Sustainable Procurement Policy and Code of Conduct

Policy

The Bernard Group (TBG) is committed to continually improving the sustainability level of our supply chain by incorporating environmental and social principles into our purchasing program.

Through this procurement policy, we intend to make our operations more sustainable by:

• Upholding the laws and regulations of the respective countries we operate in
• Endorsing highest standards of economic, social, ethical and environmental practice
• Identifying and moderating risks associated with our procurement process
• Communicating the policy with stakeholders (internal and external) and raising awareness among our suppliers

Scope of Commitment

Our Sustainable Procurement policy applies to all suppliers of The Bernard Group. The policy helps identify and evaluate qualified suppliers, promote best practices, and serve as a communication and improvement tool for the industry. Our commitment also extends to all individuals throughout our supply chain, and we use our relationships with our suppliers and other business partners to encourage and promote the principles of this policy throughout their networks. 

As a company, we abide by the laws where we operate. We expect our suppliers to share our commitment and standards by adopting similar policies within their business operations and, where possible, work with them to develop the capacity to do so.

Focus and Important Issues

In accordance with our commitment to the highest standards, we expect our suppliers to aspire to the same standards in their business operations, including but not limited to: 

Environment

Comply with TBG’s Environmental Policy

• Comply and adhere to all the applicable environmental laws in respective countries/jurisdiction
• Undertake initiatives to promote greater environmental responsibility such as:
  • Responsible waste management and disposal 
  • Reduction of greenhouse gas and other emissions harmful to the environment 
  • Minimize energy and water consumption
  • Protect biodiversity

Wood Products

• TBG practices and promotes the efficient and responsible use of wood and wood products.  
• TBG commits to source wood that:
  • comes from a known source;
  • is legally harvested and traded;
  • does not threaten high conservation value or high carbon stock forests;
  • does not come from deforestation or other ecosystem conversion, which leads to biodiversity loss, including that of rare, threatened and endangered species;
  • is not endangered;
  • is harvested and produced in a way that recognizes and upholds indigenous and other local community rights and customs;
  • is harvested and produced ensuring that human and worker rights are protected, including decent and humane working conditions and no forced labor.

• TBG promotes and supports the development and use of alternative environmental products. 
• TBG expects its vendors and their suppliers of wood and wood products to maintain compliance with laws and regulations pertaining to their operations and the products they manufacture.

Business Ethics

Comply with TBG’s Anti-Bribery, Anti-Corruption Policy

• Comply with all applicable international and domestic laws regarding ethical business practices 
• This includes but is not limited to laws governing: 
  • Money laundering 
  • Fraud, bribery, corruption 
  • Conflicts of interest 
  • Data security issues 
  • Anti-competitive practices
  • Breaches of physical and digital data

Labor and Human Rights

Comply with TBG’s Labor and Human Rights Policy

• Comply with all applicable laws, in accordance with the principles of the International Labor Organization, the UN Global Compact and the UN Universal Declaration of Human Rights 
• Provide all workers with a safe and healthy working environment

Community Development 

• Provide employees with competitive wages
• Partner with the local governments and communities to improve the education, cultural, economic and social well-being of communities in which they operate 

Implementation

Based on the Sustainable Procurement policy and its CSR commitment, TBG promotes and implements sustainable procurement by working together with our supply chain. 

We conduct due diligence throughout our business to access, identify, prevent and mitigate actual and potential adverse impacts to stakeholders across our supply chain. Due diligence tools that we rely on include sustainable procurement key performance indicators, materiality analysis, regulatory compliance audits, and social and environmental risk assessments of our suppliers. Consistent with the Sustainable Procurement policy, the issues assessed include energy consumption, water, biodiversity, pollution, waste, customer safety, industrial safety, labor practices, human rights, corruption, bribery, fraud, money laundering, and sustainable procurement.

When adverse impacts are uncovered in our business activities, operations or supply chain, The Bernard Group is committed to taking timely action to remediate in a fair and equitable manner in line with the UNGPs. 

Due Diligence

In compliance with international trade regulations, TBG conducts visual compliance restricted party screening through Descartes on all of our suppliers to ensure that all suppliers are free from corruption and bribery and adhere to the laws and regulations of the countries where they operate. 

Raise a Concern

If you suspect that there is a violation of any of the above issues occurring in relation to The Bernard Group, you are encouraged to raise your concerns at as early a stage as possible. If you’re uncertain about whether a certain action or behavior can be considered a violation of this policy, you should speak to your manager, Human Resources or the General Manager.

The Bernard Group familiarizes all employees with its whistleblowing procedures so employees can vocalize their concerns swiftly and confidentially. 

All employees have access to our 24-hour Helpline to report work-related problems confidentially and without fear of retaliation. The Company will investigate to the best of its ability, address and respond to the concerns of employees and will take appropriate corrective action in response to any violation. 

Training and Communication

The Bernard Group will provide training on this policy as part of the induction process for all relevant employees. Employees will also receive regular, relevant training on how to adhere to this policy, and will be asked annually to formally accept that they will comply with this policy. 

The Bernard Group’s Sustainable Procurement Policy will be clearly communicated to all suppliers, contractors, business partners and any third-parties at the outset of business relations, and as appropriate thereafter. 

Governance and Accountability

The Bernard Group’s CEO, along with the ethics committee, is responsible for monitoring the effectiveness of this policy and will review the implementation of it on a regular basis. They will assess its suitability, adequacy and effectiveness. 

Any need for improvements will be applied as soon as possible. Employees are encouraged to offer their feedback on this policy if they have any suggestions for how it may be improved. Feedback of this nature should be addressed to Human Resources . 

This policy does not form part of an employee’s contract of employment and The Bernard Group may amend it at any time so to improve its effectiveness.

We understand that procurement performance improvement is a continuous process and recognize the contribution of our suppliers in our journey to become more sustainable.