Code of Conduct

1. Purpose

Bentley Mills is committed to creating a culture of sustainability through its business operations and relationship with suppliers, communities, potentially affected groups, and other relevant stakeholders. We understand that we have a responsibility to prevent and mitigate negative social and environmental impacts in our value chain. Promoting this responsibility in our operations and supply chain through transparency is important.

2. Scope

This code of conduct explains our expectations in the areas of ethical business, labor and human rights, health and safety and environmental sustainability. Bentley Mills expects all associates and suppliers to meet or surpass the minimum standards stated below. In addition, Bentley Mills shall ensure that third parties, including communities, potentially affected groups, and other relevant stakeholders, who maintain relations with Bentley Mills are aware of the commitments established in this policy. Bentley Mills’ suppliers shall ensure that their own suppliers, contractors, and other business partners participating in the delivery of products, components, materials and services to Bentley Mills’ subsidiaries comply with the minimum requirements set out in this Code, and that this Code is communicated to them.

3. Legal Compliance

Bentley Mills expects compliance with all local, state and federal laws and regulations applicable to operations.

4. Code Standards

Human and Labor Rights

This Code of Conduct is guided by the United Nations (UN) ‘Guiding Principles on Business and Human Rights’, the eight core International Labor Organization (ILO) Conventions,  the International Bill of Human Rights, and United States (US) national law. Where US law and UN Guiding Principles differ, the US law shall apply. Bentley Mills sets the following expectations:

  • Support the protection of internationally recognized human rights and prohibit the use of forced, indentured or involuntary labor (including modern slavery and human trafficking) and child labor. Provide adequate protections for workers above the legal working age and below age 18.
  • Create an environment where employees are not exposed to discrimination of any kind, irrespective of their gender, ethnicity, religion, race, or age.
  • Uphold the freedom of association and the effective recognition of the right to collective bargaining.
  • Empower employees and other stakeholders to anonymously report concerns or potential unlawful practices at the workplace without retaliation.
  • Every employee shall be treated with respect and dignity. No employee shall be subject to any physical, sexual, psychological, or verbal harassment or abuse or to monetary fines or embarrassing acts as a disciplinary measure. Harassment and abuse includes any form of – or threat of – physical violence, including slaps, pushes or other forms of physical contact as a means to maintain labor discipline and any form of verbal violence, including screaming, yelling, or the use of threatening, demeaning, or insulting language, as a means to maintain labor discipline.
  • Pay legally mandated minimum wages and benefits, comply with the law regarding wage deductions, and provide workers with the basis on which workers are paid via pay stub or similar documentation. Do not deduct from wages as a disciplinary measure.
  • For workers paid hourly, maximum working hours are 8 hours per day, or 48 hours per week, and overtime is the number of hours worked beyond the maximum allowed by week. Employee working hours must comply with applicable US State and Federal law.

Health and Safety

We believe that every accident at work or occupational illness can be avoided. Bentley Mills will only deliver products which will safeguard the safety and hygiene of the end‐users during their entire life cycle. We expect:

  • A healthy and incident free working environment for all personnel, and to be harmless to neighbors.
  • Ensure that appropriate health and safety information and equipment are provided to employees and contractors.
  • Products or parts do not contain any product, material or substance prohibited by the legislation or regulations. Suppliers may be requested to provide disclosure on the use and provenance of certain substances and materials.
  • To address the European REACH procedures or the applicable national equivalent, such as the American Toxic Substance Control Act (TSCA).
  • Provide workers with access to water, sanitation, and hygiene (WASH). This includes a sufficient number of toilets, adequate hand washing stations, and accessible drinking water.
  • Take all appropriate measures to prevent against exposure to hazardous materials, including the implementation of hazardous materials handling.
  • Ensure that there are systems in place to assess, identify, prevent, and mitigate potential and actual threats to the health and safety of workers.
  • Take all appropriate measures, and obtain all relevant licenses and documentation required by national legislation, to see to the stability and safety of the equipment and buildings they use, as well as to protect against and prepare for any foreseeable emergency.

Environmental Sustainability

  • Bentley Mills wants to minimize the impact on the environment of its operations and products throughout the entire value chain. We expect:
  • Procedures to minimize any adverse impact of operations on the environment and utilization of management systems, to continuously improve performance.
  • Not only consider the environmental impacts of products during the design phase, but also in their production, procurement and after services processes.
  • Focus on reducing the use of raw materials and resources and eliminate the waste produced by all activities.
  • Use resources efficiently, seek to reduce water use and greenhouse gas emissions, and encourage the use of energy‐efficient technologies in production and services.
  • Bentley Mills encourages involvement in local social and environmental community charity efforts by volunteering time and/or providing other types of support.
  • All required environmental permits (e.g. discharge monitoring) and registrations are to be obtained, maintained, and kept current and operational and reporting requirements are to be followed.

Ethical Business Conduct

Our commitment to do business right means acting with integrity with all our stakeholders and being a reliable and responsible partner. We expect:

  • Fair and ethical business practices, including anti-corruption/bribery and zero-tolerance of embezzlement or extortion.
  • Transparency about ethical policies and practices and disclosure of any important information that may be a conflict of interest for Bentley Mills.
  • Implement appropriate systems and controls, which facilitate compliance with the applicable laws, regulations, and standards.
  • Adhere to international trade regulations and export control regulations.
  • Treat all information obtained from Bentley Mills as strictly confidential.
  • Manage the information on and the existence of technology and know‐how in such a manner that Bentley Mills’ intellectual property rights be adequately protected.