Cooper’s other policies and standards referenced in policies above.
(collectively the “Cooper Policies”)
Due Diligence and Risk Assessment
As part of our initiative to identify, assess and mitigate risks:
i. Cooper uses a risk-based assessment process for evaluating, verifying and
selecting direct suppliers.
ii. Cooper expects all of its suppliers to abide by all applicable laws and
regulations and maintain the highest ethical standards.
Supplier Agreements, Supplier Code of Conduct
In its supply agreements, contracts, purchase orders and other arrangements (collectively
the “Supplier Agreements”) with its direct suppliers, Cooper includes provisions
requiring such direct suppliers to comply with applicable laws and regulations, including
as relates to the products or materials being supplied. Furthermore, Supplier Code of
Conduct mandates that Suppliers shall not participate in human trafficking; use any
indentured or forced labour, slavery or servitude or purchase materials or services from
companies using forced, involuntary or slave labour.
Measuring Effectiveness
We monitor any instances of non-compliance with the provisions in the Supplier
Agreements and the Cooper Policies to measure how effective we have been in ensuring
that slavery and human trafficking is not taking place in any part of our business or supply
chains. We would tailor appropriate remedial action on a case-by-case basis should there
be any instances of non-compliance.
Training and Accountability
Cooper provides compliance training to its employees from time to time and as necessary.
Cooper has adopted and implemented its Ethics and Business Conduct Policy worldwide
across all divisions, subsidiaries and affiliated companies and is to be followed by all
employees. Employees who commit a material violation of the Ethics and Business
Conduct Policy may face disciplinary action, up to and including termination of
employment. Materiality of a violation shall be determined on a case-by-case basis by the
Governance Committee and shall be based on the Committee's business judgment in its sole
discretion. All employees certify on an annual basis that they have received, read, and been
trained on the Ethics and Business Conduct Policy.
Cooper continues to assess and evaluate its supply chain's responsible sourcing practices.
We strive to enforce best practices in our supply chain and within the entirety of our
organization.
