Supplier Code of Conduct

Supplier Code of Conduct 1

PECO Pallet’s (“PECO”) core values of Safety, Integrity, Trust, and Excellence guide all aspects of our work. This commitment requires observance of the spirit and letter of all applicable laws, as well as the rigor of holding ourselves and our business partners accountable. Consistent with these values and as a committed partner in the supply chain, PECO’s Supplier Code of Conduct ("Supplier Code" or “Code”) sets forth PECO’s requirements of its suppliers and business partners in the areas of business integrity, human rights, health and safety, and the environment. The requirements set forth herein draw upon international standards, best practices, and applicable PECO policies, and are designed to provide PECO Suppliers with a clear understanding of how they can meet PECO’s standards and conduct their business activities ethically and in compliance with the law.

All suppliers of PECO Pallet, Inc. must comply with this Code . PECO's suppliers include all entities that provide goods and services to PECO regardless of where the service is being performed.


This Supplier Code sets standards of ethical conduct that PECO requires from Suppliers when doing business with or on behalf of PECO. PECO requires its Suppliers to adhere to this Supplier 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

While PECO recognizes that its Suppliers operate in different legal and cultural environments, the standards set forth in this Supplier 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 Supplier Code. Where applicable local laws impose greater obligations on a Supplier, the Supplier must comply with such laws and regulations.

PECO Suppliers should strive for continuous improvement in performance and regularly review and update performance programs and practices in a manner that ensures ongoing compliance with law and industry standards.



PECO Suppliers must comply with all applicable laws and regulations and conduct business responsibly and with integrity.


PECO Suppliers must not engage, directly or indirectly, in corruption, fraud, bribery, kickbacks, money laundering, embezzlement, extortion or any other form of corruption, to improperly influence any action or decision. PECO Suppliers must maintain accurate financial records and reports as required by applicable laws and regulations. PECO Suppliers must comply with all applicable laws and regulations preventing corruption and fraud and ensure that any third party they engage also agrees to abide by such standards.

Confidentiality and Data Protection

PECO's business information is a valuable corporate asset. PECO Suppliers must safeguard and not improperly disclose any confidential, sensitive, and non-publicly available business information pertaining to PECO, including but not limited to financial information, intellectual property, and information relating to its employees, customers, and suppliers.

PECO Suppliers must adhere to applicable information security, data protection and privacy laws, and regulatory requirements when personal information is collected, stored, processed, transmitted, and deleted. Suppliers must account for the need to protect the confidentiality, integrity, and accessibility of information.

PECO Suppliers must comply with any contractual or other requirements regarding information security and data protection and destruction. This obligation to safeguard confidential and/or proprietary information continues even after an engagement has ended.

Conflicts of Interest

PECO Suppliers must avoid any situation that may involve a conflict or the appearance of a conflict between their personal interests and the interests of PECO. As such, PECO Suppliers must not offer or provide excessive hospitality, entertainment, or more than nominal gifts to any PECO employee or their families to obtain or retain business or to influence a decision.

Trade Compliance

PECO Suppliers must comply with all applicable trade compliance laws, including laws that control the import, export and re-export of PECO property, and laws that restrict dealings with sanctioned entities or individuals or in countries subject to trade embargoes or economic sanctions.

Fair Competition

PECO Suppliers must comply with all competition and antitrust laws and must not participate in activities that have the effect of reducing or destroying competition, such as agreeing with competitors to charge certain prices to customers (price fixing), coordinating with competitors during the competitive bidding process (bid rigging), dividing up markets by region, product, or customer (market allocation), or otherwise unfairly excluding or foreclosing competitors from the marketplace.

Honest and Accurate Dealings

PECO Suppliers must not make any false representations in connection with any PECO transaction including, but not limited to, oral misrepresentations of fact or the promotion or utilization of false documentation such as non-genuine, fraudulent, or forged contracts or other inaccurate records. All business dealings should be transparent and accurately reflected on the Supplier’s business books and records.


PECO Suppliers must uphold the human rights of all workers, whether temporary, contract, student, or direct employee. All workers must be treated with dignity and respect. PECO suppliers must, prior to employing any worker, review all relevant documentation to ensure that such a worker has the legal right to work in that jurisdiction.

Child Labor

Child labor is strictly prohibited. PECO Suppliers must adhere to the minimum employment legal age limit defined by applicable laws or regulations. In no instance will Suppliers permit children under the local legal age for completing compulsory education, perform work that exposes them to undue physical risks that can cause physical, mental, or emotional harm or improperly interfere with their schooling, except as may be permitted under apprenticeship or similar workplace learning programs in which the minor is lawfully participating. PECO encourages Supplier to follow the International Labor Organization’s (ILO) definitions on the minimum age for employment (15 years of age) and hazardous work (18 years of age).

Forced or Involuntary Labor, Human Trafficking

Any and all forms of forced or involuntary labor, human trafficking, or modern slavery are unacceptable, and have no role anywhere in PECO’s business. PECO Suppliers must not permit any form of forced or involuntary labor and human trafficking from occurring within its business and supply chain.

Diversity and Inclusion

Diversity, Inclusivity and Equity are important principles at PECO and Suppliers should promote an inclusive work environment that celebrates the diversity of its employee base. PECO Suppliers must be committed to a workplace free of harassment and unlawful discrimination and must take appropriate steps to identify, prevent and mitigate any form of discrimination. Suppliers must not discriminate on the basis of race, color, religion, gender, gender identity or expression, sexual orientation, age, national social or ethnic origin, maternity, disability, marital or family status, military status, criminal history status, or any other protected category in accordance with applicable federal, state, and local laws. PECO Suppliers must not engage in physical, mental, verbal, sexual or any other abuse, inhumane or degrading treatment, corporal punishment, or any form of harassment.

Working Hours and Compensation

PECO Suppliers must recognize the challenge of managing a work-life balance. Suppliers must abide by all local laws and mandatory standards and must respect any applicable collective bargaining agreements regarding work hours. PECO encourages Supplier to follow the ILO’s guidance for standard work hours of 48 hours per week and a maximum of 8 hours per day, while also providing overtime, a rest period of at least 24 consecutive hours every 7 days, and paid leave.

PECO Suppliers must fairly compensate their employees and provide wages and any benefits in compliance with all applicable wage and hour requirements. If there is no local legal minimum wage, wages should be comparable to those of similar local companies and in conformity with international standards.

Freedom of Association and Right to Collective Bargaining

PECO Suppliers must respect the right of all workers to join or refrain from joining worker organizations, including trade unions. Workers and/or their representatives must be able to openly communicate and share ideas and concerns with management regarding working conditions and management practices without fear of discrimination, reprisal, intimidation, or harassment.

Health and Safety

PECO is committed to the health and safety of its workers. PECO requires a safe and hygienic work environment for all its workers and expects its Suppliers to provide the same. PECO Suppliers should ensure that actual and potential risks to worker health and safety are identified, assessed, and eliminated, or managed to mitigate their impacts and ensure preparedness. Supplier must implement appropriate safety procedures and preventative maintenance, deploying training, and providing Personal Protective Equipment (“PPE”), as required.


PECO’s business of pallet pooling is built on the foundation of environmental sustainability. We reuse, repair, and recycle pallets to reduce the waste and inefficiency associated with single-use pallets. Supplier shall recognize that protecting the environment is fundamental to protecting and respecting human rights.

Respect for the Environment

PECO Suppliers must conduct their operations in ways that are environmentally responsible and in compliance with all applicable environmental laws and regulations. Reasonable standards of care must be taken to protect the environment and to provide for the health and safety of the communities in which business operations are conducted. PECO Suppliers must take prudent steps to minimize waste by reducing, reusing, and recycling materials, encouraging conservation of resources and energy, and providing training and education for its employees, as appropriate. Supplier should maintain appropriate documentary evidence of its efforts and provide it upon request.

No Deforestation and No Peat Development

Supplier shall take appropriate steps to ensure their actions do not have any significant negative impact on forests and other protected territories. Additionally, Supplier shall not expand into High Carbon Stock (HCS) forests, High Conservation Value (HCV) areas, or legally protected areas. When establishing new operations or expanding existing ones, Supplier shall obtain all required legal approvals and permissions.

Air Quality and Carbon Footprint

Supplier shall take appropriate steps to minimize air emissions and impact on air quality and implement practices to assess and reduce their carbon footprint.

Water Management and Conservation

Supplier shall take appropriate steps to minimize its impact on water by reducing their consumption and ensuring groundwater quality is maintained or improved, as much as possible.

Soil Quality

Supplier shall take appropriate steps to preserve soil quality and minimize impacts on soil, as much as possible. Supplier shall perform and promote re-use of organic matter, and regenerative agriculture.

Sustainable Packaging

Supplier shall take appropriate steps to minimize the environmental impact of packaging. Supplier shall continuously strive to remove unnecessary packaging, select recycled materials whenever possible, and reduce the amount of materials used.

Supplier Products

All products offered for sale to PECO by the Supplier must comply with PECO's specifications and all applicable laws. Upon request, PECO Supplier must be capable of disclosing potential sources of primary origin associated with the products or services provided to PECO.


Management Systems

Supplier shall take appropriate steps to maintain a management system that would include policies and procedures. Supplier shall provide appropriate training to workers to ensure that all sections of this Supplier Code of Conduct are understood and addressed consistently.

Audits and Assessments

PECO or a third-party acting on its behalf may conduct audits and inspections of Supplier's facilities, records, and employees to confirm compliance with this Code. Unsatisfactory audit results may result in PECO terminating its relationship with the Supplier, without further liability of PECO to the Supplier. In addition, Supplier shall conduct periodic self-evaluations to ensure that it, as well as its own suppliers, are complying with this Code in all jurisdictions where business or services will be conducted or performed for PECO.

Anyone who believes that a PECO Supplier has engaged in illegal, unethical or otherwise improper conduct, or conducted any other activity in violation of this Supplier Code is encouraged to speak up and report such conduct by sending an e-mail to Reported concerns will be kept confidential.

PECO Suppliers must not retaliate against any person for reporting, in good faith, contraventions of this Supplier Code, or for filing a complaint, testifying, assisting, or participating in any manner in any investigation, proceeding, or hearing conducted by a government enforcement agency. Prohibited retaliation includes any action adversely affecting continued employment, working conditions, or otherwise denying any employment benefit because an employee has reported alleged prohibited conduct or participated in an investigation.

Awareness and Monitoring

To achieve an appropriate level of understanding and knowledge, PECO expects its Suppliers to communicate PECO’s expectations to its management and workers, including the requirements of PECO’s Supplier Code of Conduct.


PECO is committed to fostering a strong partnership with each of its suppliers, to support a fair, sustainable, and transparent supply chain. As such, Supplier acknowledges that it has reviewed and understands this Supplier Code of Conduct and agrees to comply with its requirements.

Supplier agrees to distribute this Supplier Code to their employees, agents, subcontractors, suppliers, and sub-suppliers, to the extent they are involved in the provision of goods and/or services to PECO.

  1. This Code may be amended from time to time, and its enforcement and/or interpretation rests solely with PECO.
  2. Including its subsidiary and affiliated companies.
  3. This Supplier Code does not create any third-party beneficiary rights for the Supplier or any other third parties. The Supplier Code is in addition to and not in lieu of provisions of any legal agreement or contract between Suppliers and PECO
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