CODE OF CONDUCT

Overview

At MegaFood, we aspire to create a world where everyone is truly nourished by:

  • sourcing the highest quality ingredients from partners we trust
  • embracing transparency by giving everyone we work with visibility into the company’s operations

To fulfill these aspirations we are committed to:

  • Respect for the rights of all individuals
  • Respect for the environment, and:
  • Integrity and ethical conduct in all of our operations.

We expect these same commitments to be shared by all growers, co-manufacturers, suppliers, intermediary-suppliers, and distributors (“Suppliers”) of MegaFood’s ingredients, packaging, and products. At a minimum, we require all Suppliers to meet the following ethical sourcing standards, or have remedial plans in place where standards are not yet met.

Below are our standards for ethical sourcing, which apply to all aspects of our supply chain, from production facility to the fields. By electing to become a Supplier to MegaFood, you represent that you meet these standards and agree to be audited at our discretion. If you do not currently meet all standards, we expect you to notify us of the areas of non-compliance and to diligently and expeditiously work towards full compliance with these standards. Should a pattern of violation of these principles or a failure to comply with these standards become known to MegaFood® and not be immediately corrected, we may discontinue the business relationship.

Legal and regulatory compliance

All MegaFood® Suppliers and their representatives shall conduct their business activities in full compliance with the applicable laws and regulations of their respective countries, states, and localities, including but not limited to those related to labor, immigration, health and safety, and the environment.

Monitoring and evaluation

All MegaFood Suppliers will authorize MegaFood and its designated agents (including third parties) to engage in monitoring activities to confirm compliance with this Code of Conduct, including unannounced on-site inspections of manufacturing facilities and employer-provided housing; reviews of books and records relating to employment matters; and private interviews with employees. Suppliers will maintain on site all documentation that may be needed to demonstrate compliance with this Code of Conduct.

Respect for the rights of all individuals

  • All labor must be voluntary: Forced, bonded, slave, unpaid prison or indentured labor are not tolerated.
  • No child labor: Suppliers must not use child labor. The term “child” refers to a person under the age of 15 or, if older, the legal minimum age for employment or for completing compulsory education specified by applicable local and national laws. Suppliers employing young persons will also comply with any laws and regulations applicable to such persons. The term “young persons” means persons who are under age 18, but who do not meet the definition of “child” set forth above.
  • No discrimination: Discrimination in hiring and employment practices is not allowed, including (but not limited to) in compensation, promotion, discipline, termination or retirement, on the basis of race, color, religion, age, nationality, social or ethnic origin, sexual orientation, marital status, gender identity, political affiliation or disability.
  • No threatening, harsh, or inhumane treatment: Each employee must be treated with dignity and respect, and without the use of corporal punishment, threats of violence or other forms of physical, sexual, psychological or verbal harassment or abuse. Suppliers shall not engage in or support trafficking in human beings. Workers must be allowed to maintain control over their identity documents.
  • Respect freedom of association: The rights of workers to join, form, or assist a trade union, or refrain from doing so, in accordance with applicable law and practice must be respected.
  • Provide a safe work environment: A safe and healthy workplace in compliance with all applicable laws and regulations, ensuring at a minimum reasonable access and education, where applicable, to potable water and sanitary facilities, emergency exits, essential fire and other safety equipment, appropriate personal protective equipment, emergency medical care, and adequate lighting and ventilation is expected. The same standards of health and safety are applied in any housing that they provide for employees.
  • Support reasonable wages and compensation: At a minimum, Suppliers must follow all applicable wage and hour laws and regulations, including minimum wages, overtime, maximum hours, and provide legally mandated benefits. Overtime should be compensated at a rate at least equal to the regular hourly compensation rate. Where local industry standards are higher than applicable legal requirements, we expect Suppliers to meet higher standards. We encourage Suppliers to provide a livable wage. Monetary fines or deduction in compensation as a means of disciplinary action are not allowed.
  • No excessive working hours: Working hours, meal and rest breaks and allotted days off must comply with local and national laws and regulations and collective agreements. And, except in extraordinary business circumstances, working hours shall not exceed a total of 60 hours per week (inclusive of overtime for hourly employees). All overtime must be voluntary. In addition, except in extraordinary business circumstances, employees shall be provided at least one day off in every seven-day period.

Respect for the environment

  • Support environmental sustainability: At a minimum, all Suppliers must comply with all applicable environmental laws and regulations. Farms and factories should monitor and report their production processes as needed to protect the environment and as required by law, including those related to emissions and discharges and disposal of wastes. We encourage our Suppliers to adopt strategies for conservation of natural resources, recycling, source reduction and pollution elimination. We encourage our suppliers to put programs in place to measure and reduce their environmental footprint, including without limitation in the following areas, soil health, carbon, water, energy, and materials sourcing.
  • Support regenerative agriculture: We value the protection of natural resources and the valuable ecosystem services that they provide, including carbon storage, water protection, air quality, and healthy food production. We encourage our Suppliers to adopt practices that protect and support improvements in soil health and ecosystem services. We encourage Suppliers to participate in the MegaFood Farm Fresh program.
  • Conflict minerals: Suppliers are expected to adopt policies and management systems to ensure conflict-free supply chains. As of the date this Code was issued, conflict minerals are defined as those that contain tin, tungsten, tantalum or gold and are obtained from the Democratic Republic of Congo (DRC), Republic of Congo, Central Africa Republic, South Sudan, Zambia, Angola, Tanzania, Burundi, Rwanda or Uganda).
  • Animal welfare: We do not tolerate abuse of animals. Suppliers are expected to adopt policies and management systems to ensure the humane treatment of animals, including adopting practices aligned with the Five Freedoms of Animal Welfare.

    Integrity and ethical conduct in all of our operations

  • No improper payments to government officials: We prohibit Suppliers from making improper payments to government officials with respect to our business and expect that our Suppliers abide by the U.S. Foreign Corrupt Practices Act as well as all other applicable local and national laws concerning bribery or corruption.
  • No commercial bribery: We prohibit personal payments or bribes, and the offering of such payments or bribes, to individuals employed by MegaFood customers or suppliers, or receipt of a bribe or personal payment by our employees.
  • Support communities: We encourage our Suppliers to be good global citizens and support people, communities, and the environment. We encourage Suppliers to pursue B Corporation certification.
  • Be honest: We expect our Suppliers to be upfront in their dealings with MegaFood, auditors and audit programs, and other third parties. We expect our Suppliers to report conduct that violates the law or these Standards or undermines the integrity of the ethical sourcing program so that we can address it collaboratively. We want you to feel comfortable in approaching us directly to ask questions or when you believe violations of this Supplier Code of Conduct have occurred. If you do not feel comfortable making a report directly or if you prefer to place an anonymous report in confidence, you are encouraged to use our EthicsPoint hotline, hosted by an independent third party hotline provider. You may submit reports relating to violations stated in this Code of Conduct. To file an anonymous complaint as a supplier for MegaFood, you may do so by going to the website: https://secure.ethicspoint.com/domain/media/en/gui/45989/index.html or by calling toll-free at (855)-809-3045