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INW Supplier Code of Conduct

INW’s purpose is to provide Nutrition & Wellness products the highest quality, innovation, and customer care. INW believes that supply chains supporting INW products should be sustainable and balance the needs of today with the needs of future generations. INW can achieve our purpose by working closely with our suppliers to ensure these goals are met in ways that sustainably support the future of the business and our communities. INW is committed to ESG — environmental, social, and governance principles. We pledge to manufacture nutritional supplements for our customers in the most responsible manner that fosters and instills pride in our employees, investors, and community.

This Supplier Code of Conduct outlines how INW expects its vendors, consultants, suppliers, producers, manufacturers, and other business partners (each a “Supplier Partner”) to work with it to fulfill that purpose – ethically and in compliance with applicable laws.

Guiding Principles

1. Adherence to Law

As a responsible company, we expect our global Supplier Partners to share our commitment to following the law. 

We expect our Supplier Partners to:

  • Know and follow the laws that apply to them and their business.

  • Engage in ongoing review of changes in legal requirements.

  • Update policies and practices as necessary in line with legal requirements and best practices.

  • Treat legal requirements as a minimum standard.

  • Alert INW to any material issues with the goods and services they supply – especially health and safety issues. This helps INW comply with global regulations and ensures products are safe for our communities and markets.

2. Business Integrity

We seek business relationships based on trust, transparency, and mutual accountability.

We expect our Supplier Partners to adhere to the following:

  • Compete fairly and ethically for INW’s business.

  • Never directly or indirectly offer or accept bribes, kickbacks, inappropriate gifts or hospitality, or other improper incentives in connection with INW’s business.

  • Modest gifts and hospitality are permitted, if they are not given as a quid pro quo, reasonable in and customary in the relevant context, and not otherwise intended to be or reasonably perceived as improper in nature. Cash or cash equivalent gifts are not acceptable under this Code of Conduct.

  • Avoid any conflict of interest relating to financial interests or other arrangements with our employees that may be considered inappropriate.

  • Work with their own suppliers, vendors, and other business partners to promote business conduct consistent with the principles in this Supplier Code of Conduct and in compliance with applicable laws.

3. Recordkeeping

We expect our Supplier Partners to maintain accurate and honest records. This helps us make responsible business decisions and disclose truthful and timely information to our stakeholders.

We expect our Supplier Partners to:

  • Maintain books and records that reflect all transactions in an accurate, honest, and timely way in accordance with best practices and standards.

  • Employ appropriate quality audit and compliance processes for matters such as product, worker health and safety, and labor and employment.

  • Disclose, on reasonable request, relevant information for facilities connected to any INW business and known origins of materials to enable traceability.

4. Good-Faith Dealing

We work with Supplier Partners who share our desire to build productive business relationships. This requires honest communications, mutual respect, and delivering on commitments.

We expect our Supplier Partners to:

  • Share our commitment to conducting business honestly and transparently.

  • Honor business obligations and manage unanticipated events in a proactive, timely, and open way.

  • Communicate with candor and forthrightness.

  • Provide all relevant information and supplement or update information in a timely fashion.

5. Treat all with dignity and respect

We expect our Supplier Partners to prioritize the safety, well-being, human rights, and dignity of all individuals whose talents and hard work help us deliver our products and services. 

We expect our Supplier Partners to:

  • Conduct their business activities in a manner that protects the health and safety of those whose lives they touch.

  • Respect the freedom of association and right of workers to form or join a legally recognized labor organization, if they choose, without fear of reprisal, intimidation, or harassment.

  • Treat all workers with dignity and respect, and provide an emotionally and psychologically safe and inclusive working environment.

  • Provide competitive, fair, and equitable pay that meets, at a minimum, establish minimum wages for the jurisdiction in which work is being performed.

  • Comply with applicable working hours laws, including overtime hours.

  • Not engage in or permit sourcing labor from any form of human trafficking for their operations and supply chains. Supplier partners should maintain policies against human trafficking cooperate with appropriate authorities, where possible, to investigate and end any occurrences in connection with their operations and supply chains.

  • Not engage in any form of forced labor from their operations and supply chains. Supplier Partners may not withhold wages, identity papers, work permits, or impose any other similar involuntary or coerced constraint as a condition of employment.

  • Not engage in any child labor from their operations and supply chains. Supplier Partners must not employ workers under the established minimum age for employment in the applicable jurisdiction.

  • Comply with applicable laws and regulations and avoid conditions or restrictions that could be harmful to the morals, health, safety and development of employees.

  • Respect land resources and tenure rights for everyone, especially for indigenous people, local communities, and ethnic or minority groups.

  • Not discriminate on the basis of color, race, national origin, gender, marital status, sexual orientation, religion, disability, and other similar factors.

6.  Protect INW’s information, assets, and interests

We expect our Supplier Partners to protect INW’s reputation and any information or property we entrust to them.

We expect our Supplier Partners to:

  • Protect any of INW’s confidential information to which they have access, including its intellectual property, trade secrets, or financial information.

  • Promptly notify INW in the event they become aware of any unauthorized disclosure of INW’s confidential information. 

  • Safeguard any property belonging to INW while under their control.

  • Follow all applicable laws and regulations with respect to the protection, disclosure, gathering, and retention of any personal information.

  • Avoid any situations that may adversely affect our business interests or reputation, and maintain strict standards to promote product safety.

7. Be a responsible global citizen

We count on our Supplier Partners to help INW meet our strategic sustainability commitments.

We expect our Supplier Partners to:

  • Reduce the environmental impact of their business through efforts such as eliminating deforestation, reducing greenhouse gas emissions and waste, and using resources efficiently.

  • Protect water resources by minimizing use of water in their operations, avoiding contamination from their operations, and reducing the impact on the water resources of the surrounding communities.

  • Commit to addressing and mitigating the impacts of their business on climate, land, water, soil, air, and biodiversity.

  • Take guidance from international standards, conventions, and declarations, including the United Nations Guiding Principles on Business and Human Rights (UNGPs), the International Bill of Human Rights, the International Labor Organization Fundamental Principles and Rights at Work, and the OECD Guidelines for Multinational Enterprises.

  • Generally seek to improve their environmental footprint including the promotion of sustainability initiatives such as energy and water conservation, pollution prevention, waste minimization, reuse, and recycling practices.

  • Provide their stakeholders access to grievance mechanisms for raising concerns confidentially without fear of retaliation.

  • Upon request, provide evidence of their compliance with the requirements of our Supplier Code of Conduct.

Compliance with this Supplier Code of Conduct:
Investigations and Corrective Actions

It is our goal to build trust-based relationships with ethical suppliers and business partners who comply with this Supplier Code of Conduct. We expect our Supplier Partners to act with candor and fully cooperate with our reasonable requests for data, information, certifications, and audit access to verify compliance, and to obtain assurances that their own business partners and producers uphold these principles.

When there is a concern, or we become aware of facts that indicate a Supplier Partner has breached this Supplier Code of Conduct, our practice is to investigate these incidents and work with the Supplier Partner to develop an action plan to address the concern. However, during an investigation, INW may suspend contractual and business operations with the Supplier Partner. If we determine that an issue has not or cannot be corrected to the satisfaction of INW, or a Supplier Partner is unwilling to engage or reasonably cooperate, we INW may terminate its agreement(s) with that Supplier Partner.

This Supplier Code of Conduct sets forth the minimum requirements that must be met to be a INW Supplier Partner. We encourage our Supplier Partners to have due diligence and management systems in place to maintain these minimum requirements and strive to operate by best practices in all areas of the business relationship. By working closely with our Supplier Partners, we believe we can achieve mutual success while helping communities and the wider world thrive.

 

FOR CLARITY AND NOT LIMITATION, THE SUPPLIER IS AN INDEPENDENT CONTRACTOR, AND NO JOINT VENTURE, PARTNERSHIP, AGENCY OR EMPLOYMENT RELATIONSHIP IS CREATED BY THIS CODE. INW RESERVES THE RIGHT TO MODIFY OR AMEND THIS SUPPLIER CODE OF CONDUCT AT ANY TIME.