Okeanos Group, LLC, and its affiliates (jointly referred to as “Okeanos”), are committed to the highest standards of social and environmental responsibility and ethical conduct. This Code of Conduct (“Code”) applies to Okeanos and to Okeanos’ partners and licensees (including such partner’s or licensee’s subsidiaries, affiliates, and subcontractors) providing goods or services to Okeanos, or for use in or with Okeanos products (“Partner(s)”). Okeanos and its Partners are required to provide safe working conditions, treat workers with dignity and respect, act fairly and ethically, and use environmentally responsible practices wherever they make products or perform services for Okeanos. Okeanos requires its employees and Partners to operate in accordance with this Code and in full compliance with all applicable laws and regulations. This Code goes beyond compliance with applicable laws by drawing upon internationally recognized standards to advance social and environmental responsibility. When differences arise between principles contained in this Code and legal requirements, the stricter standards shall apply in compliance with applicable law.
Okeanos will assess its Partners compliance with this Code. Any violations of this Code may jeopardize the Partner’s business relationship with Okeanos, up to and including termination.
1. LABOR AND HUMAN RIGHTS
Okeanos believes all workers in our supply chain deserve a fair and ethical workplace. Workers must be treated with the utmost dignity and respect, and Okeanos and its Partners shall uphold the highest standards of human rights.
Okeanos and its Partners shall not discriminate against any worker based on age, disability, ethnicity, gender, marital status, national origin, political affiliation, race, religion, sexual orientation, gender identity, union membership, or any other status protected by applicable national or local law, in hiring and other employment practices. Okeanos and its Partners shall not require pregnancy or medical tests, except where required by applicable laws or regulations or prudent for workplace safety and shall not improperly discriminate based on test results.
ANTI-HARASSMENT AND ABUSE
Okeanos and its Partners shall commit to a workplace free of harassment and abuse. Okeanos and its Partners shall not threaten workers with, or subject them to, harsh or inhumane treatment, including but not limited to verbal abuse and harassment, psychological harassment, mental and physical coercion, and sexual harassment.
PREVENTION OF INVOLUNTARY LABOR AND HUMAN TRAFFICKING
Okeanos and its Partners shall ensure that all work is voluntary. Okeanos and its Partners shall not traffic persons or use any form of slave, forced, bonded, indentured, or prison labor. Involuntary labor includes the transportation, harboring, recruitment, transfer, receipt, or employment of persons by means of threat, force, coercion, abduction, fraud, or payments to any person having control over another person for the purpose of exploitation. Okeanos and its Partners (1) shall not withhold workers’ original government-issued identification and travel documents; (2) will ensure that workers’ contracts clearly convey the conditions of employment in a language understood by the workers; and (3) shall not impose unreasonable restrictions on movement within the workplace or upon entering or exiting company-provided facilities. Workers shall not be required to pay employers’ or their agents’ recruitment fees or other similar fees to obtain their employment.
PREVENTION OF UNDERAGE LABOR
Okeanos and its Partners shall prohibit the hiring of individuals under local legal minimum working age or the compulsory schooling age, whichever is higher. Younger workers may be employed through company approved short-term internships, apprenticeships or work experience programs, but they are never permitted to do work that may threaten their health and safety, or hinder their education or vocational orientation and training.
WORKING HOURS, WAGES AND BENEFITS
Okeanos and its Partners shall follow all applicable national wage and hour laws, including minimum wage, overtime and maximum hour rules, and shall provide any benefits required by law and/or contract.
Okeanos and its Partners shall communicate pay structure and pay periods to all workers.
FREEDOM OF ASSOCIATION AND COLLECTIVE BARGAINING
Okeanos and its Partners shall freely allow workers’ lawful rights to associate with others, form, and join (or refrain from joining) organizations of their choice, and bargain collectively, without interference, discrimination, retaliation, or harassment.
Okeanos and its Partners shall ensure that workers have an effective mechanism to report grievances and that facilitates open communication between management and workers.
HEALTH AND SAFETY
Worker health, safety, and well-being is important to Okeanos. Okeanos and its Partners shall provide and maintain a safe work environment and integrate sound health and safety management practices into their business. Workers shall have the right to refuse unsafe work and to report unhealthy working conditions. Okeanos and its Partners shall obtain, keep current, and comply with all required health and safety permits. Okeanos and its Partners will be committed to continually identify, evaluate, manage and remedy occupational health and safety hazards.
Okeanos is committed to protecting the environment and environmental responsibility is at the core of who we are. Okeanos and its Partners shall develop, implement, and maintain environmentally responsible business practices.
ENVIRONMENTAL PERMITS AND REPORTING
Okeanos and its Partners shall obtain, keep current, and comply with all required environmental permits, and shall comply with the reporting requirements of applicable permits and regulations.
Partners shall comply with Okeanos’ Product Specifications for all goods they manufacture for, and provide to, Okeanos.
HAZARDOUS WASTE MANAGEMENT
Okeanos and its Partners shall implement a systematic approach to identify, manage, reduce, and responsibly dispose of or recycle hazardous waste.
NON-HAZARDOUS WASTE MANAGEMENT
Okeanos and its Partners shall implement a systematic approach to identify, manage, reduce, and responsibly dispose of or recycle non-hazardous waste.
Okeanos and its Partners shall implement a systematic approach to identify, control, and reduce wastewater produced by their operations. Okeanos and its Partners shall conduct routine monitoring of the performance of its wastewater treatment systems.
Okeanos and its Partners shall implement a systematic approach to prevent contamination of stormwater runoff and shall prevent illegal discharges and spills from entering storm drains, the public water supply, or public bodies of water.
AIR EMISSIONS MANAGEMENT
Okeanos and its Partners shall identify, manage, reduce, and responsibly control air emissions emanating from their operations that pose a hazard to the environment. Okeanos and its Partners shall regularly quantify, set targets, monitor progress, and reduce its emissions of greenhouse gasses through conservation, use of clean energy, or other measures.
BOUNDARY NOISE MANAGEMENT
Okeanos and its Partners shall identify, control, monitor, and reduce noise generated by the facility that affects boundary noise levels.
RESOURCE CONSUMPTION MANAGEMENT
Okeanos and its Partners shall regularly quantify, set targets, monitor progress, and reduce consumption of fossil fuel, water, hazardous substances, and natural resources through conservation, re-use, recycling, substitution, or other measures.
Okeanos expects the highest standards of ethical conduct in all of its endeavors. Okeanos and its Partners shall always be ethical in every aspect of their business, including relationships, practices, sourcing, and operations.
RESPONSIBLE SOURCING OF MATERIALS
Okeanos and its Partners shall exercise due diligence on relevant materials in their supply chains. Due diligence shall be conducted to the material processing level in order to determine whether relevant materials originate from regions with high risks, which include areas associated with conflict, worst forms of child labor, forced labor and human trafficking, gross human rights violations such as widespread sexual violence, or other reasonably objective high risk activities, including severe health and safety risks and negative environmental impacts.
Okeanos and its Partners shall not engage in corruption, extortion, embezzlement, or bribery to obtain an unfair or improper advantage, and shall abide by all applicable anti-corruption laws and regulations of the countries in which they operate, including the Foreign Corrupt Practices Act (FCPA), the U.K. Bribery Act, and applicable international anti-corruption conventions.
DISCLOSURE OF INFORMATION
Okeanos and its Partners shall accurately record information regarding their business activities, labor, health and safety, and environmental practices and shall disclose such information, without falsification or misrepresentation, to all appropriate parties and as required by law.
PROTECTION OF INTELLECTUAL PROPERTY
Okeanos and its Partners shall respect intellectual property rights and safeguard customer information, and shall manage technology and know-how in a manner that protects intellectual property rights.
WHISTLEBLOWER PROTECTION AND ANONYMOUS COMPLAINTS
Okeanos and its Partners shall provide an anonymous complaint mechanism for managers and workers to report workplace grievances. Okeanos and its Partners shall protect whistleblower confidentiality and prohibit retaliation.
Partners are encouraged to help foster social and economic development and contribute to the sustainability of the communities in which they operate.
To the extent that Partners transports goods for Okeanos into the United States, Partners shall comply with the C-TPAT (Customs-Trade Partnership Against Terrorism) security procedures on the U.S. Customs website at www.cbp.gov (or other website established for such purpose by the U.S. government).
Okeanos Board of Managers
LAST UPDATED: JANUARY 18th, 2019