Global Supplier Code of Conduct
McCormick & Company, Incorporated (McCormick) conducts its business in compliance with applicable law, and in an ethical and socially responsible manner. McCormick has a culture based on fundamental values of integrity, fairness, mutual respect, teamwork, and innovation. McCormick has developed a Global Supplier Code of Conduct (Code) to clarify our global expectations in the areas of business integrity, human rights, health and safety and environmental management.
McCormick’s Supplier Code of Conduct applies to all Suppliers, Vendors, Contractors, Consultants, Agents and other providers of goods and services who wish to conduct business with McCormick entities worldwide. We expect all our suppliers to engage in responsible supply chain practices as they relate to the areas listed above. McCormick will conduct, or has conducted on its behalf, audits of production facilities and business practices to monitor Suppliers’ commitment to the Code. McCormick also reserves the right to terminate the relationship with any Supplier and/or Facility that does not comply with this Code of Conduct.
McCormick’s Purchase Orders Terms and Conditions include language that references Supplier’s expectation of adherence to McCormick’s Supplier Code of Conduct.
This Supplier Code of Conduct may be amended by McCormick from time to time; its enforcement and/or interpretation rests solely with McCormick and does not confer or create any rights in favor of any party other than McCormick.
Section 1. Business Conduct Standards
McCormick expects its suppliers to maintain awareness of and comply with all applicable laws and regulations of the countries where they conduct business; to conduct business responsibly, with integrity, honesty, and transparency; and to adhere to the following standards as they apply to the following employment practices:
Child labor is strictly prohibited. Suppliers shall adhere to the minimum employment legal age limit defined by national law or regulation, and comply with relevant International Labor Organization (ILO) standards. In no instance shall a supplier permit children to perform work that exposes them to undue physical risks than can cause physical, mental or emotional harm or improperly interfere with their schooling (except as may be permitted under apprenticeship or similar programs in which the minor is lawfully participating).
Forced Labor, Slave Labor, Human Trafficking
Supplier confirms that, in providing goods and services to McCormick, it has not used involuntary or forced labor, whether indentured, bonded, prison or otherwise, and that the Supplier has not confiscated or withheld worker identity documents or other valuable items, including passports, work permits and travel documentation. Supplier certifies that it has not been, and is not, keeping workers’ personal documents as a means to bind them to employment or to restrict their freedom of movement. Supplier further confirms and certifies that:
- All workers are voluntarily employed in the facility(ies) where McCormick’s goods are made.
- No prisoners (convicts) are working at the facility(ies) where McCormick’s goods are made.
- No workers of North Korean citizenship were employed to make McCormick’s goods for delivery.
- No materials were sourced by Supplier for McCormick’s goods for delivery from vendors that employ workers of North Korean citizenship.
Vendors employees will work in compliance with all applicable laws pertaining to the number of hours and days worked. Employees will be provided with reasonable daily and weekly work schedules, and adequate allowance will be made for time off.
Employees will be fairly compensated and provided with wages and benefits that comply with applicable laws, including appropriate compensation for overtime work and other premium pay situations required by applicable law.
Discrimination in hiring and employment practices based on race, color, religion, gender, age, national, social or ethnic origin, maternity, sexual orientation, political opinion, disability, or any other status or personal characteristic shall not be allowed Employee medical tests that can be used to discriminate in hiring or employment practices shall not be required.
Vendor shall provide employees with safe and healthy working conditions. At a minimum, potable drinking water, clean restrooms, adequate ventilation, fire exits and essential safety equipment, an emergency aid kit, access to emergency medical care and appropriately lit work stations are provided. The Vendor’s facilities are to be constructed and maintained in accordance with applicable law.
Respect for the Environment
Vendor will conduct its business in a manner compatible with the environment and in accordance with applicable law. Reasonable standards of care shall be taken to protect the environment and to provide for the health and safety of employees and the communities in which facilities are operated. Vendor will take prudent steps to minimize solid waste by reducing, reusing and recycling materials; encourage conservation of resources and energy; provide training and education for its employees, as appropriate; and support efforts to establish and implement policies that also protect the environment.
Section 2. Business Practices
Purchases of materials and services will only be made from suppliers who continually meet McCormick’s specifications on manufacturing practices, distribution methods, product quality, delivery dates, and price objectives. This Code of Conduct is not in lieu of, but is in addition to, the Vendor’s obligations to McCormick as set forth in any written agreement between McCormick and the Vendor. Should there be a conflict between this Code of Conduct and the agreement in question, the agreement shall control; however, no such agreement may reduce or eliminate the Vendor’s obligations as set forth in Section 1 above.
All products offered for sale to McCormick shall comply with McCormick’s specifications and all applicable laws of the country and political subdivisions in which they are to be offered for sale. Origin mapping – Suppliers must be capable of disclosing potential sources of primary origin associated with the products or services provided to McCormick. McCormick reserves the right to ask its Suppliers for supply chain mapping back to the origin to facilitate an assessment of upstream supply chain compliance. If Suppliers do not have this capability today, McCormick expects Suppliers to share with McCormick their future plans in this regard.
McCormick may conduct audits and inspections of Vendors facilities, records and employees to confirm compliance with this document. Unsatisfactory audit results may result in McCormick terminating its relationship with the Vendor, without further liability of McCormick to the Vendor.
Vendor is responsible for ensuring compliance with this Code of Conduct by all of its suppliers that provide materials or services in the manufacture, processing and/or production of products provided by Vendor to McCormick. McCormick may conduct such audits and inspections of Vendor’s records in respect of its suppliers. McCormick expects Suppliers to apply similar standards to their own suppliers and subcontractors by communicating the expectations contained in this Code of Conduct and holding them accountable as well. This includes contract and seasonal workers and temporary agencies.
McCormick seeks to contribute to the economic growth of a diverse business community. Our Supplier Diversity Program (SDP) enables us to develop relationships with qualified, diverse businesses that meet our high standards for quality and cost effectiveness. Suppliers are encouraged to support McCormick’s Diversity efforts by utilizing qualified diverse-owned businesses in support of the business that it conducts with McCormick.
Section 3. Business Integrity and Ethics
Gifts, Bribes and Kickbacks
McCormick is committed to conducting business legally and ethically and will not tolerate corruption in any form. Corrupt arrangements with customers, suppliers, government officials, McCormick employees or other third parties are strictly prohibited. “Corruption” generally refers to obtaining, or attempting to obtain, a personal benefit or business advantage through improper or illegal means. Suppliers must operate with the highest standards for business integrity and comply with all anti-corruption and antibribery laws, including the U.S. Foreign Corrupt Practices Act (FCPA). Suppliers are prohibited from providing or offering gifts to McCormick employees that could inappropriately influence McCormick’s decisions or gain an unfair advantage.
McCormick is committed to uncompromising integrity in all that it does. While standards of conduct are mainly based on laws, they also reflect the values that define McCormick. For a complete statement of these values, see McCormick’s Business Ethics Policy on its Investor Relations website at ir.mccormick.com under “Corporate Governance,” then “Business Ethics Policy.”
McCormick’s business information is a valuable corporate asset. Vendor and its employees and directors have an obligation to safeguard confidential information about McCormick and to protect it against unauthorized disclosure. This obligation is not limited to the duration of McCormicks relationship with the Vendor, or the duration of employment or service of the Vendors employees with the Vendor.
Section 4: Confirmation
Vendor acknowledges that it has reviewed and understands this statement with respect to McCormick’s business practices and ethical business conduct and agrees to comply with the same. Vendor also agrees that it understands the rules and principles of the FCPA and shall comply with the FCPA and any other anti-corruption laws and regulations in all jurisdictions where its business or services will be conducted or performed for McCormick.
Vendor agrees that any information provided to McCormick will be complete and true and that it will promptly notify McCormick if an owner, partner, officer, director or employee of Vendor has been or will become a “Covered Person” (defined below), or a family member of a Covered Person.
“Covered Person” Defined: A “Covered Person” includes any current or former foreign official, foreign political party or party official, or foreign candidate for political office. A “foreign official” is (i) any officer or employee of a foreign government or any department, agency or instrumentality of a foreign government, (ii) an officer or employee of a public international organization such as the United Nations or the World Bank, (iii) an individual acting in an official capacity for or on behalf of a government agency, department or instrumentality, or of a public international organization, (iv) any officer or employee of a company owned or controlled by a foreign government or (v) a member of a royal family who may lack formal authority but who may otherwise be influential, including by owning or managing state-owned or controlled companies. The definition of “foreign official” includes former foreign officials in cases where the former official has formally left the office but retains influence and the ability to affect procurement decisions or other decisions that might affect McCormick’s business.
Vendor will not directly or indirectly give, pay, offer or promise to pay, or authorize the giving, paying, offering or promising of anything of value, directly or indirectly, to any Covered Person while knowing that the payment or promise to pay will be or is likely to influence any act or decision by such Covered Person for the purpose of obtaining, retaining or directing business to another person or entity, or otherwise to obtain an improper business advantage. Vendor will not take any action that may cause McCormick to be in breach of the FCPA or any other anti-corruption laws in any jurisdiction where business or services will be conducted or performed for McCormick.
Vendor shall conduct periodic self-evaluations to ensure that it, as well as its suppliers, are complying with McCormick’s policies with respect to ethical business conduct, including McCormick’s policies relating to the FCPA and any other anti-corruption laws and regulations in all jurisdictions where business or services will be conducted or performed pursuant to this Agreement.
Last Modified: January 24, 2018