It is Pinwheel Logistics Inc’s belief that how we operate as a Company, and as individuals, is based on the principle of doing the right thing. This leads our customers and business partners to do business with us, and the best talent to join us in working for Pinwheel Logistics Inc. This Supplier Sustainability Policy identifies the global standards to be followed in your business activities on behalf of Pinwheel Logistics Inc. Suppliers are expected to share Pinwheel Logistics Inc’s commitment to these standards.

Coercion, Harassment and Discipline

Pinwheel Logistics Inc expects its suppliers to treat their employees with dignity and respect. Suppliers are expected to have systems in place to prevent, detect, and resolve unacceptable worker treatment such as harassment, inappropriate use of discipline, discrimination, physical or mental punishment, or other forms of intimidation or abuse (e.g., physical abuse, threat of abuse, sexual or other harassment, verbal abuse, any type of corporal punishment, or other forms of mental and/or physical coercion as a form of discipline).

Laws and Ethical Standards

The supplier shall comply with all laws applicable to its business. The supplier should support the principles of the United Nations Global Compact, the UN Universal Declaration of Human Rights as well as the 1998 International Labour Organization Declaration on Fundamental Principles and Rights at Work, in accordance with national laws and practice. This especially applies to:

Human Rights and Fair Labor Practices

Code of Conduct and Ethics

Pinwheel Logistics Inc conducts business with integrity and in compliance with all applicable laws and regulations. A commitment to integrity is critical to how we conduct business and maintain our outstanding reputation in the communities in which we do business. Suppliers are expected to understand and comply with Pinwheel Logistics Inc’s Code of Conduct and Ethics, and demonstrate the highest standard of integrity and ethical conduct in all business activities.

Human Rights

Pinwheel Logistics Inc is committed to recognizing human rights and labor principles throughout its organization and supply chain. Pinwheel Logistics Inc considers employees to be one of the most important resources and is committed to the treatment of all employees with dignity and respect. All suppliers are required to comply with local laws governing the employment relationship.

Women´s rights

Pinwheel Logistics Inc`s suppliers will respect the principle that women are entitled to political, economic and social equality. The guidance for this approach is the “Convention on the elimination of all forms of discrimination against women”.

Rights of minorities and indigenous peoples

Pinwheel Logistics Inc´s suppliers will show respect for the rights of local communities to decent living conditions, education, employment, social activities, and the right to Free, Prior, and informed Consent (FPIC) to developments that affect them and the lands on which they live, with particular consideration for the presence of vulnerable groups.

Wages and Hours, Working Conditions

Suppliers must comply with all applicable wage and hour laws, including minimum wage, overtime, maximum hour rules, meal and rest periods, and to provide legally mandated benefits. Where local industry standards exceed applicable legal requirements, suppliers are encouraged to provide wages and ensure working conditions that meet the higher local industry standards.

Human rights and working conditions policy

Child Labor Policy Brief & Purpose

This Child Labor Policy is designed to outline the company’s commitment to prevent and eliminate child labor in all its operations and supply chains. The purpose of this policy is to ensure compliance with international labor standards and to uphold the rights and well-being of children. This policy aims to create a safe and nurturing environment for children by prohibiting any form of child labor within the company and its supply chains. Suppliers will not use child labor. The term child refers to children under the legal age for employment in any location.

Child Labor Policy Scope

This policy applies to all employees, contractors, suppliers, and any other parties involved in the company’s operations and supply chains. It covers all activities, products, and services provided by the company, regardless of the geographical location.

Child Labor

The supplier shall not employ children under the legal age of employment in any country or local

jurisdiction. If the minimum age of employment is not defined, it shall be 15 years. Workers under the age of 18 shall only perform work in accordance with legal requirements (e.g. with regards to working time and working conditions) and subject to any requirement regarding education or training.

Policy Elements:

Definition of Child Labor:

a. Child labor refers to any work performed by children under the legal minimum age for employment or work that is likely to be hazardous or harmful to their physical, mental, or social development.

b. The legal minimum age for employment should be determined based on relevant national and international laws and regulations.

Prohibition of Child Labor:

a. The company strictly prohibits the use of child labor in any part of its operations or supply chains.

b. All employees, contractors, and suppliers are expected to comply with this policy and ensure that child labor is not used directly or indirectly.

Compliance with Legal Requirements:

a. The company will comply with all applicable laws and regulations regarding child labor in all the countries where it operates.

b. In cases where national laws and international labor standards conflict, the higher standard that provides greater protection to children shall be followed.

Due Diligence:

a. The company will conduct regular assessments and due diligence to identify and address any risks of child labor within its operations and supply chains.

b. Supply chain partners will be required to provide information regarding their policies and practices related to child labor.

Remediation and Reporting:

a. Any instances or suspicions of child labor discovered within the company’s operations or supply chains must be reported immediately to the appropriate management or designated contact.

b. The company will take prompt and appropriate action to address any confirmed cases of child labor and work towards remediation and prevention.

Awareness and Training:

a. The company will provide adequate training and awareness programs to employees, contractors, and suppliers to ensure understanding and compliance with this policy.

b. Training programs will focus on recognizing and preventing child labor, as well as promoting responsible sourcing and ethical business practices.

Continuous Improvement:

a. The company is committed to continuously improving its Child Labor Policy and practices by regularly reviewing and updating its policies, procedures, and due diligence mechanisms.

b. Feedback and suggestions from relevant stakeholders will be considered to enhance the effectiveness of the policy and ensure its alignment with evolving best practices and international standards.

Non-Retaliation:

a. The company prohibits any form of retaliation against individuals who report suspected child labor or participate in investigations related to child labor.

b. Any acts of retaliation will be treated as a serious violation and will be subject to appropriate disciplinary action.

Conclusion

In conclusion, implementing a child labor policy is crucial for any organization to ensure ethical practices and protect the rights and well-being of children. By establishing clear guidelines and procedures, businesses can demonstrate their commitment to upholding the rights of children and contribute to the eradication of child labor globally. A well-defined child labor policy not only safeguards the reputation of a company but also fosters a culture of social responsibility, promoting sustainable and equitable business practices. With a comprehensive child labor policy template in place, businesses can play a crucial role in creating a better future for children around the world.

Forced Labor

The supplier shall not use any form of forced, bonded or involuntary labor. All labor must be voluntary.  Workers must be allowed to maintain control over their identification documents (e.g. passports, work permits or any other personal legal documents). The supplier shall ensure that workers do not pay fees or make any payment connected to obtaining employment throughout the hiring process and the employment period. The supplier shall be responsible for payment of all fees and expenses (e.g. licenses and levies) relating to workers, where legally required.

Punishment, mental and/or physical coercion are prohibited. Disciplinary policies and procedures shall be clearly defined and communicated to the workers.

Modern Slavery, Forced Labor, & Human Trafficking Statement

Pinwheel Logistics Inc believes that all employees should have the right to voluntarily select whether to be employed by the supplier. The supplier will not use forced or involuntary labor of any kind or tolerate physically abusive disciplinary practices.We are committed to ensuring that our business operates in a socially responsible way that prevents slavery and human trafficking. We are also committed to playing our part in helping the world to improve practices designed to combat slavery and human trafficking. Pinwheel Logistics Inc believes that all employees should have the right to voluntarily select whether to be employed by the supplier. The supplier will not use forced or involuntary labor of any kind or tolerate physically abusive disciplinary practices.

We are not aware of any allegations of human trafficking/slavery activities against any of our current suppliers. If such allegations arise, we will immediately conduct an inquiry and report it to the authorities where required.

Preventing the Flow of Funds to Armed Groups and Conflicts

Pinwheel Logistics Inc strives to use only components with raw materials where extraction, transport, trade, processing and export are obtained from validated sources as a matter of principle, wherever practicable. We ask our suppliers to source responsibly and endeavor to understand that sourcing of their materials neither directly nor indirectly provides funding to conflicts and human rights abuses. (Conflict Minerals)

Compensation and Working Hours

The supplier shall comply with all applicable national laws and mandatory industry standards regarding working hours, overtime, wages and benefits. The supplier shall pay workers in a timely manner and clearly convey the basis on which workers are being paid.

Deductions from wages as a disciplinary measure shall not be allowed, if not legally permitted.

Freedom of Association and Collective Bargaining:

The employees of the supplier must be free to join or not to join a union/employee representation of their choice, free from threat or intimidation. The supplier recognizes and respects the right to collectively bargain in accordance with applicable laws.

Diversity

The supplier shall promote an inclusive work environment that values the diversity of its employees.  The supplier shall not discriminate or tolerate discrimination with respect to gender, race, religion, age, disability, sexual orientation, national origin or any other characteristic protected under law.

Discrimination

Pinwheel Logistics Inc is committed to providing all employees with a professional working environment which is free from unlawful forms of discrimination and harassment. Suppliers must make all employment decisions based on the facts and individual merit. Suppliers shall not discriminate in their hiring and employment practices (e.g., pay/promotion) and must follow all employment laws.

DIVERSITY, EQUITY, & INCLUSION POLICY

Pinwheel Logistics Inc´s suppliers will develop and promote inclusive cultures where diversity is valued, celebrated and everyone is able to contribute fully and reach their full potential. Suppliers should encourage diversity in all levels of their workforce and leadership, including boards of directors. Pinwheel Logistics Inc is committed to fostering a work environment that is inclusive, equitable and diverse. One where we celebrate differences; where each employee is treated fairly and is respected for those differences; and where every team member has an equal opportunity to contribute to the success of our company and reach their full potential. This commitment stems from our senior most leaders and includes every member of our team.  Pinwheel Logistics Inc suppliers will develop and promote inclusive cultures where diversity is valued, celebrated and everyone is able to contribute fully and reach their full potential. Suppliers should encourage diversity in all levels of their workforce and leadership, including boards of directors. 

SCOPE:

This policy applies to all current employees (full-time, part-time, contractual, permanent and temporary) of Pinwheel Logistics and it extends to our treatment of vendors and suppliers, contractors, visitors, customers and job applicants.

DEFINITIONS For the purpose of this policy and for interpretation by our employees:

Diversity refers to the differences in the makeup of our employees, including age, race, colour, national or ethnic origin, family or marital status, sex, gender identity or expression, sexual orientation, language, physical and mental ability, genetic characteristics, political affiliation, religion, socio-economic status, and other characteristics that make our employees unique.

Equity means ensuring fair access to all employment opportunities for everyone, regardless of diversity or difference. Equity addresses the effects of colonization, economic and social disparity, and injustices against marginalized groups. It also addresses systemic barriers to access and participation in employment opportunities, sometimes through practices that may not appear to be “equal”.

Inclusion is the process through which the company builds community and where employees and the organization at large experience the benefits of diversity. Inclusion provides everyone with the right to participate in our workplace.

COMMITMENTS

As a company, Pinwheel Logistics Inc is committed to:

Creating an environment where the individual differences and contributions of all employees are recognized and valued. Maintaining a work environment that promotes dignity and respect for every employee. Attracting and retaining a skilled and diverse workforce that best represents the talent that is available within the communities in which we operate. Ensuring all selection-based criteria are appropriate and based on diverse skills, experience and perspectives when both hiring new staff and promoting current team members. Selecting team members for new jobs or promotions based solely on merit. Regularly reviewing and updating as required all employment practices and policies that do not support the intention behind this policy – including, but not limited to: recruitment and selection; compensation and benefits; professional development and training; promotions; transfers; social and recreational programs; terminations; and the ongoing development of a work environment built on the premises of diversity, equity and inclusion. Reviewing diversity statistics on an ongoing basis to ensure representation of our communities within and at all levels of our workforce. Complying with all associated legislation requirements. Encouraging respectful communication at all times. Actively discouraging, and addressing through appropriate disciplinary action, any forms of intimidation, bullying, victimization, vilification or harassment that result from or are contrary to the intentions of this policy.

Additionally, we expect our company leaders to: 

Understand their role in promoting diversity, equity and inclusion within our company. Act in accordance with this policy at all times. Actively discourage and address any actions that are contrary to this policy.

And we require all employees to:

Treat all employees with dignity and respect at all times. Act in accordance with this policy at all times. Identify and bring forward any situations that are contrary to this policy.

COMPLAINTS

It is the expectation of Pinwheel Logistics Inc that all employees adhere to the commitments outlined above. Should you witness any breach of this policy, please advise Human Resources immediately. If you are personally in violation of any commitments or the general intention of this policy, disciplinary action, up to and including termination, may be taken. The disciplinary action will be in direct correlation to the nature and extremity of the violation.

REPRISALS

Any employee who files a valid complaint in accordance with this policy will not be subject to any form of retaliation either direct (e.g. dismissal or demotion) or indirect (e.g. being passed over for a promotion).

POLICY REVIEW

Pinwheel Logistics Inc is committed to reviewing our policies regularly. This policy will be reviewed no less than once every three years.

Pinwheel Logistics Inc & its suppliers will show respect for the rights of local communities to decent living conditions, education, employment, social activities, and the right to Free, Prior, and informed Consent (FPIC) to developments that affect them and the lands on which they live, with particular consideration for the presence of vulnerable groups. Pinwheel Logistics Inc strives to use only components with raw materials where extraction, transport, trade, processing and export are obtained from validated sources as a matter of principle, wherever practicable. We ask our suppliers to source responsibly and endeavor to understand that sourcing of their materials neither directly nor indirectly provides funding to conflicts and human rights abuses. 

Freedom of Association and Collective Bargaining Policy

Suppliers must respect their employees’ right to choose to join or not to join a trade union, or to have recognized employee representation in accordance with local law. Suppliers are expected to maintain constructive dialogue and negotiate in good faith with such representatives. Suppliers shall not harass, discriminate against, or otherwise penalize workers, worker representatives, or trade union members because of their interest and/or membership in, or affiliation with, a trade union, or their legitimate trade union activity, in accordance with international labor standards. 

Purpose This Policy defines the commitment of Pinwheel Logistics Inc to employees’ right to engage in collective bargaining and have freedom of association. Pinwheel Logistics Inc of Directors has ultimate responsibility for the implementation of this Policy, with full power to delegate as they deem appropriate.  Scope This Policy applies to all Pinwheel Logistics Inc employees, including any third parties acting for and on behalf of the company, wherever they are located.  Freedom of Association at present, Pinwheel Logistics Inc employees are not unionized and do not engage in collective bargaining. This is due both to the nature of our business and to the diversity of skills and roles among our personnel. To the best of Pinwheel Logistics Inc’s knowledge, no Pinwheel Logistics Inc employee is a member of any trade union.  However, Pinwheel Logistics Inc commits to respect and protect the right of all employees to freedom of association, collective bargaining, the right to organize and to engage in workers’ representation.   Pinwheel Logistics Inc respects the right of employees to engage in collective bargaining with respect to matters such as: Health and safety, remuneration, working hours, training and career development, work-time flexibility, life-long learning, stress management and equal opportunities.   Pinwheel Logistics Inc abides by all applicable national laws relating to the recognition of trade unions. No prior authorization is necessary for any employee or employees to join any trade union. No employee will suffer victimization, discrimination or any other ill-treatment due to their decision to engage or not engage in workers’ representation. Pinwheel Logistics Inc is open to recognition of a trade union or unions if a substantial number of eligible employees choose to join a union or unions.

Preventing Bribery and Corruption

Pinwheel Logistics Inc is committed to conducting business ethically throughout the world. Pinwheel Logistics Inc prohibits suppliers from giving or promising to give anything of value to employees or representatives of foreign governments, governmental agencies, political parties, or to political candidates, for the purpose of obtaining or retaining business. Suppliers must conduct business with integrity and in full compliance with all applicable laws.

Complaint Process and Retaliation Protection

Pinwheel Logistics Inc expects its suppliers to implement a complaint procedure that includes all relevant business processes and that guarantees the complainant every protection against retaliation (“whistleblower policy”).

Conflict of Interests

Pinwheel Logistics Inc requires that employees of its suppliers avoid any conflict between their own interests and the interests of their company in dealing with suppliers, customers and other third parties. It is also a conflict of interest for an employee during or subsequent to employment and without proper authority to give or make available to anyone or use for his/her own benefit information of a confidential nature derived from his/her employment.

Health & Safety

We expect our suppliers to strive to implement the standards of occupational health and safety at a high level by applying a health and safety management approach appropriate for the business.  The supplier shall comply with applicable occupational health and safety regulations and provide a work environment that is safe and conducive to good health, in order to preserve the health of employees, safeguard third parties and prevent accidents, injuries and work-related illnesses.  This includes regular workplace risk assessments and the implementation of adequate hazard control and precautionary measures. Employees are to be adequately educated and trained in health and safety issues.

Machine Safety Policies

Users must complete safety training and be approved to operate desired machine or tool

ALWAYS wear safety glasses

Be sure ALL guards are in place before operating the machine

STOP the machine before making measurements OR cleaning chips

Do not attempt to stop a moving a spinning part with your hand

Be familiar with the location of the machine’s stop/E-stop switch or lever controls

You are the ONLY one who should operate controls

Always be aware of the direction of rotation and RPM of tool/part being cut

NEVER reach over or near rotating cutter

NEVER start a cut until there is adequate clearance for ALL moving parts

Use care when cleaning machines – use shop vacs and brushes to remove chips

NEVER clean a machine with compressed air or your hands – chips are SHARP

General Machine Safety Rules

No equipment is to be left running while unattended. Any damage to the machines, tools, fixtures, etc. must be reported to a supervisor immediately. Machines shall be completely stopped and de-energized before attempting to clear jammed work or debris.

Inform Supervisors of Unsafe Conditions.

Use Equipment, Machines, and Tools Properly.

Wear Safety Equipment (PPE)

Prevent Slips and Trips.

Keep Work Areas and Emergency Exits Clear.

Eliminate Fire Hazards.

Avoid Tracking Hazardous Materials.

Prevent Objects from Falling.

General requirements for machine guards. Guards shall be affixed to the machine where possible and secured elsewhere if for any reason attachment to the machine is not possible. The guard shall be such that it does not offer an accident hazard in itself. Point of operation guarding.

GHG Emissions Policy

Pinwheel Logistics as a company understands the detrimental impact that greenhouse gas emissions (GHG) have on the environment, and as such, we have implemented a comprehensive emissions policy. Our main objective is to reduce our carbon footprint significantly by adopting sustainable practices throughout our operations. We prioritize the use of fuel-efficient vehicles, leverage route optimization and load consolidation strategies to minimize fuel consumption, and continuously invest in alternative fuel technologies. Additionally, we actively encourage our employees to adopt eco-friendly behaviors, such as carpooling or using public transportation, and engage in carbon offsetting programs to further mitigate our impact. By taking these measures, we aim to demonstrate our commitment to environmental responsibility and contribute to global efforts in combating climate change.

Renewable Energy Policy

At our logistics company, we are committed to reducing our environmental impact and promoting sustainable practices. As part of our Renewable Energy Policy, we prioritize the use of renewable energy sources across all our operations. We are actively investing in renewable energy initiatives, such as solar panels and wind turbines, to generate clean energy and decrease our reliance on fossil fuels. With our commitment to renewable energy, we aim to minimize greenhouse gas emissions and contribute to a greener future. By incorporating sustainable practices into our logistics operations, we strive to be a leader in the logistics industry and inspire other businesses to embrace renewable energy solutions.

Environmental, Health & Safety

Pinwheel Logistics Inc is committed to complying with all applicable environmental, health and safety legal requirements and protecting the environment. Suppliers are expected to comply with all applicable environmental, health and safety legal requirements and prevent incidents or conditions that might result in a violation of law or otherwise endanger the environment.

Suppliers must provide each employee with a safe and healthful work environment. Each supplier has responsibility for maintaining a safe and healthy workplace for all employees by following health and safety rules and practices and reporting accidents, injuries and unsafe equipment, practices or conditions as stated in the Environmental, Health and Safety Policy.

Environmental Sustainability

Pinwheel Logistics Inc adopts the definition for Sustainability as “meeting the needs of the present without compromising the ability of future generations to meet their own needs.” For Pinwheel Logistics Inc, this means being aware of our impacts and understanding how these affect the world around us. Our mission is to reduce these impacts while increasing the profitability and longevity of our company.  Pinwheel Logistics Inc expects its suppliers to support Pinwheel Logistics Inc’s sustainability mission by complying with all applicable environmental laws, rules and regulations while using resources wisely. Suppliers are expected to share Pinwheel Logistics Inc’s commitments by developing and implementing a sustainability program focused on using natural resources responsibly, reducing water usage, reducing waste generation, preventing air pollution, improving energy efficiency and reducing the carbon footprint of their operations. Pinwheel Logistics Inc expects its suppliers to implement responsible chemical management in regards of purchasing, usage and handling.

Environment

The supplier shall comply with all applicable environmental laws, regulations and standards as well as implement an effective system to identify and eliminate potential hazards to the environment. 

We expect our business partners to strive to support Pinwheel Logistics climate protection goals through the products and services they deliver (e.g. by providing relevant data on climate protection). In this regard, we also expect our suppliers to take climate protection appropriately into account in their own operations, for example by setting climate protection goals for themselves and achieving them.

Animal Welfare

Pinwheel Logistics Inc upholds the highest standards for ethical behavior. With respect to animal welfare, we require compliance with all legal requirements and, as applicable, we expect our suppliers to implement industry-best policies and practices related to the ethical treatment of animals. Pinwheel Logistics Inc commits to a belief in the humane treatment of animals, including freedom from thirst and hunger, freedom from discomfort, pain, injury and disease, freedom to express normal behavior, and freedom from fear and distress.

Decarbonisation

Pinwheel Logistics Inc´s suppliers undertake to contribute to the reduction of GHG emissions from a company’s value chain.

Reuse and recycling

Suppliers will establish processes to use existing materials or products as they are to reduce waste whilst recycling refers to turning a product into a raw material that can be used again.

Biodiversity, land use and deforestation

Pinwheel Logistics Inc´s suppliers will be active in the maintenance of ecosystems so that flora and fauna are not lost and natural habitats do not suffer irreparable damage. As part of the European Union’s Green Deal plans to protect ecosystems and biodiversity, the European Commission has proposed a new law to halt deforestation and minimize the EU’s impact on forests worldwide. The proposed law will require companies that sell commodities linked to deforestation and forest degradation (e.g. leather) to ensure they are ‘deforestation-free’ before placing them on the European market or exporting them from the EU.

Land, forest and water rights and forced eviction

Suppliers commit to the avoidance of forced eviction and the deprivation of land, forests and waters in the acquisition, development or other use of land, forests and waters.

Soil quality

Suppliers will determine the condition of the soil in their area of responsibility and establish measures to maintain and improve soil quality.

Noise emissions

Pinwheel Logistics Inc´s suppliers will determine the release of noise into the environment from various sources that can be grouped in: transportation activities, industrial activities and daily normal activities. They will establish measures to improve noise emissions.

Fire protection policy

All work areas will be kept free of debris and other combustible materials. Inside company-owned or leased buildings, fire extinguishers will be spaced no more than 100 feet apart and will have no less than a 2A rating for every 3,000 feet of protected building.

Financial responsibility (accurate records)

Suppliers commit to a company’s responsibility to accurately record, maintain and report business documentation including, but not limited to, financial accounts, quality reports, time records, expense reports and submissions to customers or regulatory authorities, when appropriate. Books and records are expected to be maintained in accordance with applicable law and generally accepted accounting principles.

Data Protection and Data Security Disclosure of Information

The supplier shall adhere to relevant data protection and data security laws as well as to respective regulations, in particular with regard to personal data of customers, consumers, employees and shareholders.  The supplier shall comply with all said requirements when personal data is collected, processed, transmitted or used.  Suppliers shall safeguard and make only appropriate use of confidential information.  The supplier shall not disclose any information that is not known to the general public.  Pinwheel Logistics Inc expects its suppliers to respect the privacy for all employees and other participants in the business process. Pinwheel Logistics Inc expects that the content of the General Data Protection Regulation (EU 2016/679) will be included in the internal management documentation of the suppliers and that it will be implemented in full. All information and documents from previous, current or future projects are to be assessed as customer property and accordingly protected from unauthorized access. The unauthorized disclosure of protected information of any kind is prohibited.

Disclosure of information

Pinwheel Logistics Inc´s suppliers commit to a company’s responsibility to disclose financial and non-financial information in accordance with applicable regulations and prevailing industry practices and, when applicable, disclose information regarding labor force, health and safety practices, environmental practices, business activities, financial situation and performance.

Private or public security forces policy

Pinwheel Logistics Inc´s suppliers should commission or use private or public security forces to protect the business project if, due to a lack of training or control on the part of the company, the deployment of the security forces may lead to violations of human rights

Bribery and Corruption

The supplier shall comply with all national and international anti-bribery regulations as well as

applicable anti-corruption laws, regulations and standards. The supplier shall not (either directly or indirectly) offer or promise to provide anything of value to improperly influence an official act or to secure an improper advantage in order to obtain or retain business.

Export controls and economic sanctions

Suppliers will respect the restrictions on the export or re-export of goods, software, services and technology, as well as with applicable restrictions on trade involving certain countries, regions, companies or entities and individuals.

Trade Regulation

The supplier shall comply with all applicable trade and import regulations including sanctions and embargoes that apply to their activities.

Money Laundering & Financial Records

The supplier shall comply with applicable laws and regulations designed to combat money laundering activities. The supplier shall maintain financial records and reports according to international laws and regulations.

Fair Competition and Antitrust Law

Pinwheel Logistics Inc expects all those involved in the business process to submit to the regulations of antitrust law and international agreements on fair competition.  The supplier shall comply with applicable competition and anti-trust laws.

Conflicts of Interest

A conflict of interest arises when an individual has a private/personal interest which could appear to influence their decisions. Such conflict of interest situations include a relationship by blood or marriage, partnership, business partnership or investment. The supplier shall disclose any actual or potential conflict of interest with Pinwheel Logistics, inc. personnel.

Counterfeit Parts Policy

Suppliers will fulfill the requirement for companies to develop, implement and maintain methods and processes appropriate to their products and services to minimize the risk of introducing counterfeit parts and materials into deliverable products. Business partners are also expected to establish effective processes to detect counterfeit parts and materials and, if detected, quarantine the materials and notify the Original Equipment Manufacturer (OEM) customer and/or law enforcement as appropriate. Finally, companies are expected to confirm that any sales to non-OEM customers are compliant with local laws and those products sold will be used in a lawful manner.

Intellectual property

Pinwheel Logistics Inc´s suppliers are requested to protect creations of the mind, such as inventions; literary and artistic works; designs; and symbols, names and images used in commerce. It is protected in law by, for example, patents, copyright and trademarks, which enable people to earn recognition or financial benefit from what they invent or create.

Implementation of Sustainability Standards in the Supply Chain

Pinwheel Logistics Inc expects its suppliers and all subcontractors to abide by the requirements of this Supplier Sustainability Policy, including identifying risks within their supply chains and taking appropriate measures to address them. Pinwheel Logistics Inc´s suppliers shall implement sustainability requirements for their own supply base following the content of this policy. It is agreed that all Pinwheel Logistics Inc suppliers will find out about the sustainability requirements on the website of the project-related OEM, and that they observe and implement them.

Right to Audit and Ensure Compliance

Pinwheel Logistics Inc reserves the right to conduct audits to ensure compliance with these requirements and also reserves the right to take appropriate measures, including discontinuing any relationship with a supplier should the supplier violate, fail to correct, or have a pattern of violating this Policy. Pinwheel Logistics Inc reserves also the right to send out questionnaires regarding the Supplier Sustainability Requirements and to establish a rating system that can have an impact on the awarding process.

Business Continuity Planning

The supplier shall be prepared for any disruptions of its business (e.g. natural disasters, terrorism, software viruses, illness, pandemics, infectious diseases). This preparedness especially includes disaster plans to protect both employees as well as the environment as far as possible from the effects of possible disasters that arise within the domain of operations.

Business Partner Dialogue

The supplier shall encourage its own suppliers to adhere to this Supplier Code of Conduct as part of fulfilling their contractual obligations.

Compliance with the Supplier Code of Conduct

Pinwheel Logistics, Inc. reserves the right, upon reasonable notice, to check compliance with the requirements of the Supplier Code of Conduct. Pinwheel Logistics, Inc. encourages its suppliers to implement their own binding guidelines for ethical behavior.  Any breach of the obligations stipulated in this Supplier Code of Conduct is considered a material breach of contract by the supplier.

Legal Compliance

Pinwheel Logistics Inc is committed to complying with all applicable legal requirements. Suppliers are expected to comply with all applicable legal requirements and prevent incidents or conditions that might result in a violation of law. All purchased materials used in manufacture of goods shall satisfy current governmental and safety constraints on restricted, toxic and hazardous materials as well as environmental, electrical and electromagnetic considerations applicable to the country of manufacture and sale. All suppliers must be in compliance with ISO 14001, ISO 9001 under consideration with IATF 16949 or their successors, as amended from time to time.

ENVIRONMENTAL HEALTH AND SAFETY

Note: Each item in this Section 8.00 is a best practice, except to the extent an item is required by local law or regulation in a location, in which case the item is mandatory in that location. Pinwheel strongly encourages its Service Providers to adopt these or other equivalent practices to promote Employee and visitor and environmental health and safety..

General Safety

Emergency Contacts

Health and Safety information (such as labor law, emergency contacts, etc.) should be

maintained in a central location for all Employees to see.

Safety Awareness 

Safety orientations should be done with all new Employees, new Temporary Employees,and visitors. Additional orientations should be done for employees handling Goods that present special safety hazards. Refresher safety awareness training should be done periodically.

Fire Extinguishers

Pathways to fire extinguishers and other fire fighting equipment should be clear of all obstructions.

Ergonomics

Evacuation Routes

Emergency evacuation routes should be posted or otherwise communicated to all

Employees and visitors and should be clear of all obstructions.

Janitorial/Pest Control

Janitorial and pest control measures should be in place as needed to prevent infestation of Goods and maintain a hygienic Facility.

Risk Assessment 

A risk assessment should be done for each Facility at least once per year (within the previous 365 days). Any safety hazards discovered should be addressed with adequate controls.

Safety Incident Reporting 

Any safety incident or near miss arising from Services provided should be reported to Pinwheel and Service Provider’s management personnel as soon as possible. Service Provider should implement appropriate risk controls following its root-cause analysis.

Transport Safety 

Note: This Section applies only to Service Providers providing trucking Services.

Hours of Service

Service Provider should ensure that drivers are well rested and must ensure compliance with all local hours-of-service regulations.

Vehicle Safety 

Service Provider should have a documented maintenance program to ensure all vehicles are in safe operating condition and must ensure compliance with all applicable vehicle safety requirements and in accordance with manufacturer’s specifications.

Drug and Alcohol Policy

Service Provider should have a drug and alcohol policy.

Hazardous Waste

Service Provider should have a process in place to properly identify, dispose of, and record hazardous waste generated in any Facility in a compliant and safe manner.