Vendor Code of Conduct


TAWANI Enterprises believes in honoring the lessons of history to create positive change for individuals, properties, and businesses. Through all its work, TAWANI Enterprises unites past and progress by advancing historic preservation, sustainability, neighborhood development, awareness of military history, and other projects that impact people and the places they live.  TAWANI Enterprises together with its subsidiaries and affiliates, including but not limited to Arum Trading LLC (collectively “TAWANI”), strives to work with vendors (including but not limited to manufacturers, printers, packagers, distributors, contractors, subcontractors, suppliers of goods or services, consultants, and other vendors) (collectively “Vendors”) who treat their workers with dignity and respect, maintain decent and healthy working conditions, adhere to all applicable laws, rules, and regulations, and make their products, and offer their services in a safe and environmentally sustainable manner.  Accordingly, we require each Vendor and their representatives to conduct their business interactions and activities with integrity, in accordance with their obligations under their specific agreements with TAWANI, and to adhere to and comply with the following Vendor Code of Conduct (the “Code”). This Code defines our minimum expectations. No code of conduct can be all-inclusive, but we expect those Vendors with whom we do business to act reasonably in all respects and to ensure that no abusive, exploitative, or illegal conditions exist at their workplace. Vendors shall, upon request, certify their compliance with this Code. TAWANI may cancel, terminate, or suspend its business relationship with any Vendor who fails to comply with this Code or the law or fails to certify to this Code when requested.

Business Conduct & Human Rights:

Compliance with Applicable Laws, Rules, Regulations and Company Policies: Vendors are expected to comply with, and ensure their subcontractors comply with, all laws, rules, regulatory requirements, and company policies applicable to their business, including but not limited to those related to wages, hours, labor, health, safety, the environment, immigration, import/export, and business conduct and ethics.  In furtherance of the foregoing, all Vendors must:

  1. Refrain from unlawful discrimination and discrimination based on citizenship status in employment and undertake affirmative action to assure equality of employment opportunity and eliminate the effects of past discrimination. Vendors shall not subject any person to discrimination in employment (including hiring, selection for training, including apprenticeship, salary or other forms of compensation, benefits, upgrading, advancement, discipline, demotion or transfer, layoff, termination, or retirement) on the basis of age, sex, race, color, ancestry, religion, creed, citizenship status, disability, national origin, marital status, military status, sexual orientation, gender identity and expression, or any factors not related to the job. Vendors are expected to comply with all applicable local laws concerning discrimination in hiring and employment practices, including but not limited to the Civil Rights Act, the Age Discrimination Act, and the Americans with Disabilities Act.
  2. Comply with the procedures and requirements of the Illinois Department of Human Rights’ regulations concerning equal employment opportunities and affirmative action.
  3. Provide such information, with respect to its employees and applicants for employment, and assistance as the Illinois Department of Human Rights may reasonably request from time to time.
  4. Vendors will treat each employee with respect and dignity and will not subject any employee to any physical, sexual, psychological, verbal, or any other form of harassment or abuse.Vendor shall have written sexual harassment policies that must include, at a minimum, the following information:  (i) the illegality of sexual harassment; (ii) the definition of sexual harassment under State law; (iii) a description of sexual harassment, utilizing examples; (iv) Vendor’s internal complaint process including penalties; (v) the legal recourse, investigative and complaint process available through the Illinois Department of Human Rights and the Illinois Human Rights Commission; (vi) directions on how to contact the Illinois Department of Human Rights and the Illinois Human Rights Commission; and (vii) protection against retaliation as provided in Section 6-101 of the Illinois Human Rights Act (775 ILCS 5/2-105).  A copy of the policies must be provided to the Illinois Department of Human Rights upon request.

Labor & Compensation:

Forced Labor: TAWANI does not tolerate the use of forced or involuntary labor and does not and will not knowingly work with Vendors who engage in such practices. All workers have the right to engage in work willfully, without surrendering identification. Workers have the right to freedom of movement and Vendors must ensure it is afforded to them. Vendors shall not utilize forced or involuntary labor, whether in the form of prison labor, indentured labor, bonded labor, or otherwise.

Child Labor: TAWANI does not tolerate the use of child labor and does not and will not knowingly work with, nor accept products or services from Vendors that utilize and exploit underage workers.  Vendors are expected to comply with applicable local child labor laws and employ only workers who meet the applicable minimum legal age requirement.

Compensation and Working Hours:  Vendors are expected to comply with all applicable wage and hour labor laws and regulations governing employee compensation and working hours. Vendors must provide wages and benefits that meet or exceed local law requirements and are paid/provided in a timely manner. If no minimum wage law applies, Vendors shall pay employees the prevailing industry wage.  TAWANI will not use Vendors who require employees to work in excess of the statutory requirements without proper compensation and time-off as required by applicable law.

Environment, Health & Safety:

Environment: Vendors are expected to conduct their operations in a way that protects the environment. Vendors shall comply with all applicable environmental laws and regulations in the countries in which they operate.

Health and Safety: Vendors shall comply with all applicable safety and health laws and regulations in the countries in which they operate. Vendors are expected to provide a safe working environment that supports accident prevention and minimizes exposure to health risks occurring within or arising out of the course of work. Workers shall not be disciplined for raising safety concerns and shall have the right to refuse unsafe working conditions without fear of reprisal until management adequately addresses their concerns. Vendors are also expected to provide products and services that meet all applicable health and safety requirements.

Conflict Minerals: Vendors are required to design and implement reasonable processes to ensure transparency related to the content and materials comprising all products manufactured for TAWANI which may include gold, tantalum, tin, and tungsten and the ores from which they are derived. Vendors are required to communicate, to the best of their knowledge, the country of origin and content of the product(s) manufactured for TAWANI and to determine whether these products contain “conflict minerals” as defined by Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act.

Conflicts of Interest:

Gifts and Gratuities: Vendors shall conduct business in an ethical and legal manner, free from potential personal or private interests that may affect professional judgment or adversely impact TAWANI.  TAWANI employees are permitted to give and accept only modest entertainment and tokens of appreciation that are considered usual and customary and consistent with regular business practice, which are of nominal value. Vendors must avoid the appearance of impropriety and never give any gift or offer of entertainment to anyone if doing so would cause the recipient to violate the law, or his or her employer’s rules and policies.

Anti-Bribery and Anti-Corruption: Corruption, extortion, and embezzlement, in any form, are strictly prohibited. TAWANI complies with the anti-bribery and anti-corruption laws of the countries in which it does business, including the Foreign Corrupt Practices Act (“FCPA”) and any similar foreign laws. Neither Vendors, their agents, subcontractors, nor their representatives shall violate the FCPA, any international anticorruption conventions, or applicable anti-corruption laws or regulations of the countries in which they operate, nor shall they engage in corruption, extortion, or embezzlement in any form. Vendors will not make any direct or indirect payments or promises of payment to foreign government officials for the purpose of inducing an unfair business advantage. Offers or agreements with foreign government officials that could reasonably be interpreted as an attempt to gain an unfair business advantage are also prohibited. This prohibition also applies in areas where such activity may not violate local law.

Intellectual Property:

Vendor shall display the highest standard of respect, legal and ethical behavior with regard to the intellectual property rights of third parties. Vendors must ensure that the products or services sold and/or provided to TAWANI do not violate the patent, trademark, copyright, or any other proprietary rights of any third party.

Contact: If you have questions about any of the information in this Code, or what is expected of you, or to report any violations of the Code, please contact the Legal and Risk Management Department at (312) 374-9455.