E1. Company Commitment

Code 8.0

Participants shall establish human rights, health and safety, environmental and ethics policy statements affirming Participant's commitment to due diligence and continual improvement, endorsed by executive management. Policy statements shall be made public and communicated to workers in a language they understand via accessible channels.

Elements to Demonstrate Compliance to RBA Code

1. Policy

Ensure company's corporate responsibility policies include the following elements:

• a. An adequate and effective Code of Conduct covering all elements of the RBA Code is established.
• b. The Code of Conduct is endorsed by executive management.

2. Procedures & Practices

Procedures & Practices are in place such that:

• a. A Code of Conduct covering all elements of the RBA Code (Human Rights, Health and Safety, Environment, Ethics and Management Systems) is established.

NOTE: The words do not necessarily have to exactly match but are aligned to the principles of the RBA Code at a minimum.

• b. It also contains the following elements of
  • i. Due diligence
  • ii. Access to remedies for internal and external stakeholders where the participant caused or contributed to adverse human rights or environmental impacts.
  • iii. Continuous improvement
• c. The Code of Conduct is appropriate for the nature and scope of the facility's operations.
• d. The Code of Conduct is signed by company executive management.
• e. The Code of Conduct is communicated to workers via accessible channels in a language the workers understand.
• f. Senior management actively supports and ensures implementation of the Code of Conduct, including compliance with laws and regulations.

NOTE: If equivalent policies are used to endorse the RBA code, then they must contain all policy requirements in the RBA Code of Conduct

3. Controls & Monitoring

Controls & Monitoring should include:

• a. The Code of Conduct is reviewed annually by management and revised as needed.

4. Records

Records are maintained including:

• a. The Code of Conduct is made public.

3.0.0 (2024-01-01)

Changed

• Added a mandatory annual-review monitoring control for the Code of Conduct: 8.0.1 added a new Controls & Monitoring requirement that the Code of Conduct is reviewed annually by management and revised as needed. The 8.0.0 appendix E1 contained no annual-review requirement. A facility that passed 8.0.0 with a compliant, endorsed, public and communicated code but with no annual management review of that code could now fail 8.0.1 solely on this new mandatory monitoring control — a prior pass can become a fail, hence major.

2.0.0 (2023-09-01)

Changed

• Added mandatory due-diligence, access-to-remedy, public-disclosure and worker-communication code requirements: 8.0.0 added several new mandatory E1.1 conformance requirements absent in 7.1.2. The Record Review now mandates that the code commit to (i) Due diligence and (ii) Access to remedy for internal and external stakeholders for adverse human-rights or environmental impacts, plus new requirements that the code is made public and is communicated to workers via accessible channels in a language the workers understand, plus a Human Rights minimum-scope definition. A facility that passed 7.1.2 with an executive-endorsed RBA-covering code that did not explicitly commit to due diligence or access to remedy, or that was not made public, now fails 8.0.0 — a prior pass can become a fail, hence major.

1.1.0 (2022-06-01)

Changed

• Rating-table genericisation (no pass/fail effect): The 7.0.0 explicit Major/Minor rating bands (Major if two or more minimum-requirement elements missing, or no continuous-improvement/legal- compliance commitment, or >20% of workers unaware of the code; Minor if no senior endorsement, or one element missing, or <=20% unaware) were replaced by the generic "See finding severity definition" rubric for Priority/Major/Minor. No new mandatory conformance requirement was added — E1.1 still required a code covering all RBA elements with executive endorsement, appropriate for the nature and scope of operations. A reformatting with no demonstrable pass->fail flip, hence minor.

1.0.0 (2021-01-01)

Changed

• Initial historical baseline — Company Commitment (RBA Code of Conduct 7.0): Earliest imported version. Required corporate social and environmental responsibility policy statements affirming commitment to compliance and continual improvement, endorsed by executive management and posted in the facility in a language the workers understand. Adequate and effective policies/Code(s) covering Labor, Health & Safety, Environment and Ethics, endorsed by the highest-level manager, appropriate for the nature and scope of operations. Used explicit Major/Minor rating bands (Priority was Not Applicable for this criterion).