Responsible Business Alliance
Code of Conduct
TomTom | RBA Code of Conduct | Version 6.0 | January 2018
CONTENTS
INTRODUCTION ........................................................................................................................ 2
A. LABOR ............................................................................................................................. 3
B. HEALTH and SAFETY ........................................................................................................... 5
C. ENVIRONMENTAL ............................................................................................................... 7
D. ETHICS ............................................................................................................................ 9
E. MANAGEMENT SYSTEMS ....................................................................................................11
REFERENCES .........................................................................................................................13
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TomTom | RBA Code of Conduct | Version 6.0 | January 2018
INTRODUCTION
The Responsible Business Alliance (RBA), formerly the Electronic Industry Citizenship Coalition (EICC),
Code of Conduct establishes standards to ensure that working conditions in the electronics industry or
industries in which electronics is a key component and its supply chains are safe, that workers are treated
with respect and dignity, and that business operations are environmentally responsible and conducted
ethically.
This TomTom RBA Code of Conduct (the Code) is based on the RBA Code of Conduct, which is maintained
and updated by RBA from time to time. TomTom is adopting the Code for TomTom suppliers (Suppliers)
and for its own operations. All Suppliers involved in the manufacturing of TomTom products, product
components, sub-assemblies, and materials, packaging or that provide services to or on behalf of TomTom
are required to comply with the Code. Whilst we recognize that the existence of difference legal and cultural
environments in which Suppliers operate around the world, this Code establishes the minimum
requirements that all Suppliers are expected to meet in doing business with TomTom.
The Code is made up of five sections. Sections A, B, and C outline standards for Labor, Health and Safety,
and the Environment, respectively. Section D adds standards relating to business ethics; Section E outlines
the elements of an acceptable system to manage conformity to this Code.
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A. LABOR
Participants are committed to uphold the human rights of workers, and to treat them with dignity and respect
as understood by the international community. This applies to all workers including temporary, migrant,
student, contract, direct employees, and any other type of worker. The recognized standards, as set out in
the annex, were used as references in preparing the Code and may be a useful source of additional
information.
The labor standards are:
1) Freely Chosen Employment
Forced, bonded (including debt bondage) or indentured labor, involuntary or exploitative prison labor,
slavery or trafficking of persons shall not be used. This includes transporting, harboring, recruiting,
transferring or receiving persons by means of threat, force, coercion, abduction or fraud for labor or
services. There shall be no unreasonable restrictions on workers’ freedom of movement in the facility in
addition to unreasonable restrictions on entering or exiting company-provided facilities. As part of the hiring
process, workers must be provided with a written employment agreement in their native language that
contains a description of terms and conditions of employment prior to the worker departing from his or her
country of origin and there shall be no substitution or change(s) allowed in the employment agreement upon
arrival in the receiving country unless these changes are made to meet local law and provide equal or better
terms. All work must be voluntary and workers shall be free to leave work at any time or terminate their
employment Employers and agents may not hold or otherwise destroy, conceal, confiscate or deny access
by employees to their identity or immigration documents, such as government-issued identification,
passports or work permits, unless such holdings are required by law. Workers shall not be required to pay
employers’ or agents’ recruitment fees or other related fees for their employment. If any such fees are found
to have been paid by workers, such fees shall be repaid to the worker.
2) Young Workers
Child labor is not to be used in any stage of manufacturing. The term “child” refers to any person under the
age of 15, or under the age for completing compulsory education, or under the minimum age for
employment in the country, whichever is greatest. The use of legitimate workplace learning programs, which
comply with all laws and regulations, is supported. Workers under the age of 18 (Young Workers) shall not
perform work that is likely to jeopardize their health or safety, including night shifts and overtime. Participant
shall ensure proper management of student workers through proper maintenance of student records,
rigorous due diligence of educational partners, and protection of students’ rights in accordance with
applicable law and regulations. Participant shall provide appropriate support and training to all student
workers. In the absence of local law, the wage rate for student workers, interns and apprentices shall be at
least the same wage rate as other entry-level workers performing equal or similar tasks.
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3) Working Hours
Studies of business practices clearly link worker strain to reduced productivity, increased turnover and
increased injury and illness. Working hours are not to exceed the maximum set by local law. Further, a
workweek should not be more than 60 hours per week, including overtime, except in emergency or unusual
situations. Workers shall be allowed at least one day off every seven days.
4) Wages and Benefits
Compensation paid to workers shall comply with all applicable wage laws, including those relating to
minimum wages, overtime hours and legally mandated benefits. In compliance with local laws, workers
shall be compensated for overtime at pay rates greater than regular hourly rates. Deductions from wages
as a disciplinary measure shall not be permitted. For each pay period, workers shall be provided with a
timely and understandable wage statement that includes sufficient information to verify accurate
compensation for work performed. All use of temporary, dispatch and outsourced labor will be within the
limits of the local law.
5) Humane Treatment
There is to be no harsh and inhumane treatment including any sexual harassment, sexual abuse, corporal
punishment, mental or physical coercion or verbal abuse of workers; nor is there to be the threat of any
such treatment. Disciplinary policies and procedures in support of these requirements shall be clearly
defined and communicated to workers.
6) Non-Discrimination
Participants should be committed to a workforce free of harassment and unlawful discrimination.
Companies shall not engage in discrimination based on race, color, age, gender, sexual orientation, gender
identity and expression, ethnicity or national origin, disability, pregnancy, religion, political affiliation, union
membership, covered veteran status, protected genetic information or marital status in hiring and
employment practices such as wages, promotions, rewards, and access to training. Workers shall be
provided with reasonable accommodation for religious practices. In addition, workers or potential workers
should not be subjected to medical tests or physical exams that could be used in a discriminatory way.
7) Freedom of Association
In conformance with local law, participants shall respect the right of all workers to form and join trade unions
of their own choosing, to bargain collectively and to engage in peaceful assembly as well as respect the
right of workers to refrain from such activities. Workers and/or their representatives shall 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.
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B. HEALTH and SAFETY
Participants recognize that in addition to minimizing the incidence of work-related injury and illness, a safe
and healthy work environment enhances the quality of products and services, consistency of production
and worker retention and morale. Participants also recognize that ongoing worker input and education is
essential to identifying and solving health and safety issues in the workplace.
Recognized management systems such as OHSAS 18001 and ILO Guidelines on Occupational Safety
and Health were used as references in preparing the Code and may be a useful source of additional
information.
The health and safety standards are:
1) Occupational Safety
Worker potential for exposure to safety hazards (e.g., chemical, electrical and other energy sources, fire,
vehicles, and fall hazards) are to be identified and assessed, and controlled through proper design,
engineering and administrative controls, preventative maintenance and safe work procedures (including
lockout/tagout), and ongoing safety training. Where hazards cannot be adequately controlled by these
means, workers are to be provided with appropriate, well-maintained, personal protective equipment and
educational materials about risks to them associated with these hazards. Reasonable steps must also be
taken to remove pregnant women/nursing mothers from working condition with high hazards, remove or
reduce any workplace health and safety risks to pregnant women and nursing mothers including those
associated with their work assignments, as well as include reasonable accommodations for nursing
mothers
2) Emergency Preparedness
Potential emergency situations and events are to be identified and assessed, and their impact minimized
by implementing emergency plans and response procedures including: emergency reporting, employee
notification and evacuation procedures, worker training and drills, appropriate fire detection and
suppression equipment, clear and unobstructed egress adequate exit facilities and recovery plans. Such
plans and procedures shall focus on minimizing harm to life, the environment and property.
3) Occupational Injury and Illness
Procedures and systems are to be in place to prevent, manage, track and report occupational injury and
illness including provisions to: encourage worker reporting; classify and record injury and illness cases;
provide necessary medical treatment; investigate cases and implement corrective actions to eliminate their
causes; and facilitate return of workers to work.
4) Industrial Hygiene
Worker exposure to chemical, biological and physical agents is to be identified, evaluated, and controlled
according to the hierarchy of controls. Potential hazards are to be eliminated or controlled through proper
design, engineering and administrative controls. When hazards cannot be adequately controlled by such
means, workers are to be provided with and use appropriate, well-maintained, personal protective
equipment. Protective programs shall include educational materials about the risks associated with these
hazards.
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5) Physically Demanding Work
Worker exposure to the hazards of physically demanding tasks, including manual material handling and
heavy or repetitive lifting, prolonged standing and highly repetitive or forceful assembly tasks is to be
identified, evaluated and controlled.
6) Machine Safeguarding
Production and other machinery shall be evaluated for safety hazards. Physical guards, interlocks and
barriers are to be provided and properly maintained where machinery presents an injury hazard to workers.
7) Sanitation, Food, and Housing
Workers are to be provided with ready access to clean toilet facilities, potable water and sanitary food
preparation, storage, and eating facilities. Worker dormitories provided by the Participant or a labor agent
are to be maintained to be clean and safe, and provided with appropriate emergency egress, hot water for
bathing and showering, adequate lighting heat and ventilation, individually secured accommodations for
storing personal and valuable items, and reasonable personal space along with reasonable entry and exit
privileges.
8) Health and Safety Communication
Participant shall provide workers with appropriate workplace health and safety information and training in
the language of the worker or in a language the worker can understand for all identified workplace hazards
that workers are exposed to, including but not limited to mechanical, electrical, chemical, fire, and physical
hazards. Health and safety related information shall be clearly posted in the facility or placed in a location
identifiable and accessible by workers. Training is provided to all workers prior to the beginning of work
and regularly thereafter. Workers shall be encouraged to raise safety concerns.
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C. ENVIRONMENTAL
Participants recognize that environmental responsibility is integral to producing world class products. In
manufacturing operations, adverse effects on the community, environment and natural resources are to
be minimized while safeguarding the health and safety of the public. Recognized management systems
such as ISO 14001 and the Eco Management and Audit System (EMAS) were used as references in
preparing the Code and may be a useful source of additional information.
The environmental standards are:
1) Environmental Permits and Reporting
All required environmental permits (e.g. discharge monitoring), approvals and registrations are to be
obtained, maintained and kept current and their operational and reporting requirements are to be followed.
2) Pollution Prevention and Resource Reduction
Emissions and discharges of pollutants and generation of waste are to be minimized or eliminated at the
source or by practices such as adding pollution control equipment; modifying production, maintenance and
facility processes; or by other means. The use of natural resources, including water, fossil fuels, minerals
and virgin forest products, is to be conserved or by practices such as modifying production, maintenance
and facility processes, materials substitution, re-use, conservation, recycling or other means.
3) Hazardous Substances
Chemicals and other materials posing a hazard to humans or the environment are to be identified, labelled
and managed to ensure their safe handling, movement, storage, use, recycling or reuse and disposal.
4) Solid Waste
Participant shall implement a systematic approach to identify, manage, reduce, and responsibly dispose
of or recycle solid waste (non-hazardous).
5) Air Emissions
Air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting chemicals
and combustion by-products generated from operations are to be characterized, routinely monitored,
controlled and treated as required prior to discharge. Participant shall conduct routine monitoring of the
performance of its air emission control systems.
6) Materials Restrictions
Participants are to adhere to all applicable laws, regulations and customer requirements regarding
prohibition or restriction of specific substances in products and manufacturing, including labeling for
recycling and disposal.
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7) Water Management
Participant shall implement a water management program that documents, characterizes, and monitors
water sources, use and discharge; seeks opportunities to conserve water; and controls channels of
contamination. All wastewater is to be characterized, monitored, controlled, and treated as required prior
to discharge or disposal. Participant shall conduct routine monitoring of the performance of its wastewater
treatment and containment systems to ensure optimal performance and regulatory compliance.
8) Energy Consumption and Greenhouse Gas Emissions
Energy consumption and all relevant Scopes 1 and 2 greenhouse gas emissions are to be tracked and
documented, at the facility and/or corporate level. Participants are to look for cost- effective methods to
improve energy efficiency and to minimize their energy consumption and greenhouse gas emissions.
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D. ETHICS
To meet social responsibilities and to achieve success in the marketplace, Participants and their agents
are to uphold the highest standards of ethics including:
1) Business Integrity
The highest standards of integrity are to be upheld in all business interactions. Participants shall have a
zero tolerance policy to prohibit any and all forms of bribery, corruption, extortion and embezzlement.
2) No Improper Advantage
Bribes or other means of obtaining undue or improper advantage are not to be promised, offered,
authorized, given or accepted. This prohibition covers promising, offering, authorizing, giving or accepting
anything of value, either directly or indirectly through a third party, in order to obtain or retain business,
direct business to any person, or otherwise gain an improper advantage. Monitoring and enforcement
procedures shall be implemented to ensure compliance with anti-corruption laws.
3) Disclosure of Information
All business dealings should be transparently performed and accurately reflected on Participant’s business
books and records. Information regarding participant labor, health and safety, environmental practices,
business activities, structure, financial situation and performance is to be disclosed in accordance with
applicable regulations and prevailing industry practices.
Falsification of records or misrepresentation of conditions or practices in the supply chain are
unacceptable.
4) Intellectual Property
Intellectual property rights are to be respected; transfer of technology and know- how is to be done in a
manner that protects intellectual property rights; and, customer and supplier information is to be
safeguarded.
5) Fair Business, Advertising and Competition
Standards of fair business, advertising and competition are to be upheld.
6) Protection of Identity and Non-Retaliation
Programs that ensure the confidentiality, anonymity and protection of supplier and employee
whistleblowers1 are to be maintained, unless prohibited by law. Participants should have a communicated
process for their personnel to be able to raise any concerns without fear of retaliation.
1
Whistleblower definition: Any person who makes a disclosure about improper conduct by an employee or officer of a company, or
by a public official or official body.
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7) Responsible Sourcing of Minerals
Participants shall have a policy to reasonably assure that the tantalum, tin, tungsten and gold in the
products they manufacture does not directly or indirectly finance or benefit armed groups that are
perpetrators of serious human rights abuses in the Democratic Republic of the Congo or an adjoining
country. Participants shall exercise due diligence on the source and chain of custody of these minerals
and make their due diligence measures available to customers upon customer request.
8) Privacy
Participants are to commit to protecting the reasonable privacy expectations of personal information of
everyone they do business with, including suppliers, customers, consumers and employees. Participants
are to comply with privacy and information security laws and regulatory requirements when personal
information is collected, stored, processed, transmitted, and shared.
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E. MANAGEMENT SYSTEMS
Participants shall adopt or establish a management system whose scope is related to the content of this
Code. The management system shall be designed to ensure: (a) compliance with applicable laws,
regulations and customer requirements related to the participant’s operations and products; (b)
conformance with this Code; and (c) identification and mitigation of operational risks related to this Code.
It should also facilitate continual improvement.
The management system should contain the following elements:
1) Company Commitment
A corporate social and environmental responsibility policy statements affirming Participant’s commitment
to compliance and continual improvement, endorsed by executive management and posted in the facility
in the local language.
2) Management Accountability and Responsibility
The Participant clearly identifies senior executive and company representative[s] responsible for ensuring
implementation of the management systems and associated programs. Senior management reviews the
status of the management system on a regular basis.
3) Legal and Customer Requirements
A process to identify, monitor and understand applicable laws, regulations and customer requirements,
including the requirements of this Code.
4) Risk Assessment and Risk Management
A process to identify the legal compliance, environmental, health and safety2 and labor practice and ethics
risks associated with Participant’s operations. Determination of the relative significance for each risk and
implementation of appropriate procedural and physical controls to control the identified risks and ensure
regulatory compliance.
5) Improvement Objectives
Written performance objectives, targets and implementation plans to improve the Participant’s social and
environmental performance, including a periodic assessment of Participant’s performance in achieving
those objectives.
6) Training
Programs for training managers and workers to implement Participant’s policies, procedures and
improvement objectives and to meet applicable legal and regulatory requirements.
2
Areas to be included in a risk assessment for environmental health and safety are production areas, warehouse and storage
facilities, plant/facilities support equipment, laboratories and test areas, sanitation facilities (bathrooms), kitchen/cafeteria and worker
housing/dormitories.
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7) Communication
A process for communicating clear and accurate information about Participant’s policies, practices,
expectations and performance to workers, suppliers and customers.
8) Worker Feedback, Participation and Grievance
Ongoing processes, including an effective grievance mechanism, to assess employees’ understanding of
and obtain feedback on or violations against practices and conditions covered by this Code and to foster
continuous improvement.
9) Audits and Assessments
Periodic self-evaluations to ensure conformity to legal and regulatory requirements, the content of the
Code and customer contractual requirements related to social and environmental responsibility.
10) Corrective Action Process
A process for timely correction of deficiencies identified by internal or external assessments, inspections,
investigations and reviews.
11) Documentation and Records
Creation and maintenance of documents and records to ensure regulatory compliance and conformity to
company requirements along with appropriate confidentiality to protect privacy.
12) Supplier Responsibility
A process to communicate Code requirements to suppliers and to monitor supplier compliance to the
Code.
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REFERENCES
The following standards were used in preparing this Code and may be a useful source of additional
information. The following standards may or may not be endorsed by each Participant.
Dodd-Frank W all Street Reform and Consumer Protection Act
http://www.sec.gov/about/laws/wallstreetreform -cpa.pdf
Eco Management & Audit System www.quality.co.uk/emas.htm
Ethical Trading Initiative www.ethicaltrade.org/
ILO Code of Practice in Safety and Health
www.ilo.org/public/english/protection/safework/cops/english/download/e000013.pdf
ILO International Labor Standards www.ilo.org/public/english/standards/norm/whatare/fundam/index.htm
ISO 14001 www.iso.org
National Fire Protection Agency www.nfpa.org/catalog/home/AboutNFPA/index.asp
OECD Due Diligence Guidance
http://www.oecd.org/document/36/0,3746,en_2649_34889_44307940_1_1_1_1,00.html
OECD Guidelines for Multinational Enterprises www.oecd.org
OHSAS 18001
www.bsi-global.com/index.xalter
Universal Declaration of Human Rights www.un.org/Overview/rights.html
United Nations Convention Against Corruption
www.unodc.org/unodc/en/crime_convention_corruption.html
United Nations Global Compact www.unglobalcompact.org
United States Federal Acquisition Regulation www.acquisition.gov/far/
SA 8000 www.cepaa.org/
SAI www.sa-intl.org
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