Last Modified: June 4, 2025
1 Purpose and Scope
The Supplier Code of Conduct (“Code”) sets standards of ethical conduct which Eastlink requires from manufacturers, distributors, vendors, service providers, and other suppliers that supply products or services to Eastlink (collectively, “Suppliers”) when doing business with or on behalf of Eastlink. This Code is designed to promote safe and fair working conditions and the responsible management of social, ethical, and environmental risks within Eastlink’s supply chain.
Corporate integrity, responsible product sourcing, and the safety and well-being of workers across the global supply chain are of paramount importance to Eastlink. As such, Eastlink requires its Suppliers to adhere to this Code and expects Suppliers to implement these requirements in a manner that is appropriate and proportional to the nature and scale of their activities, the goods that they supply, and the services that they provide. The standards set out in this Code are expected to apply throughout Suppliers’ product supply chain, which includes Supplier’s facilities (including manufacturing, distribution, and packaging facilities) and Suppliers’ agents and subcontractors.
While Eastlink recognizes that its Suppliers operate in different legal and cultural environments, the standards set forth in this Code operate as a benchmark for acceptable conduct. Where applicable local laws impose less restrictive obligations on a Supplier, the Supplier is expected to adhere to the standards of this Code. Where applicable local laws impose greater obligations on a Supplier, the Supplier must comply with such laws and regulations.
2 Recognized Standards
Eastlink follows best practices, and the expectations and principles in the Code are derived from key international human rights standards including the International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work and the United Nations Universal Declaration of Human Rights.
3 Labour Practice and Standards
Suppliers must abide by applicable employment standards, labour, non-discrimination, and human rights legislation. Where laws do not prohibit discrimination, or where they allow for differential treatment, we expect Suppliers to be committed to non-discrimination principles and not to operate in a way that unfairly differentiates between individuals.
Eastlink is committed to upholding human rights and to promoting the standards set out in our Human Rights Statement. We expect our Suppliers to share this commitment, which includes Suppliers operating in accordance with the following principles:
3.1 Freely Chosen Employment
Suppliers must ensure all labour is voluntary, allowing workers to leave or terminate employment freely and without the requirement to pay any fees. Forced or bonded labour, indentured labour, involuntary prison labour, slavery, or trafficking are strictly prohibited.
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Actions like transporting, recruiting, or receiving individuals through threat, force, coercion, or fraud for exploitation are also strictly forbidden.
3.2 Child Labour Avoidance
Child labour is strictly prohibited. Suppliers must not engage in child labour, with the minimum age for employment at 15 years or the age for completing compulsory education, whichever is greater.
3.3 Working Hours
Suppliers must adhere to local laws regarding working hours, ensuring workweeks don't exceed the legal limit. In the absence of applicable laws, Suppliers are expected to limit work to sixty (60) hours per week, including overtime, with a mandatory day off every seven (7) days, except in emergencies.
3.4 Wages and Benefits
Suppliers must compensate all workers with wages, including overtime pay, and benefits that at a minimum meet the highest of: (1) applicable wage laws, including minimum wages, overtime, and mandated benefits, (2) collective agreements, and (3) industry benchmark standards. Suppliers must make wage payments and provide benefits on a timely basis. Disciplinary deductions from wages are prohibited. Workers are entitled to timely, understandable wage statements for accurate compensation verification. Temporary, dispatch, and outsourced labor must align with local law limits.
3.5 Humane Treatment
Suppliers must ensure a workplace free from harsh and inhumane treatment, explicitly prohibiting sexual harassment, abuse, corporal punishment, coercion, or verbal abuse. Suppliers must not condone or tolerate such behaviors. Clear disciplinary policies aligned with applicable law must be communicated to workers, and Suppliers must promote a work environment that treats workers with respect and dignity.
3.6 Non-Discrimination
Suppliers must not discriminate against employees based on various criteria, including race, colour, gender, language, religion, political opinion, origin, pregnancy, marital status, sexual orientation, and disability. Suppliers must foster equal opportunities and fair treatment in hiring, task assignments, work conditions, pay, career development, retirement, and employment practices. Suppliers are encouraged to establish formal non-discrimination policies, communicate them to employees, and institute confidential grievance mechanisms.
3.7 Freedom of Association and Collective Bargaining
Suppliers must respect workers’ rights to freely associate, join labour unions, seek representation, and participate in workers’ councils in adherence to local laws. Open communication between workers and management is crucial for resolving workplace issues, and Suppliers must ensure that workers can express ideas and concerns without fear of discrimination, reprisals, intimidation, or harassment.
3.8 Occupational Health and Safety
Suppliers must prioritize occupational health and safety, by providing a safe and healthy, work environment for their employees and taking reasonable steps to protect the safety and health of their customers and the community. Suppliers must implement and maintain a proactive safety management system, whereby all efforts are made to identify and mitigate hazards that could result in a workplace incident or injury. The safety management system should include an effective safety training program and protocols for preventative maintenance of tools and equipment.
4 Environmental Protection
Recognizing the integral role of environmental responsibility in producing high-quality products, Eastlink is committed to minimizing adverse effects on communities, the environment, and natural resources while prioritizing public health and safety. The adoption of practices aimed at reducing pollution and the development of eco-efficient or energy-efficient products are encouraged, while compliance with environmental laws and regulations is required. Demonstrating proactive measures, Suppliers must operate in accordance with the following principles:
4.1 Permits and Compliance
Suppliers must obtain and maintain all necessary environmental permits required for the conduct of their business activities, such as discharge monitoring or chemical-related approvals, and must comply with operational and reporting requirements associated with such permits.
4.2 Resource Use and Pollution
Suppliers are expected to work towards minimizing resource consumption and mitigating adverse environmental impacts arising from their business activities, encompassing biodiversity, ecosystems, and habitats. Suppliers must take reasonable efforts to minimize or eliminate emissions, pollutant discharges, and waste generation at the source. Efforts should also be made to minimize the consumption of natural resources, including water, fossil fuels, minerals, and forest products, where possible.
4.3 Hazardous Substances
Suppliers must identify, label, and manage hazardous substances in compliance with local laws, ensuring their safe handling, movement, storage, use, recycling, or disposal. Suppliers are encouraged to minimize the use of hazardous substances, and if necessary, ensure proper identification, safe management, use, and disposal of such substances.
4.4 Air Pollutants, Energy Consumption and Greenhouse Gas Emissions
Air emissions, encompassing volatile organic chemicals, aerosols, corrosives, particulates, ozone-depleting chemicals, and combustion by-products from operations, must be characterized, routinely monitored, controlled, and treated as necessary before discharge, adhering to local laws. Additionally, Suppliers are encouraged to implement measures for reducing energy consumption and Greenhouse Gas (GHG) emissions in their operations, products, and services.
5 Business Integrity
Eastlink maintains the highest level of honesty and ethical behavior in its operations. This applies to interactions with employees, customers, suppliers, and the communities in which Eastlink operates. It is strictly forbidden to engage in any form of corruption, extortion, or embezzlement, and those found guilty of such actions may face legal consequences and risk termination.
Suppliers must comply with all relevant laws and are encouraged to follow international or industry standards that promote the highest ethical practices. Suppliers are expected to demonstrate a high level of ethical and responsible behavior by operating in accordance with the following principles:
5.1 Improper Advantage
Suppliers must not gain unfair advantages or engage in conflicts of interest when dealing with Eastlink’s employees. This includes a prohibition on offering or requesting gifts, rewards, entertainment, or benefits that could compromise the integrity of Eastlink’s employees or its business. This applies to any direct or indirect exchange of value aimed at obtaining or retaining business or gaining an unfair advantage.
5.2 Intellectual Property
Suppliers must uphold the integrity of intellectual property rights, ensuring that the transfer of technology and know-how is conducted in a manner that safeguards these rights. Suppliers must handle confidential information and trade secrets appropriately and in accordance with local laws and contractual requirements.
5.3 Privacy & Information Security
Suppliers must respect and protect the privacy of our customers and employees in accordance with applicable local and Canadian privacy laws, as well as their contractual obligations to Eastlink. Suppliers must process personal data respectfully, guarding against bias, discrimination, and unjust impacts. Suppliers must follow industry standard information security processes, as well as the security requirements outlined in their contract with Eastlink. Eastlink reserves the right to assess Suppliers’ information security practices and procedures. Suppliers must promptly notify Eastlink of any actual or suspected privacy breaches or information security incidents and assist Eastlink in managing the consequences.
5.4 Supplier Diversity
Eastlink values and encourages diversity not only within our workforce but also throughout its entire supply chain. Suppliers are expected to actively promote, identify, and integrate diversity within their own supplier networks. Through these efforts, Eastlink aims to foster economic development for culturally diverse organizations and create a more inclusive business environment.
5.5 Responsible Sourcing of Minerals
Eastlink is committed to responsible sourcing practices and expects Suppliers to adhere to the same principles. Suppliers are encouraged to conduct thorough evaluations of the origin or source of their materials to ensure they are not derived from conflict zones or areas associated with human rights abuses. Specifically, suppliers of electronic or electric equipment/products should pay attention to metals such as gold, columbite-tantalite (coltan), tantalum, tin, and tungsten, which may be sourced from the Democratic Republic of Congo and neighboring countries. Suppliers are encouraged to establish due diligence processes to prevent the use of conflict minerals in their products and disclose the results of their assessments upon request.
5.6 Community Engagement
Eastlink believes in the power of community engagement to drive social and economic development. Suppliers are encouraged to actively participate in and invest in the communities where they operate, live, and serve. By engaging meaningfully with these communities, Suppliers can contribute to their growth and well-being, fostering positive social and economic outcomes.
6 Work Performed on Behalf of Eastlink
Suppliers working on behalf of Eastlink must conduct themselves with courtesy and integrity in all their interactions, whether with Eastlink’s employees, customers, representatives, or other relevant third parties. Suppliers must adhere to applicable Environment, Health and Safety standards and comply with all relevant laws and regulations in the locations where their work is performed.
7 Monitoring and Reporting Violations
Eastlink maintains the right to evaluate and monitor Suppliers’ adherence to this Code of Conduct. Suppliers may be asked to complete self-assessment questionnaires. On-site audits, conducted by Eastlink or its designated third party, may be carried out at supplier facilities to review records, policies, work practices, and ensure compliance with the Code. In case of non-compliance, Suppliers are expected to take appropriate actions to rectify the situation and meet Eastlink's standards promptly.
We urge anyone who has knowledge of a Supplier engaging in illegal, unethical, or otherwise improper conduct, or any activity that violates this Code, to report such behavior. Incidents related to human rights violations, human trafficking, forced labor, retaliation, or other ethical concerns can be reported by all Eastlink stakeholders to our legal department at [email protected].
