Overview
As a reputable and leading dormitory operator in Singapore, Centurion depends upon the seamless flow of goods and services for the smooth conduct of its business. To its valuable customers, trusted partners and government authorities, Centurion is committed to conduct its business with the highest standards of ethics and integrity. It is imperative that business operations are conducted in an environmentally responsible and ethical way.
The CENTURION Supplier Code of Conduct (Code), establishes standards to ensure that working conditions are safe, that workers are treated with respect and dignity. CENTURION requires all of our suppliers to adhere to our standards, understand their business, and operate in full compliance with the laws, rules and regulations of the countries in which they operate. When differences arise between standards and legal requirements, the stricter standard shall apply, in compliance with applicable law.
The Code comprises 5 sections;- A. Labour
- B. Health and Safety
- C. Environment
- D. Ethics
- E. Management systems
- F. Whistleblowing
A.Labour
CENTURION expects its suppliers to uphold the human rights of workers, and to treat them with dignity and respect as understood by the international community. This applies to all workers including temporary, migrant, student, contract, direct employees, and any other type of worker. The recognized standards, as set out in the References, were used in preparing the Code and may be useful sources of additional information.
The labour standards are:
1.Freely Chosen Employment
Forced, bonded (including debt bondage) or indentured labour, involuntary or exploitative prison labour, slavery or trafficking of persons is not permitted. This includes transporting, harbouring, recruiting, transferring, or receiving persons by means of threat, force, coercion, abduction or fraud for labour or services. There shall be no unreasonable restrictions on workers’ freedom of movement in the facility in addition to unreasonable restrictions on entering or exiting company-provided facilities including, if applicable, workers’ dormitories or living quarters.
As part of the hiring process, all workers must be provided with a written employment agreement in their native language that contains a description of terms and conditions of employment. Foreign migrant workers must receive the employment agreement prior to the worker departing from his or her country of origin and there must be no substitution or change(s) allowed in the employment agreement upon arrival in the receiving country unless these changes are made to meet local law and provide equal or better terms. All work must be voluntary, and workers shall be free to leave work at any time or terminate their employment without penalty if reasonable notice is given as per the worker’s contract.
Employers, agents, and sub-agents may not hold or otherwise destroy, conceal, or confiscate identity or immigration documents, such as government-issued identification, passports, or work permits. Employers can only hold documentation if such holdings are required by law. In this case, at no time should workers be denied access to their documents.
Workers must not be required to pay recruitment fees or other employment-related fees to employers’ agents or sub-agents. If any such fees have been paid by workers, such fees must be repaid to the worker.
2.Young Workers
Suppliers shall not employ any person under the minimum legal age or child labour for employment as prescribed by the relevant local authority. Child labour is not to be used in any stage of manufacturing. The term “child” refers to any person under the age of 15, or under the age for completing compulsory education, whichever is greatest. Suppliers must implement an appropriate mechanism to verify the age of workers. If child labour is identified, the supplier should immediately remediate and provide other assistance. Workers under the age of 18 (Young Workers) must not perform work that is likely to jeopardize their health or safety, including night shifts and overtime. The use of legitimate workplace learning programs, which comply with all laws and regulations, is supported. Suppliers must ensure proper management of student workers through proper maintenance of student records, rigorous due diligence of educational partners, and protection of students’ rights in accordance with applicable laws and regulations. Suppliers must provide appropriate support and training to all student workers. In the absence of local law, the wage rate for student workers, interns, and apprentices must be at least the same wage rate as other entry-level workers performing equal or similar tasks.
3.Working Hours
Suppliers shall not require their workforce to work beyond daily and weekly work hour limits as defined and required by local, state/provincial and federal/national law. Further, a workweek should not be more than 44 hours per week, excluding overtime, except in emergency or unusual situations. All overtime must be voluntary. Workers must be allowed at least one day off every seven days.
4. Wages and Benefits
Wage payments, compensation, overtime hours and legally mandated benefits must comply with all applicable laws and regulations. Supplier shall inform their workforce members of the basis on which they are paid via pay stubs or similar documentation and in a timely manner. All overtime must be voluntary. Workers must be allowed at least one day off every seven days. Deductions from wages as a disciplinary measure shall not be permitted.
5.Humane Treatment
Supplier shall ensure that all members of the workforce are treated with respect and to be no harsh or inhumane treatment including violence, gender-based violence, sexual harassment, sexual abuse, corporal punishment, mental or physical coercion, bullying, public shaming, or verbal abuse of workers; nor is there to be the threat of any such treatment. Disciplinary policies and procedures in support of these requirements shall be clearly defined and communicated to workers.
6.Non-Discrimination/Non-Harassment
MEP does not tolerate any harassment or discrimination. Workplaces must operate free of harassment and unlawful discrimination. Companies must not engage in discrimination or harassment based on race, colour, age, gender, sexual orientation, gender identity and expression, ethnicity or national origin, disability, pregnancy, religion, political affiliation, union membership, covered veteran status, protected genetic information or marital status in hiring and employment practices such as wages, promotions, rewards, and access to training. Workers should be provided with reasonable accommodation for religious practices. In addition, workers or potential workers should not be subjected to medical tests, including pregnancy or virginity tests, or physical exams that could be used in a discriminatory way.
7.Freedom of Association
In conformance with local law, suppliers shall respect the right of all workers to form and join trade unions of their own choosing, to bargain collectively, and to engage in peaceful assembly as well as respect the right of workers to refrain from such activities. Workers and/or their representatives shall 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.
B.Health and Safety
Suppliers will take actions, as necessary, to minimize the incidence of work-related injury and illness, and ensure a safe and healthy work environment.
Recognized management systems such as ISO 45001 and ILO Guidelines on Occupational Safety and Health were used as references in preparing the Code and may be useful sources of additional information.
The health and safety standards are:
1. Occupational Safety
Worker potential for exposure to health and safety hazards (chemical, electrical, and other energy sources, fire, vehicles, and fall hazards, etc.) are to be identified and assessed, mitigated using the Hierarchy of Controls, which includes eliminating the hazard, substituting processes or materials, controlling through proper design, implementing engineering and administrative controls, preventative maintenance and safe work procedures (including lockout/Tagout), and providing ongoing occupational health and safety training. Where hazards cannot be adequately controlled by these means, workers are to be provided with appropriate, well-maintained, personal protective equipment, and educational materials about risks to them associated with these hazards. Reasonable steps must also be taken to remove pregnant women and nursing mothers from working conditions with high hazards. In addition, any workplace health and safety risks to pregnant women and nursing mothers, including those associated with their work assignments, should be removed or reduced, and reasonable accommodations for nursing mothers should be provided. These accommodations should include a private or semi-private space to express milk, other than a bathroom, and a safe place to store milk until the end of their shift.
2. Emergency Preparedness
Potential emergencies and events are to 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. Emergency drills must be executed at least annually or as required by local law, whichever is more stringent. Emergency plans should also include appropriate fire detection and suppression equipment, clear and unobstructed egress, adequate exit facilities, contact information for emergency responders, and recovery plans. Such plans and procedures must focus on minimizing harm to life, the environment, and property.
3. Occupational Injury and illness
Procedures and systems are to be in place to prevent, manage, track and report occupational injury and illness, including provisions to encourage worker reporting, classify and record injury and illness cases, provide necessary medical treatment, investigate cases and implement corrective actions to eliminate their causes, and facilitate the return of workers to work.
4. Industrial Hygiene
Worker exposure to chemical, biological, and physical agents is to be identified, evaluated, and controlled according to the Hierarchy of Controls. If any potential hazards are identified, suppliers will look for opportunities to eliminate and/or reduce the potential hazards. If elimination or reduction of the hazards is not feasible, potential hazards are to be controlled through proper design, engineering, and administrative controls. When hazards cannot be adequately controlled by such means, workers are to be provided with and use appropriate, well-maintained, personal protective equipment – free of charge. Protective programs will be ongoing and include educational materials about the risks associated with these hazards.
5. Physically Demanding Work
Worker exposure to the hazards of physically demanding tasks, including manual material handling and heavy or repetitive lifting, prolonged standing, and highly repetitive or forceful assembly tasks is to be identified, evaluated, and controlled.
6. Work Equipment Safeguarding
Work related equipment and machinery must be evaluated for safety hazards. Physical guards, interlocks and barriers are to be provided and properly maintained where machinery presents an injury hazard to workers.
7. Sanitation, Food, and Housing
Workers are to be provided with ready access to clean toilet facilities, potable water, and sanitary food preparation, storage, and eating facilities. Worker dormitories provided by the supplier or a labour agent are to be maintained, to be clean and safe, and provided with appropriate emergency egress, hot water for bathing and showering, adequate lighting and heat and ventilation, individually secured accommodations for storing personal and valuable items, and reasonable personal space along with reasonable entry and exit privileges.
8. Health and Safety Communication
Suppliers must provide workers with appropriate workplace health and safety information and training in the language of the worker or in a language the worker can understand for all identified workplace hazards that worker are exposed to, including but not limited to mechanical, electrical, chemical, fire, and physical hazards. Health and safety-related information must be clearly posted in the facility or placed in a location identifiable and accessible by workers. Training will be provided to all workers prior to the beginning of work and regularly thereafter. Workers should be encouraged to raise any health and safety concerns.
C. Environment
Suppliers should recognize that environmental responsibility is integral to producing world-class products. Supplier shall identify the environmental impacts and minimize adverse effects on the community, environment, and natural resources within their manufacturing operations while safeguarding the health and safety of the public.
The environmental standards are (and should be applied when applicable:
1.Environmental Permits and Reporting
All required environmental permits (e.g. discharge monitoring), approvals, and registrations are to be obtained, maintained, and kept current and their operational and reporting requirements are to be followed.
2.Pollution Prevention and Resource Reduction
Emissions and discharges of pollutants and generation of waste are to be minimized or eliminated at the source or by practices such as adding pollution control equipment; modifying production, maintenance, and facility processes; or by other means. The use of natural resources, including water, fossil fuels, minerals, and virgin forest products, is to be conserved by practices such as modifying production, maintenance and facility processes, materials substitution, re-use, conservation, recycling, or other means
3.Hazardous Substances Chemicals, waste, and other materials posing a hazard to humans or the environment are to be identified, labelled, and managed to ensure their safe handling, movement, storage, use, recycling or reuse, and disposal. Appropriate training should be conducted to ensure the safe handling and disposal of hazardous substances.
4. Solid Waste
Suppliers should implement a systematic approach to identify, manage, reduce, and responsibly dispose of or recycle solid waste (non-hazardous).
5. Air Emissions
Air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone-depleting substances, and combustion by-products generated from operations are to be characterized, routinely monitored, controlled, and treated as required prior to discharge. Ozone-depleting substances are to be effectively managed in accordance with the Montreal Protocol and applicable regulations. Suppliers should conduct routine monitoring of the performance of its air emission control systems.
6. Material Restriction
Suppliers are to adhere to all applicable laws, regulations, and customer requirements regarding the prohibition or restriction of specific substances in products and manufacturing, including labelling for recycling and disposal.
7. Water Management
Suppliers should implement a water management program that documents, characterizes, and monitors water sources, use and discharge; seeks opportunities to conserve water; and controls channels of contamination. All wastewater is to be characterized, monitored, controlled and treated as required prior to discharge or disposal. Suppliers should conduct routine monitoring of the performance of its wastewater treatment and containment systems to ensure optimal performance and regulatory compliance.
8. Energy Consumption and Green-House Air Emissions
Suppliers are to establish a corporate-wide greenhouse gas reduction goal. Energy consumption and all relevant Scopes 1 and 2 greenhouse-gas emissions are to be tracked, documented, and publicly reported against the greenhouse gas reduction goal. Suppliers are to look for methods to improve energy efficiency and to minimize their energy consumption and greenhouse-gas emissions.
D. Ethics
To meet social responsibilities and to achieve success in the marketplace, suppliers and their agents are to uphold the highest standards of ethics. The ethical standards should include:
1.Business Integrity
The highest standards of integrity are to be upheld in all business interactions. Suppliers must have a zero-tolerance policy to prohibit any and all forms of bribery, corruption, extortion, and embezzlement.
2.No Improper Advantage
Bribes or other means of obtaining undue or improper advantage are not to be promised, offered, authorized, given, or accepted. This prohibition covers promising, offering, authorizing, giving, or accepting anything of value, either directly or indirectly through a third party, in order to obtain or retain business, direct business to any person, or otherwise gain an improper advantage. Monitoring, record keeping, and enforcement procedures must be implemented to ensure compliance with anti-corruption laws.
3.Disclosure of Information
All business dealings should be transparently performed and accurately reflected on Suppliers’ business books and records. Information regarding participant’s labour, health and safety, environmental practices, business activities, structure, financial situation, and performance is to be disclosed in accordance with applicable regulations and prevailing industry practices. Falsification of records or misrepresentations of conditions or practices is unacceptable.
4.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, and customer and supplier information is to be safeguarded.
5. Fair Business, Advertising and Competition
Standards of fair business, advertising, and competition are to be upheld.
6. Protection of Identity and Non-Retaliation
Programs that ensure the confidentiality, anonymity, and protection of supplier and employee whistleblowers2 are to be maintained unless prohibited by law. Suppliers should have a communicated process for their personnel to be able to raise any concerns without fear of retaliation.
7.Privacy
Suppliers are to commit to protecting the reasonable privacy expectations of the personal information of everyone they do business with, including suppliers, customers, consumers, and employees. Suppliers are to comply with privacy and information security laws and regulatory requirements when personal information is collected, stored, processed, transmitted, and shared.
E.Management Systems
Suppliers must adopt or establish a management system with a scope that is related to the content of this Code.
The management system should be designed to ensure:- compliance with applicable laws, regulations and customer requirements related to operations and products;
- conformance with this Code; and
- identification and mitigation of operational risks related to this Code. It should also facilitate continual improvement.
The management system should contain the following elements:
1.Business Integrity
The highest standards of integrity are to be upheld in all business interactions. Suppliers must have a zero-tolerance policy to prohibit any and all forms of bribery, corruption, extortion, and embezzlement.
2. No Improper Advantage
Bribes or other means of obtaining undue or improper advantage are not to be promised, offered, authorized, given, or accepted. This prohibition covers promising, offering, authorizing, giving or accepting anything of value, either directly or indirectly through a third party, in order to obtain or retain business, direct business to any person, or otherwise gain an improper advantage. Monitoring, record keeping, and enforcement procedures must be implemented to ensure compliance with anti-corruption laws.
3.Legal and Customer Requirements
A process to identify, monitor and understand applicable laws, regulations, and customer requirements, including the requirements of this Code.
4.Risk Assessment and Risk Management
A process to identify the legal compliance, environmental, health and safety3 and labour practice and ethics risks associated with supplier’s operations. Determination of the relative significance for each risk and implementation of appropriate procedural and physical controls to control the identified risks and ensure regulatory compliance.
4.Risk Assessment and Risk Management
A process to identify the legal compliance, environmental, health and safety3 and labour practice and ethics risks associated with supplier’s operations. Determination of the relative significance for each risk and implementation of appropriate procedural and physical controls to control the identified risks and ensure regulatory compliance.
6.Training
Programs for training managers and workers to implement policies, procedures, and improvement objectives and to meet applicable legal and regulatory requirements.
7. Communication
A process for communicating clear and accurate information about supplier’s or Centurion’s policies, practices, expectations, and performance to workers, suppliers, and customers.
8.Worker Feedback, Participation and Grievance
Ongoing processes, including an effective grievance mechanism, to assess workers’ understanding of and obtain feedback on or violations against practices and conditions covered by this Code and to foster continuous improvement. Workers must be given a safe environment to provide grievance and feedback without fear of reprisal or retaliation. An option to report grievances anonymously is preferred, but not required.
9. Audit and Assessments
CENTURION or third-party audits or assessments to ensure conformity to legal and regulatory requirements, the content of the Code, and customer contractual requirements related to social and environmental responsibility.
10. Corrective Action Process
A process for timely correction of deficiencies identified by internal or external assessments, inspections, investigations, and reviews.
11. Documentation and Records
Creation and maintenance of documents and records to ensure regulatory compliance and conformity to company requirements along with appropriate confidentiality to protect privacy
12. Supplier Responsibility
A process to communicate Code requirements to suppliers and to monitor supplier compliance to the Code.
