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Code of Conduct

Our Code of Conduct sets the values and principles that we as owners, managers, and employees follow in our interactions with each other, customers, suppliers, and regulatory authorities. It is framed around our core values of conducting ourselves ethically and responsibly, with honesty and integrity.

Business Ethics Policy

Suppliers must demonstrate a high degree of ethical conduct. Suppliers shall respect intellectual property rights and not violate the U.S. Foreign Corrupt Practices Act. Bribery in any form is prohibited. Falsification, or any attempt to interfere with the audit process, will be cause for immediate termination. Retaliation or reprisal against any person who, in good faith, reports unlawful or inappropriate activity related to the Code and/or the audit process may also lead to the termination of the business relationship.

Forced Labor Policy

Employees, contractors, and/or subcontractors are strictly prohibited from engaging in any activity related to forced labor. All workers have the right to: 

  • Freedom of employment (voluntary, free of deception and without threat of penalty),
  • Retention of personal belongings and documents (accessible at all times and not withheld by the
  • Wage & benefits (according to legal requirements, paid on time directly to employee, documented in the form of pay slips, and must not include any illegal deductions, deposits, or disciplinary infractions),
  • Leave & overtime (complies with labor laws, where overtime is voluntary, not mandated, coerced, free from suffering negative consequences, and paid according to local law),
  • Non-discrimination (principles apply equally to regularly employed workers, seasonal and/or temporary workers, contracted and/or subcontracted workers, migrant or refugee workers, and remote workers; no discrimination on the basis of sex, gender and gender identity, ethnicity, nationality, race, color, social origin, religion, faith, age, legal status, political opinion, disability, sexual orientation, pregnancy, or trade union membership or activity.)

There shall be no use of state-imposed forced labor, prison labor, debt bondage, or child labor.

Human Trafficking Policy

Employees, contractors, and/or subcontractors are strictly prohibited from engaging in any activity related to human trafficking, including:

  • Using misleading or fraudulent practices to recruit employees,
  • Charging a recruitment fee from an employee,
  • Arranging travel or facilities for a person for purposes of exploiting him or her,
  • Obtaining labor from a person by threats of serious harm to that person or another person,
  • Using a recruiter that does not comply with local labor laws,
  • Denying a person access to his or her identification or immigration documents,
  • Failing to provide return transportation to employees who are brought to a country outside their home country for the purpose of working on a U.S. government contract,
  • Failing to provide or arrange housing that meets host-country standards; or
  • If required by law or contract, failing to provide an employment contract, recruitment agreement, or other required work document in writing.

Freedom of Association Policy

To the extent permitted by the laws of the manufacturing country, Suppliers respect the right of its employees to freedom of association and collective bargaining. This includes the right to form and join trade unions and other worker organizations of their own choosing without harassment, interference, discrimination, or retaliation. In the absence of formal representation, Suppliers shall ensure that workers have a mechanism to report grievances.

Reporting and Retaliation

To encourage employees to report policy violations, Pacific Crest Trading Group strictly prohibits discrimination, harassment, or retaliation against employees who report violations or who cooperate with audits or investigations.

  • Employees should report any suspected violation of this policy to management or to the Human Resources department. If an employee suspects someone is being controlled or forced to work or provide services, the employee should report the suspected policy violation. Managers are expected to listen and respond appropriately when an employee reports a suspected violation.
  • Our company prohibits retaliation against any employee who reports suspected trafficking or assists with an internal or governmental audit or investigation. Any employee who fails to report a violation of this policy or engages in prohibited retaliation will be subject to disciplinary action, up to and including termination of employment.

Employees who engage in conduct that rises to the level of a violation of law can be held personally liable for such conduct. Remember, the Company cannot remedy claimed violation, discrimination, harassment, or retaliation unless employees bring these claims to the attention of management. Employees are encouraged to report any conduct which they believe violates this policy.