RBA CODE OF CONDUCT-MANAGEMENT SYSTEMS

RBA CODE OF CONDUCT is made up of five sections. Sections A, B, and C outline standards for Labor, Health and Safety, and the Environment, respectively. Section D adds standards relating to business ethics. Section E outlines the elements of an acceptable system to manage conformity to this Code.

E.MANAGEMENT SYSTEMS

Participants shall adopt or establish a management system with a scope that is related to the content of this Code. The management system shall be designed to ensure: (a) compliance with applicable laws, regulations and customer requirements related to the participant’s operations and products; (b) conformance with this Code; and (c) 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)Company Commitment

Corporate social and environmental responsibility policy statements affirming Participant’s commitment to compliance and continual improvement, endorsed by executive management, and posted in the facility in the local language.

2)Management Accountability and Responsibility

The Participant clearly identifies senior executive and company representative(s) responsible for ensuring implementation of the management systems and associated programs. Senior management reviews the status of the management systems on a regular basis.

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 labor practice and ethics risks associated with Participant’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.

5)Improvement Objectives

Written performance objectives, targets and implementation plans to improve the Participant’s social, environmental, and health and safety performance, including a periodic assessment of Participant’s performance in achieving those objectives.

6)Training

Programs for training managers and workers to implement Participant’s policies, procedures, and improvement objectives and to meet applicable legal and regulatory requirements.

7)Communication

A process for communicating clear and accurate information about Participant’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.

9)Audits and Assessments

Periodic self-evaluations 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.