Step 1:  Benchmark your Customers’ Codes of Conduct to understand what is included. 

  • Benchmark should include the following:
    • Provisions included in customer Codes
    • Specific terms and conditions included in provisions such as Discrimination terms, minimum age listed in Child Labor
    • Any internal policies such as a Code of Ethics or related policies
  • If you or your customers are a member of an industry initiative (such as the Fair Labor Association, Ethical Trading Initiative, SA8000, WRAP, BSCI or others), the benchmark should also include related Industry Codes.

Step 2:  Based on your benchmark, determine which provisions to include in your Code. 

Your provisions should be more or less aligned with customer provisions.  Examples of provisions (with industry standard provisions in bold):

  • Bribery and Corruption
  • Child Labor
  • Communication
  • Compliance with Laws
  • Contract Labor
  • Customer Requirements
  • Customs and Security
  • Discrimination
  • Environment
  • Forced Labor
  • Freedom of Association
  • Harassment and Abuse
  • Health and Safety
  • Hours of Work
  • Management Systems
  • Monitoring and Compliance
  • No Retaliation
  • Recordkeeping and Transparency
  • Unauthorized Subcontracting
  • Wages and Benefits
  • Women’s Rights

Step 3:  Write your Supplier Code of Conduct.


We have provided sample language to get you started. 

Bribery and Corruption

Factories must demonstrate a high degree of ethical conduct. Any and all forms of bribery are prohibited.

Child Labor

Factories must have hiring practices in place that accurately verify worker’s age and legal right to work in the country prior to employment. Factories must not employ anyone younger than 15 years of old, or younger than the age for completing compulsory education if the age in the country of manufacture is greater than 15.   


Factories must communicate this Code of Conduct and the provisions to workers and supervisors and provide regular training to current and new employees about these requirements.

Compliance with Laws

[Supplier] expects its suppliers to operate in full compliance with applicable labor and environmental laws and regulations of the country of manufacture.  Where Code requirements are stricter than law, compliance with the Code is required.  All legally required licenses, permits and certifications must be current and properly maintained. 

Contract Labor

Factories that employ or recruit foreign workers must take steps to ensure those workers are treated fairly and given equal status to local workers.

Customer Requirements

In addition to [SUPPLIER] Code of Conduct and requirements, factories are subject to the Responsible Sourcing requirements set forth by customers of [SUPPLIER].  Factories are expected to understand and comply with the requirements set forth by [SUPPLIER} and its customers relating to social compliance, including Codes of Conduct and related procedures. 

Customs and Security

Factories must comply with all applicable local, national and international customs laws.  Suppliers shall implement security measures consistent with the recommendations set forth by the Customs-Trade Partnership Against Terrorism (C-TPAT).


[SUPPLIER] factories must not discriminate in employment practices, including hiring, compensation, training, promotion, termination and retirement should on the basis of gender, race, age, religion, disability, sexual orientation, cultural beliefs,  or other similar factors. 


Factories must adhere to applicable local, national and international laws and regulations regarding the protection and preservation of the environment, including those related to waste disposal, emissions, discharges, toxic substances and hazardous waste disposal. 

Forced Labor

All labor must be voluntary.  Factories shall not use any form of forced labor, whether in the form of prison labor, indentured labor, bonded labor or other compulsory labor.  Slavery and human trafficking are prohibited throughout the supply chain.  In addition, Factories shall respect the freedom of movement of its workers, ensure contracts are written in workers’ spoken language, and shall not restrict worker movement by controlling identity papers, holding money deposits, or taking any other action to prevent workers from terminating their employment.

Freedom of Association

Factories must recognize and respect the rights of workers to freedom of association and collective bargaining.  Where such rights are restricted by law, factories should take steps to provide means of open communication with workers. 

Harassment and Abuse

Workers shall be treated with dignity and respect.  Factories shall prohibit physical, sexual, psychological or other forms of mental or physical coercion, harassment, abuse or intimidation. 

Health and Safety

Factories must provide a safe and health working environment for all workers.    Factories should operate in compliance with all applicable legal health and safety requirements including standards for electrical, mechanical, structural and fire safety.  This also applies to residential and dining facilities, where applicable. 

Hours of Work

Factories shall comply with all applicable laws and regulations relating to hours of work.  Except in extraordinary business circumstances, workers shall not be required to work more than 60 hours per week (including overtime) and shall be provided with at least one rest day every week.

Management Systems

Factories are expected to have management systems, policies, procedures, and practices, to ensure compliance with this Code.

Monitoring and Compliance

[SUPPLIER] reserves the right to conduct announced and unannounced inspections at all factories.  Factories must allow [SUPPLEIR] staff and designated third party representatives unimpeded access to production facilities, documents and workers for confidential interviews. 

No Retaliation

[SUPPLIER] will not tolerate any retribution or retaliation taken against any individual who, in good faith, reports unlawful or inappropriate activity related to the Code and/or the audit process. 

Recordkeeping and Transparency

[SUPPLIER] is committed to working with factories who are open and honest.  factories shall maintain complete and accurate records and information so that compliance can be effectively evaluated.  factories must not falsify or understate aspects of their operations to [SUPPLIER], our customers or third party representatives.  Factories must not coach employees on how to answer questions or respond to inquiries by [SUPPLIER], our customers or representatives. 

Unauthorized Subcontracting

Factory must not subcontract any portion of the manufacturing process without prior written approval from [SUPPLIER].  All subcontractors must agree to comply with this Code and factories are responsible for ensuring their subcontractors are in compliance with the Code.

Wages and Benefits

Factories shall pay workers for all work completed shall pay at least the minimum wage required by law or the prevailing industry wage, whichever is higher.  In addition to compensation for regular hours of work, workers shall be compensated for overtime hours at such a premium rate as is legally required or, in those countries where such laws do not exist, at least equal to their regular hourly compensation rate.  The use of monetary fines as a disciplinary practice is not permitted.

Women’s Rights

Factories shall ensure that women workers receive equal treatment in all areas of employment.