Code of Conduct

Prodir is committed to exemplary social and ethical conduct: we believe that we bear responsibility for all persons involved in the production and support of our products and services worldwide. 
By trading with Prodir, you are agreeing to support and apply our fundamental principles in the areas of human rights, working conditions, the environment and combatting corruption. 
The provisions of this Code of Conduct set forth Prodir’s expectations for all Partners registered with Prodir and with whom Prodir does business. Prodir expects these principles to be applied by Partners and their employees, as well as any subsidiaries, affiliate entities and subcontractors thereof. 
The provisions of this Code constitute the minimum standards, not the maximum. This Code of Conduct strictly obligates all Partners to observe and comply with all of the fundamental principles expressed herein. 
Respect of this Code of Conduct by Partners will determine the continuing commercial relationship between Partners and Prodir. 

1. Labour and human rights

Child labour: There must be no use of child labour. The minimum working age is determined by existing national regulations and the relevant ILO standards. Prodir supports the use of legitimate workplace apprenticeship programmes in accordance with all applicable laws and regulations. Employees under the age of 18 should not perform hazardous work, may be restricted from night work with consideration given to educational needs, and shall be entitled to more breaks than adults. 

Discrimination: Prodir expects its Partners to ensure equality of opportunity and treatment with regards to employment and occupation, and does not tolerate discrimination based on race, skin colour, age, gender, gender identity, sexual orientation, ethnicity, disability, faith, political affiliation, union membership or marital status. Employees must be treated with dignity and respect. Employees are not to be exposed to threats of violence or any other harassment or maltreatment of a physical, sexual, psychological or verbal nature. 

Minimum wages: Prodir expects its Partners to ensure all employees are paid at least the minimum wage required by applicable laws and to comply with laws and regulations relating to overtime, maximum hours, piece rates and other forms and components of compensation, and to provide legally mandated benefits. Wage payments shall be made at regular intervals and directly to employees; deductions from wages for disciplinary reasons are prohibited. 

Working hours: Prodir expects its Partners to ensure that no employees are forced to work in excess of the number of hours permitted by applicable national law; where the law is silent, normal working hours shall not exceed 8 hours per day and 48 hours per week, and employees shall also be given at least an average of one day off for every 7 day period. Overtime shall be voluntary, shall not exceed 12 hours per week, shall not be demanded on a regular basis and shall always be compensated at a premium rate. 

Freedom of association: Prodir expects its Partners to recognise the right of employees to join or to form trade unions and to bargain collectively in accordance with local laws. Employees shall be able to communicate openly with management regarding working conditions without fear of reprisal, intimidation, or harassment. 

Forced labour: Prodir expects its Partners to ensure the prohibition of forced labour in all its forms; employees may leave the employer freely, providing they comply with advance notice periods specified by law. The retention of identity papers, passport(s), work permits and any other documents is prohibited. Inhumane treatment, physical punishment, insults, harassment and mental or physical coercion are all prohibited. 

2. Environmental safety and production processes

Prodir expects its Partners to operate an effective environmental policy and to comply with existing legislation and regulations regarding environmental protection; Partners shall ensure that programmes are in place at all their sites in order to minimise the environmental impact of their activities. 

Chemicals and hazardous materials: Chemicals and other materials which may constitute a hazard if released into the environment must be identified and managed in order to ensure their safe and proper handling, transport, storage, re-cycling or reuse and disposal. 

Wastewater and solid waste: Wastewater and solid waste generated through operations, industrial processes and/or sanitation facilities must be treated, monitored and controlled as required prior to being discharged. 

Recycling and minimum waste: Prodir expects its Partners to operate a recycling policy. This means that waste is correctly recycled and not diverted into the environment, in accordance with local regulations; waste of all types, including waste water and energy, must be minimised or eliminated at the source. 

Air emissions: Volatile organic chemicals, aerosols, corrosives, particulates and products which deplete the ozone or are combustible that are generated by and emitted as a result of operations must be classified, monitored, controlled and treated as required prior to their discharge or disposal. 

Pollution prevention: Prodir expects its Partners to ensure that all substances that present an environmental hazard are appropriately managed in order to prevent any risk of pollution in the event of their accidental emission or discharge, including into ground water. 

3. Health and safety

Prodir expects its Partners to provide a safe and healthy work environment for all employees. Partners shall identify and protect employees from any physical, chemical or biological hazards in the work environment; moreover, machinery, equipment and processes must be safe and pose no risk to employees’ health. 

Industrial health and safety: Prodir expects its Partners to ensure that employees’ exposure to chemical and physical agents is well identified, evaluated and controlled. Employees must be provided with appropriate personal protective equipment, including gloves, masks, work clothes and safety shoes. 

Emergency situations and response: Prodir expects its Partners to have comprehensively identified and assessed potential emergency situations and to have minimized their impact by implementing emergency plans including emergency reporting, employee notification and evacuation procedures, employee training and drills, and the provision of appropriate fire detection systems, firefighting equipment and adequate exit facilities. 

4. Ethical conduct

Corruption: Prodir expects its Partners to adhere to the highest standards of moral and ethical conduct, to respect local laws and not to engage in corrupt practices in any form, including but not limited to extortion, fraud or bribery. 

Conflicts of interest: Prodir Partners are expected to disclose to Prodir any situation that may constitute a conflict of interest and to inform Prodir of any Prodir employees who may have an interest of any kind in the Partners’ business or any sort of economic connection with the Partner. 

Gifts: Prodir has a zero tolerance policy and does not accept any type of gift. Prodir expects that its Partners shall not offer any benefit such as free goods or services, employment or sales opportunities to any Prodir staff member in order to facilitate the Partners’ business with Prodir. 

January 2019

Pagani Pens SA - BU Pens - Prodir
Fausto Conti 
Regulatory Affairs Manager