Business Guidelines

Business guidelines, effective January 1, 2020

1. Purpose and Scope

MJ Celco will profitably manufacture products and services that supports both our ownership and customer requirements.  We will operate our business to be fully compliant with local laws and regulations while adhering to our policies and procedures.  We will create/operate/support a lean manufacturing environment for our employees to produce cost effective and defect free products.  We will add continuous value to our business to provide an optimal future for our stakeholders, employees, and suppliers.

We expect that as part of the commitment to doing business with MJ Celco that our suppliers and also their sub-suppliers will implement this or equivalent guideline and commit to upholding the same social, ethical, and environmental principles in operating their businesses. Additionally, we expect our supply base to conduct their business in a manner that is in accordance with generally accepted ethics principles.

These principles draw upon those embedded in human rights frameworks and charters, including but not limited to the following:

  • The UN Universal Declaration of Human Rights
  • Global Sullivan Principles of Social Responsibility
  • International Labor Organizations’s Declaration of Fundamental Principles and Rights at Work
  • OECD Guidelines for Multinational Enterprises
  • International Labor Organization Tripartite Declaration of Principles concerning Multinational Enterprises on Social Policy
  • Other relevant local law or legislation

2. Responsibility

MJ Celco employees and suppliers are obligated to be fully compliant with local laws, regulations and MJ Celco policies applicable to them and that they contractually bind their sub-suppliers accordingly. This document sets forth MJ Celco’s expectation and serves as notice for our employees and suppliers of the importance to conduct their activities in line with the following principles addressed in this standard.

MJ Celco employees and suppliers will acknowledge and agree to comply with the principles of the Business Guidelines, which are an integral component of the business relationship.

3. Human Rights and Working Conditions

3.1 Health and Safety

Ensure the health and safety of employees and visitors, by providing awareness, support and the necessary tools to identify and mitigate potential health hazards and risks, and maintain compliance with all applicable regulatory requirements.

3.2 Child Labor and Forced Labor

Child labor is not tolerated, and the age of employment in accordance with legally established minimum ages in the country, where work is performed shall be complied with. Employing any person below the age of 18 is prohibited, except when clearly beneficial to the persons participating and allowable by local legislation.  Any forms of physically abusive disciplinary practices are not tolerated, nor are any forms of forced, compulsory or involuntary labor, including human trafficking.

3.3 Fair Working Conditions

Working conditions, hours worked and compensation must be fair, and comply with regulations in the country where work is performed; complying with national provisions and agreements applicable to regulating working hours, minimum wages, overtime compensation, and legally mandated benefits.

3.4 Non-Harassment and Non-Discrimination

Do not tolerate harassment or discrimination on any basis, in accordance with applicable laws and regulations, including but not limited to age, race, religion or personal belief, color, gender, gender identity, disability, national origin, marital status/parental status, pregnancy status, sexual orientation, or any other characteristic prohibited by law or otherwise irrelevant for the position. This principle extends to all decisions relating to hiring, promotion, transfer, recruitment, termination, benefits, rates of pay, and other forms of compensation or benefits provided.

3.5 Freedom of Association & Collective Bargaining

Recognize and respect employees’ freedom to join or not to join a labor union in accordance with local law.  The rules of the various trade union organizations representing employees have to be recognized, as does an employee’s right to be represented or not represented by trade unions or other representatives established in accordance with local legislation and practice.

3.6 Conflict Minerals

Ensure responsible procurement in the Democratic Republic of Congo (DRC) in the extraction and trade of ores of tantalum, tin, tungsten, and gold (“Conflict Minerals”) through abstaining from the procurement or usage of materials which are unlawful or which are obtained through unethical or otherwise unacceptable means.

4. Environment & Sustainability

Conduct business in an environmentally-friendly and responsible manner, taking a precautionary approach to environmental challenges by designing and developing products that take into account the impact they have on the environment and the potential to re-use and recycle them. Comply with all applicable environmental laws and regulations and promptly develop and implement plans or programs to correct any non-compliant practices.

5. Business Conduct and Ethics

The highest standards of integrity, honesty and fairness are required in all business activities.  Implementation of a Code of Conduct is highly recommended for our suppliers. Regardless, activities must be performed in a manner consistent with all applicable laws and regulations.

5.1 Antitrust and Competition 

Strictly comply with all applicable antitrust laws, trade practice laws and any other laws, rules and regulations. Do not enter into agreements with competitors and other acts, which may unfairly impact competition, including, but not limited to, price fixing or market allocations.

5.2 Anti-corruption and anti-bribery

Do not engage in nor tolerate any form of corruption, bribery, theft, embezzlement, or extortion, or the use of illegal payments for the purpose of influencing the decision-making process, whether or not in violation of applicable laws. Do not offer, grant, demand or accept bribes, illegal payments, payoffs, kickbacks, incentives, gifts, entertainment, favors or other benefit of a value in exchange for business opportunities with or in any way related to the business operations of MJ Celco.

5.3 Conflicts of Interest

Disclose actual and potential conflicts of interest, including having a business associate, an immediate family member and/or relative, or a close friend that is employed by MJ Celco. Suppliers must also disclose if a MJ Celco employee has an ownership  in their company.

5.4 Export Controls

Comply with all applicable import and export control laws, including without limitation, sanctions, embargoes and other laws, regulations, government orders and policies controlling the transmission or shipment of goods and technology.

5.5 Data Protection, Confidential Information and Intellectual Property

Comply with all applicable laws concerning data protection, ensuring that any confidential business information or trade secrets gained by virtue of the business activities with MJ Celco is maintained confidential and will not be improperly used or disclosed to third parties. Respect and ensure that MJ Celco Intellectual Property is secured in relation with others.

6. Compliance

Employees and suppliers are required to report non-compliance with this guideline to their respective contact.  In the event of non-conformity with any of the aforementioned principles, MJ Celco reserves the right to early termination for cause of the business relationship with any employee or supplier. 

7. Acknowledgement

We expect that as part of the commitment to doing business with MJ Celco that our suppliers will implement this or equivalent guideline and commit to upholding the same social, ethical, and environmental principles in operating their businesses.

8. References