Human Rights
Freely Chosen Employment
Suppliers shall not use forced, bonded, trafficked, or involuntary labor. Workers must be employed voluntarily and free to leave with reasonable notice. Suppliers shall not require surrender of identity documents as a condition of employment. Recruiting fees charged to workers are prohibited.
Freedom of Movement
Suppliers shall not restrict workers' freedom of movement within or outside the facility, except as needed for documented safety or security reasons applicable equally to all persons.
Child Labor
Suppliers shall not employ workers under the legal minimum working age or under age 15, whichever is greater. Work for persons under 18 must not interfere with schooling, must not be hazardous, and must comply with age-specific restrictions. Age verification records must be maintained for all workers.
Wages and Benefits
Suppliers shall pay at least the legally mandated minimum wage and provide all legally required benefits. Wages shall be paid in full, on time, and documented clearly. Wage deductions as discipline are prohibited.
Humane Treatment
Suppliers shall not subject workers to corporal punishment, coercion, verbal abuse, sexual harassment, or any form of abuse or intimidation. Effective grievance mechanisms protecting workers from retaliation must be maintained.
Ethical Recruitment
Suppliers shall use only ethical recruitment practices. The employer bears all recruitment costs. No deception regarding job conditions, wages, or location is permitted.
Non-Discrimination
Suppliers shall maintain a workplace free from discrimination based on race, color, national origin, gender, sexual orientation, age, religion, disability, pregnancy, political affiliation, union membership, or any other protected characteristic. Hiring, compensation, and promotion decisions shall be based solely on job-relevant qualifications.
Freedom of Association
Suppliers shall respect workers' rights to form, join, or not join labor organizations and engage in collective bargaining as permitted by local law. Suppliers shall not retaliate against workers exercising these rights.
Protection of Vulnerable Groups
Suppliers shall provide appropriate protections for pregnant workers, nursing mothers, workers with disabilities, migrant workers, and persons under 18.
Human Rights Defenders
Suppliers shall not retaliate against, intimidate, or harm individuals acting as human rights defenders in connection with business activities near supplier operations.
Diversity, Equity & Inclusion
Suppliers shall promote a work environment that is inclusive and respectful of all workers. Suppliers are encouraged to actively pursue diversity in hiring and management, close compensation gaps, and ensure equitable access to training, advancement, and leadership opportunities.
Health & Safety
Occupational Safety
Suppliers shall provide a safe work environment that prevents injuries and work-related illnesses. Hazards shall be identified, evaluated, and controlled. Workers shall receive adequate PPE at no cost and may refuse unsafe work without retaliation.
Emergency Preparedness
Written emergency response plans including evacuation procedures, fire safety, and chemical incident response shall be maintained. Emergency exits shall be clearly marked, unlocked during work hours, and unobstructed.
Machine Safeguarding
All machinery posing injury risk shall have appropriate guards and lockout/tagout procedures. Guards shall not be bypassed. Operators shall be specifically trained and authorized.
Sanitation and Facilities
Suppliers shall provide clean restrooms, potable water, and sanitary conditions. Dormitory facilities, where provided, shall meet applicable housing standards.
Worker Safety Training
Safety training shall be provided to all workers upon hire and ongoing in a language they understand, addressing hazards specific to each role.
Environment
Pollution Prevention
Suppliers shall minimize or eliminate emissions, discharges, and waste generation. Greenhouse gas emissions (Scope 1, 2, and 3) shall be tracked, disclosed upon request, and suppliers shall establish science-based emission reduction targets.
Other Air Emissions
Suppliers shall follow applicable air pollution control laws and manage ozone-depleting substances in accordance with the Montreal Protocol.
Hazardous Substances
Suppliers shall identify, label, store, and manage chemicals and hazardous materials safely and in compliance with applicable laws.
Materials Restrictions
Suppliers shall adhere to all applicable laws and WCC requirements regarding restricted substances. See Restricted Substances Declaration (COM-007) for specific regulatory frameworks.
Water Management
Suppliers shall implement a water management program monitoring sources, use, and discharge; treating wastewater as required; and preventing unpermitted discharges.
Animal Welfare
Suppliers shall respect the five freedoms for animal welfare (OIE). WCC does not conduct or commission animal testing. Suppliers shall not supply materials that involved testing on animals.
Continuous Improvement
Suppliers shall reduce carbon footprint, energy, water, material use, and waste. Set sustainability goals, track results, and report progress.
Responsible Sourcing
Land Rights
Suppliers shall respect the land rights of individuals, indigenous peoples, and local communities in accordance with local laws, ILO Convention No. 169, and the UN Declaration on the Rights of Indigenous People. Suppliers shall protect ecosystems and avoid illegal deforestation.
Conflict Minerals
Suppliers shall implement a responsible minerals sourcing policy consistent with WCC's Conflict Minerals Policy (COM-005) and conduct OECD due diligence for 3TG minerals. Annual disclosure via CMRT (COM-006) is required for applicable suppliers.
Business Integrity
Anti-Corruption and Anti-Bribery
Suppliers shall not tolerate corruption, bribery, money laundering, embezzlement, extortion, or fraud in any form — including giving or receiving gifts or incentives to influence government officials or business dealings.
Disclosure of Information
Suppliers shall accurately disclose labor, health and safety, environmental, and business information in accordance with applicable regulations. Falsification of records is unacceptable.
Intellectual Property
Suppliers shall respect intellectual property rights and safeguard all customer and supplier information.
Counterfeit Parts
Suppliers shall never use counterfeit components in products supplied to WCC.
Privacy
Suppliers shall comply with privacy and information security laws when collecting, storing, processing, or transmitting personal information.
Export Controls and Economic Sanctions
Suppliers shall comply with all applicable export restrictions and economic sanctions, conducting appropriate due diligence on third parties.
Grievance Mechanisms and Non-Retaliation
Suppliers shall provide a confidential grievance mechanism in local languages for workers to report concerns without fear of reprisal. Whistleblower confidentiality shall be protected.
Reporting Concerns to WCC
Suppliers shall promptly inform WCC of any concern related to issues governed by this Code. Contact your WCC Global Sourcing representative directly.
Management Systems
Suppliers shall implement an internal management system to comply with applicable law and this Code, and shall demonstrate compliance upon WCC's request.
Leadership Commitment
Senior executives shall be identified and responsible for management system implementation, with regular senior management review.
Risk Assessment and Management
Processes shall be maintained to identify and control compliance, environmental, health & safety, and labor practice risks throughout operations and supply chains.
Training
New-hire and ongoing training shall cover policies, procedures, improvement objectives, and applicable legal requirements.
Communication and Documentation
Clear, accurate information about policies and practices shall be communicated to workers, suppliers, and customers. Records shall meet regulatory and confidentiality requirements.
Supplier Responsibility
Suppliers shall communicate these Code requirements through their own supply chains and require their sub-suppliers to adopt materially consistent practices.