PURPOSE

At Panduit, one of our core values is Integrity. As such, we are, and have always been, committed to respecting the human rights and dignity of everyone, and we support international efforts to promote and protect human rights. We are committed to ensuring all employees are treated with dignity and respect. We do not tolerate conduct that exploits workers or denies them the freedom, rights and benefits that we believe they are legally and fundamentally entitled to. We will not tolerate abuse of human rights in our operations or in our supply chain.

This Policy is guided by international human rights principals and labor standards including those covered by the Universal Declaration of Human Rights, the International Labor Organization’s (ILO) Declaration on Fundamental Principles and Rights at Work including its conventions, the Organization for Economic Cooperation and Development’s (OECD) Guidelines for Multinational Enterprises, and the United Nations Guiding Principles on Business and Human Rights.

SCOPE

This policy applies to Panduit Corp. and its subsidiaries worldwide (“Panduit”) and the directors, officers and employees of Panduit and anyone acting on our behalf.  This policy is not an exhaustive representation of Human Rights, but it defines Panduit’s position and expectations pertaining to Human Rights within our operations and supply chain. It, along with our Code of Ethics and Business Conduct (the “Code”), our Supplier Code of Conduct, our Business Partner Code of Ethics, and other company policies, set the standards required by our employees, anyone acting on our behalf and throughout our value chain. Panduit is committed to complying with all applicable laws, rules and regulations in the countries where we operate. However, if a local law is less stringent than any standard set forth herein, Panduit will follow the standards set forth herein. 

STANDARDS

I. Hiring and Recruiting Practices

a. Child Labor

Panduit is committed to contributing to the elimination of the use of child labor. In practice, Panduit is not engaged in and does not support the employment of children under the age of 18. Under no circumstances does the Company support workers under the age of 18 for hazardous work that impacts their health and safety, including night shifts and overtime. The only exception to employing individuals under 18 would be for limited exploratory work programs designed for individuals who are no younger than 15, which do not impair their right to access education and follow all legal requirements.  Panduit, to the best of its knowledge, does not engage with business partners that are using child labor, as defined by ILO Convention standards, in their operations. Panduit reserves the right to enforce its Supplier Code of Conduct if a business partner has been found or is suspected of having child labor in its supply chain.

b. Elimination of Forced Labor and Human Trafficking

Panduit does not tolerate any form of forced or compulsory labor, including indentured, bonded, modern forms of slavery, human trafficking, or prison labor. Panduit will never use wage deductions, withholding personal documents, or other means to force employees to continue to work for Panduit. Panduit reserves the right to enforce its Supplier Code of Conduct, if a business partner has been found or is suspected to have forced labor or human trafficking in its supply chain.

c. Migrant Workers and Fair Recruiting and Hiring Practices

Panduit does not employ migrant workers as a significant part of its workforce; however, business demands may require employment of migrant workers. In such situations Panduit ensures that all migrant workers are employed using a transparent recruitment process, positions are filled through legitimate agencies who comply with all laws, and workers have necessary visas permitting them to legally work in the host country just as we do when we hire Panduit employees and contract workers from staffing agencies. Panduit requires recruitment fees to be charged to Panduit, never the candidate being hired, as outlined in our company policies. Passports and visas are collected for means of proof of the right to work, but we do not hold passports or visas, nor do we allow our recruiting or staffing firms to withhold passports or any identification documents. It is Panduit’s policy that all workers always retain freedom of movement and access to the same rights as all employees. Housing is not provided by Panduit on or near the work location; however, in some countries an allowance may be provided as a benefit to the employee for the employee to seek adequate and safe housing.

II. Working Conditions

a. Humane Treatment in the Workforce 

Panduit ensures that all our employees or contract workers working in our facilities are free from harsh and inhumane treatment.  The following disciplinary measures are strictly prohibited: capital punishment, mental, verbal or sexual abuse, intimidation, or other types of coercion or harassment.

b. Harassment Prohibition and Workplace Respect

At Panduit, our employees and business partners are entitled to respect and dignity. We define harassment as any unwelcome conduct toward another person that creates an intimidating, hostile or offensive work environment. We do not tolerate any harassment, discrimination or bullying in the workplace. The following are examples of conduct that is not tolerated at Panduit:

• Inappropriate remarks, insults, gestures, threats, bullying or physical contact.
• Jokes, comments, or email of sexual, racial, or otherwise offensive nature.
• Online behavior such as displaying inappropriate pictures, sending offensive messages, or engaging in hostile social media conduct toward fellow employees,
• Sexual harassment, which can included repeated unwanted sexual advances and promising favorable treatment or threatening unfavorable treatment in response to sexual requests. We will not tolerate such conduct, regardless of whether such conduct is legal under local law.

c. Wage, Work Hours and Overtime

Panduit is committed to paying all employees a decent living wage, considering the needs of workers and their families, and economic factors. We strive to provide employees with access to equal pay for equal work at all levels of our company. Employee working hours must be in compliance with all applicable laws and regulations. Where the law is silent, all our global businesses and business partners must aim to maintain ordinary and reasonable working hours, limitations and compensation for overtime worked, and night shifts that follow the ILO Convention standards. Employees are given an Employee Handbook that details the hours to be worked, breaks in the workday, and days of rest.

d. Health and Safety

We understand that human rights cannot be enjoyed without a safe, clean, and healthy environment, and standard of well-being inside and outside the workplace. We are committed to promoting a safe and healthy environment by providing:

• Access to company benefits that support health and well-being.
• Training on how to maintain a safe working environment and be proactive to minimize and prevent workplace injuries.
• Emergency and security procedures that apply to local work environments and translate in local languages.
• A centralized process to report all safety and environmental incidents.

e. Security

Panduit has zero tolerance for workplace violence and is committed to providing a safe and secure work environment that is free from violence. Panduit’s policy prohibits any type of violence, including verbal and physical threats, dangerous horseplay, bullying, stalking, property destruction, or vandalism. We prohibit possession of weapons on company property, including firearms (unless carried by authorized Panduit security personnel). Employees are regularly trained in how to identify warning signs of violence and to report any concerns immediately.

f. Data Privacy

We respect the privacy of employees, customers and business partners and are dedicated to safeguarding this information in accordance with relevant laws, regulations, and treaties. The right to privacy is recognized in Article 12 of the Universal Declaration of Human Rights. We understand the effects of mishandled personal data on human rights, such as freedom of expression, reputation, and freedom of association. We have taken several steps to ensure privacy is protected, and treated ethically including the following:

• When we collect, access and use personal information it must be for legitimate business purposes only.
• We train and instruct employees to use care when providing personal and confidential data to anyone inside or outside of Panduit and limit access to authorized individuals.
• When we use third parties to provide services for us, we make sure they understand the importance we place on privacy and data security.

g. Freedom of Expression and Grievance Mechanisms

We value freedom of expression and encourage open dialogue, allowing employees to express their concerns and opinions without fear of retaliation. Our Code states that all Panduit employees have a responsibility to report any illegal, unsafe or unethical conduct, including violations of human rights. There are many ways for our employees to report such concerns including reporting to any manager, HR business partner or the Chief Compliance Officer or the Legal department. Further, Panduit’s Integrity Line: Panduit’s Ethics and Compliance Helpline is accessible to all of our stakeholders globally including employees, customers, distributors, suppliers and other business partners.  On the Integrity Line, you can report via the website (which is translated into all languages where Panduit conducts business), or by calling a local phone number that is answered in the local language. You can report anonymously or give your name. No matter how the report is received, Panduit takes every complaint seriously and follows a consistent investigation process. We have a strict policy against any retaliation. 

III. Equal Opportunity

a. Non-Discrimination

We are committed that regardless of geographic location, all employment-related decisions must be based exclusively on job-related qualifications, without regard to characteristics such as a person’s age, race, color, physical or mental disability, genetic information, gender, gender identity or expression, marital status, medical condition, ancestry, military or veteran status, national origin, religion, sex, sexual orientation, or any other characteristic protected by law.

b. Workplace Inclusion

We expect all our employees and partners to help create a culture of respect, dignity and fairness. We understand that to succeed we must attract and retain outstanding employees and create an inclusive work environment where they can thrive and innovate. This means building an environment where all employees belong and can do their best work. Employee Resource Groups have been founded to promote inclusion opportunities for development and giving a voice to our workforce.

c. Freedom of Association and Collective Bargaining

We respect the individual rights of our employees to freely join, participate in or quit labor organizations. Panduit guarantees that any employee wishing to join or participate in labor organizations can do so without fear of reprisal, intimidation or harassment. Where employees are represented by a legally recognized union, we are committed to establishing a constructive dialogue with their freely chosen representatives. We are committed to bargaining in good faith with such representatives.

IV.  Global Non-Labor Standards

a. Anti-Bribery and Corruption

We recognize the risk of bribery and corruption is often present where there are risks of human rights violations. Panduit has a zero-tolerance policy towards any form of bribery and corruption anywhere in the world. This is communicated to employees and business partners through our Code, our internal Anti-Corruption Policy and our regular in-person and online training. 

b. Environment (Land Rights and Water Resources)

We recognize the interconnectedness of human rights and environmental sustainability. Environmental Stewardship is core to how we think about our impact on the communities we operate in. In addition to complying with all applicable environmental laws, Panduit is committed to sustainability in our operations. We meet or exceed applicable environmental laws and work to continuously improve our environmental performance through resource conservation, waste minimization, water and energy efficiency and effective use of raw materials.

We comply with all laws, policies, permits and regulations aimed at:

• Protecting the environment.
• Conserving energy, water and natural resources.
• Reducing the environmental impact of our operations.

Through continuous improvement efforts we are proactive and look for ways that we can reduce waste and use energy and natural resources more efficiently.

We have a reporting mechanism to address environmental regulatory violations or adverse environmental impacts and would take any reports on our activities seriously.

c. Local Community Engagement

We seek to understand the impact of our operations on the communities in which we do business whether at our owned and operated local sites, temporarily for a project, or partnering with our customers and suppliers. Panduit seeks to build an understanding by establishing a regular dialog with local stakeholders, communities, and their representatives.

We care about the issues that are important to our employees and provide company-sponsorship to employee-driven community initiatives and organized community service events. We encourage our employees to be involved in their communities, providing them with paid time off to volunteer and stay connected to the community.

In times of crisis, we work with local authorities and communities to provide support through disaster relief, humanitarian aid, and other initiatives aimed at protecting the well-being of affected individuals.

How to Report Human Rights Violations

Remember that respect for human dignity begins with our daily interactions with one another and with our customers and business partners. Each of us can help support efforts to eliminate human rights abuse and we encourage anyone to report actions that have a negative impact on human rights. You can do this by reporting any suspicion or evidence of human rights abuses in our operations or in the operations of our business partners via the Integrity Line: Panduit Ethics & Compliance Helpline.