a situation where there may be a violation of company policy pertaining to receiving or soliciting gifts, bribes or kickbacks, disclosure of confidential information, a conflict of interest, or any other violation of these Corporate Compliance and Ethical Standards, they should immediately notify C6 Diamond LLC.
Suppliers will take appropriate steps to ensure that the provisions of this Supplier Code of Conduct Manual are communicated to employees.
Supplier Diversity and Equal Employment Opportunity
C6 Diamond LLC is committed to promoting economic growth through diversity by offering competitively priced, high-quality products to our customers. One of the ways C6 Diamond LLC will achieve growth is through a comprehensive Supplier diversity business strategy that includes working with a variety of businesses.
Equal Employment Opportunity – Affirmative Action Statement
C6 Diamond LLC supports and complies with both the spirit and the intent of Executive Order 11246, 29 CFR Part 471 Appendix A to Subpart A, the Civil Rights Act of 1964, the Americans with Disabilities Act, the Vietnam Era Veterans Readjustment Act, the Rehabilitation Act of 1973, the Age Discrimination in Employment Act, and other pertinent federal and state laws and regulations which are designed to promote equal employment opportunity. Domestic suppliers are advised that, in accordance with these laws and regulations as well as under certain contractual conditions, it and its contractors and subcontractors are obliged to take affirmative action to provide equal employment opportunity without regard to race, color, religion, national origin, age, sex, physical or mental disability, or status as a qualified disabled veteran, recently separated veteran, other protected veteran or Armed Forces service medal veteran.
Product Safety and Intellectual Property
The safety of products being sold by C6 Diamond LLC is of crucial concern to us. C6 Diamond LLC requires that Suppliers and manufacturers comply with all applicable legal and regulatory safety requirements; conduct routine safety tests in-house and by independent, certified third-party testing laboratories when required; or use equivalent procedures when not specifically required to use certified laboratories.
If a product sold by C6 Diamond LLC becomes subject to a recall, Supplier agrees to work with C6 QA, its lawyers and/or any other designated party engaged directly or indirectly by C6 Diamond LLC to provide any needed information and to assist in the management of the recall. Supplier agrees to work closely with C6 Diamond LLC and any appropriate regulatory agencies to remove the product from the market as quickly as possible. In some instances, when legitimate concerns about materials or processes are raised in the absence of a regulatory standard, Suppliers will assist C6 Diamond LLC to isolate or remove products from shipment or retail, pending more definitive study. In all circumstances, Suppliers must stand behind the quality and safety of their products and take such actions that are in the best interests of C6 Diamond LLC’ customers.
If Supplier sells C6 Diamond LLC a product that is similar to a product that is subject to a recall (same failure mode or root cause), Supplier shall immediately notify C6 Diamond LLC.
C6 Diamond LLC respects the valid intellectual property rights of others. Suppliers must certify to C6 Diamond LLC all rights they claim are owned in the products they supply to C6 Diamond LLC and that their products do not knowingly violate or infringe upon the intellectual property rights of others. This certification may include, but is not limited to, providing C6 Diamond LLC with an opinion of United States intellectual property counsel, and/or appropriate licenses, agreements, patents and/or registrations.
Any innovations or product improvements created in whole or part by C6 Diamond LLC shall be deemed to be the intellectual property of C6 Diamond LLC and shall remain the exclusive property of C6 Diamond LLC at all times. Suppliers may be asked to acknowledge this ownership by C6 Diamond LLC at the onset of a specific project and may be required to sign an Intellectual Property License Agreement or similar agreement upon completion of development.
Country of Origin
The country of origin is the country of manufacture, production or growth of an item. Proper determination of country of origin can affect rate of duty, eligibility for Free Trade Agreements, tariffs, anti-dumping and countervailing inclusions or exclusions to scope, admissibility of products into United States and more. Materials or components sourced from other countries and manufacturing processes performed in other countries must be disclosed to C6 Diamond LLC.
Factories will be inspected by C6 Diamond LLC’ inspectors and engineers to ensure components used in the production and manufacturing processes are verified. Furthermore, products must be directly exported from the factory to the United States.
Country of Origin Marking and Labeling
Suppliers must ensure that all merchandise (or the outermost retail container) is accurately and clearly marked or labeled with its country of origin and other labeling information in compliance with the laws of the country in which the merchandise was manufactured and the countries in which the merchandise will be sold.
Social Compliance Commitment
At C6 Diamond LLC, we view each person in our Supply Chain as an extension of our community. As such, we believe it is important to provide the individuals who make our products with healthy, safe and fair working conditions.
In order to assess factory conditions, we have selected reputable third party monitoring firms to conduct social compliance and CTPAT audits.
Initial audits as well as subsequent annual re-audits will be paid by C6 Diamond LLC.
Typically, audits will be announced with a 2-week window via e-mail or phone call from a representative of the third party audit firm and via e-mail by C6 Diamond LLC’ Social Compliance Manager. You will be required to accept this window; if you accept the 2-week window and then discover you will not be able to grant access to the auditor(s), it is your responsibility to inform the third party firm immediately so they can reschedule. Failure to reschedule with the auditor in advance or denying access to the factory will result in the Supplier being responsible for the full audit fee as well as other potential penalties or termination of Supplier’s business relationship with C6 Diamond LLC.
C6 Diamond LLC expects that you will grant the auditors full access to your factory so that they can conduct a thorough audit.
Click here to download a copy of the Supplier Code of Conduct and Compliance Manual