OUR COMMITMENT TO EXCELLENCE
Empire Surfaces, its subsidiaries, and its affiliates are committed to maintaining: A standard of excellence in every facet of our business and across all corners of the world Ethical and responsible conduct in all our operations Respect for the rights of all individuals Respect for the environment
We expect all our suppliers, agents, and other third parties with whom we conduct business (“Suppliers”) to share these commitments. It is essential that all Suppliers adhere to the following standards. Compliance with these standards is a prerequisite for conducting business with us. By supplying products, goods, articles, or services, and issuing invoices for the same, the Supplier certifies its adherence to this Code of Conduct concerning referenced products, goods, articles, or services, as well as the materials contained in such products. Failure to comply with the provisions of this Code of Conduct and other Empire Surfaces policies and procedures may lead to the termination of the Supplier’s relationship with us. Additionally, violations of the standards outlined in this Code of Conduct may result in criminal penalties and civil liabilities.
Associations
Suppliers shall respect the rights of employees to associate, organize, and engage in collective bargaining lawfully and peacefully, without repercussions or interference.
Bribes, Illegal Payments, and Illegal Solicitations
Any form of corruption, extortion, and embezzlement is strictly prohibited. Suppliers shall not bribe government officials or others in violation of the U.S. Foreign Corrupt Practices Act (FCPA), the UK Bribery Act, or the laws of any country in which the Supplier operates. Suppliers shall not offer, pay, authorize, or promise money or anything of value to a government official in a corrupt manner to secure or maintain business.
Child Labor
Empire Surfaces prohibits the use of child labor. We endorse the United Nations (U.N.) Convention on the Rights of the Child (1989) and adhere to the International Labor Organisation (ILO) Minimum Age Convention no. 138 (1973) and Worst Forms of Child Labor no. 182 (1999).
The term “child” refers to a person younger than 15 (or 14 where local law allows) or, if higher, the local legal minimum age for employment or the age for completing compulsory education.
Should instances of child labor be discovered in any production facility, Empire Surfaces will require the Supplier to implement a corrective action plan. Failure to implement corrective action within the agreed timeframe or repeated violations may lead to the termination of business with the concerned Supplier. The corrective action plan will prioritize the child’s best interests, considering family and social circumstances and educational level. Measures will be taken to ensure the transition from child labor to more sustainable alternatives.
Coercion and Harassment
Suppliers shall treat every employee with dignity and respect, refraining from corporal punishment, threats of violence, or any form of physical, sexual, psychological, or verbal harassment or abuse.
Compensation
Wages are essential for employees’ basic needs, and Suppliers shall recognize this. Suppliers shall adhere to applicable wage and hour laws and regulations, including those pertaining to minimum wages, overtime, maximum hours, piece rates, and other compensation components. If local laws do not mandate overtime pay, Suppliers shall pay at least regular wages for overtime work. Workweeks shall not exceed 60 hours, including overtime, and employees must have at least one day off every seven days. All overtime must be voluntary. Workweeks shall not surpass legal limits. Suppliers are encouraged to exceed local industry standards when applicable.
Conflict Minerals
Empire Surfaces is dedicated to responsibly sourcing raw materials, including “conflict minerals” such as gold, tin, tungsten, and tantalum. Suppliers are expected to provide materials that are “conflict-free,” meaning they do not fund armed conflict in the Democratic Republic of Congo (DRC) or neighboring countries. Alternatively, conflict minerals must originate from recycled or scrap sources. Suppliers are required to survey their suppliers to determine the origin of conflict minerals and whether they are conflict-free. Responses to surveys or requests related to conflict minerals supplied to Empire Surfaces must be prompt.
Conflicts of Interest
Suppliers shall avoid any business activity that conflicts with or hampers their provision of products and services to Empire Surfaces.
Health and Safety
Suppliers shall ensure a safe and healthy workplace for employees, complying with all relevant laws and regulations. This includes providing access to clean water, sanitary facilities, fire safety, adequate lighting, and ventilation, and applying the same health and safety standards to any employee housing provided.
Gifts and Entertainment
Soliciting gifts, cash, trips, or incentives from Suppliers is strictly prohibited. Empire Surfaces employees shall not accept gifts that could influence their decision-making. Cash and cash equivalents (gift cards) are prohibited. Commissions, fees, or payments from Suppliers in connection with work for us are prohibited. Business outings within the normal course of business are permissible as long as they do not influence or appear to influence business judgments.
Involuntary Labor
Suppliers shall not employ forced or involuntary labor, whether in prison, bonded, indentured, or any other form. Human trafficking and slavery practices are strictly prohibited.
Monitoring, Compliance
Suppliers shall grant Empire Surfaces and its designated agents (including third parties) authorization to engage in monitoring activities to confirm compliance with the Code of Conduct. This includes unannounced on-site inspections, record reviews, provision of environmental and sustainability reports, and private employee interviews. Suppliers shall maintain on-site documentation to demonstrate compliance.
Nondiscrimination
Suppliers shall not discriminate in hiring, employment practices, advancement, salary, discipline, retirement, or termination based on race, religion, age, nationality, social or ethnic origin, sexual orientation, gender, political opinion, disability, or the exercise of legal rights. Suppliers shall comply with all relevant laws prohibiting employment discrimination and unfair labor practices.
Other Laws
Suppliers shall comply with all applicable laws and regulations, including anti-competition and unfair trade practices laws, as well as laws governing manufacturing, pricing, sale, distribution, and service provision.
Protection of the Environment
Suppliers shall adhere to all environmental laws and regulations, including Empire Surfaces’ environmental initiatives. Responsible resource use and proper waste disposal, in accordance with laws, are essential.
Publication
Suppliers shall ensure that this Code of Conduct is communicated to employees. A copy of this Code of Conduct, in the local language, shall be prominently displayed in a location accessible to employees at all times.
Subcontracting
Suppliers shall inform Empire Surfaces of any subcontracting and ensure that subcontractors adhere to this Code of Conduct. We support our Suppliers’ efforts to source supplies and services from certified businesses owned by minorities, women, disadvantaged individuals, or those with disabilities.Workplace Violence Suppliers shall maintain a violence-free workplace and respond promptly to acts or threats of violence.