Code of Conduct
Overview

FLTR, Inc. (“FLTR”) is a fast-paced, vibrant, and design-centric organization supplying personal protective equipment (PPE) to the largest retailers in the world. Our mission is to make effective PPE widely available and help contain the crisis through our retail product lines, charitable giving initiatives, and consumer education. We develop highly effective and creative products and are building a world class organization with significant brand presence. Our Suppliers are critical to our success and it is important that our Suppliers share the same values of ensuring safe workplaces that respect the fundamental rights of all employees and operates with the highest standard of quality, business transparency, and ethics.

This Code of Conduct provides specific requirements for FLTR suppliers to follow. These standards are based on local and national laws and/or regulations, the International Labor Organization’s Core Conventions, and other relevant international standards. The list is not all encompassing and FLTR will adhere to other standards as identified in Industrial Audit standards, such as the Sedex Members Ethical Trade Audits (SMETA) or Amfori’s Business Social Compliance Initiative (BSCI). FLTR will conduct audits of its Suppliers using either internal Compliance staff and / or independent third-party auditing companies or will accept audit reports from internationally recognized third-party industrial audit standards to qualify its Suppliers.

Supply Chains are becoming increasingly complex and it is critical that companies improve visibility of their production and drive improvements throughout their Supply Chain. FLTR requires transparency and reliability with our Factories and we work with our Suppliers on continuous improvement of their business practices. For any violations discovered during a Supplier audit, rather than penalizing the Supplier in a way that may cause hardship to workers and their families who depend upon the Supplier for employment, FLTR works on corrective and preventative action plans to drive improvements with that Supplier.

Definitions

Applicable Laws means all national, provincial, state, local, or international laws and regulations that apply in the country of manufacture, including but not limited employment, health and safety, and environmental regulations.

 

Code means this Supplier Code of Conduct.


Employee means any employee, laborer, worker, or staff member employed or contracted by the Supplier. This includes all foreign

or migrant workers, whether employed directly or through an agency, and any service agency providing services to Supplier.

Factory means any entity that produces, or processes finished goods or components sold to FLTR. The Factory may be owned or contracted by the Supplier.

Finished Goods means all goods that have finished the manufacturing process but have not yet been sold. These goods are generally described on the FLTR purchase order.

Home Worker means any individual who performs services related to the manufacturing process or production of merchandise from his or her home or premises other than the Supplier.

Major Components means any finished good that may be subsequently packed as part of a separate kit.

Migrant Worker specifically means a class of Employee who is a domestic or foreign migrant worker, whether employed directly or through an agency, imported into the area or country of production. Special employment rules shall apply specifically for Migrant Workers. Domestic migrant workers move within different areas within the same country. Foreign migrant workers move between countries.

Supplier means all entities contracted to provide products to FLTR, including non-manufacturing Suppliers to which purchase orders may be issued, manufacturing facilities of finished goods or major finished good components, assembly, packing, and shipping facilities, and printing companies.

Unauthorized Subcontracting means the assigning, delegating, or transferring any portion of a Purchase Order to another Supplier without full disclosure and consent of FLTR. This does not refer to subcontracting of minor production processes.

Zero Tolerance means violations that are prohibited. All Zero Tolerance violations must cease immediately, and Suppliers must provide a detailed Corrective Action Plan (CAP) to address the violations.

General Requirements

Suppliers are responsible for ensuring compliance to this Code throughout their organization. The Code applies to all workers in every work site and dormitory facility. All workers must be informed about their rights and entitlements under both local law and the Code.

 

Business Transparency & Ethics

FLTR Suppliers are expected to be open, honest, and straightforward with regards to their business operations. Suppliers are expected to openly share real information related to their performance, operations, policies and procedures, hiring, and payroll for the purposes of Ethical Sourcing (ES) audits of their facility. Suppliers are also expected to operate in an ethical manner, whether in straightforward and honest dealings with their customers or in the treatment of its workers.

  • Supplier shall have management systems, policies, procedures, and practices in place to comply with this Code. Supplier shall maintain accurate documentation at all times and make that information available to auditors as required.

  • All Suppliers engaged in production of major components and finished goods for FLTR are required to be disclosed and approved by FLTR. Failure to do so is a Zero Tolerance violation for Unauthorized Subcontracting.

  • All forms of bribery, corruption, deception, and falsification of records are strictly prohibited. Any such finding may result in the termination of the business relationship. FLTR employees are prohibited from accepting gratuities from Suppliers. Gratuities include gifts, moneys, trips, meals, lodging, or special favors.

     

Zero Tolerance (ZT) Violations

 

FLTR considers certain situations to be unacceptable under any circumstances. These Zero Tolerance violations must cease immediately and addressed fully by the Supplier. Some examples of the ZT violations in this document are:

  • Denial of Access (Auditor)

  • Falsification of Records

  • Attempted Bribery

  • Child Labor

  • Forced Labor (forced, indentured or prison labor)

  • Debt Bondage

  • Workplace Violence / Harassment

  • Locked or Systematically Blocked Emergency Exits

  • Unauthorized Subcontracting

  • Unauthorized Home Working

 

Consequences of Code Violations

If a Zero Tolerance (ZT) violation is found at any FLTR facility, all orders are put on hold until a review has been completed. Within 48 hours of notification to the Supplier of a ZT violation, a detailed Corrective Action Plan (CAP) addressing all violations shall be submitted to FLTR for review and approval. The CAP must include a timeline for rectifying the ZT violations. FLTR will approve or reject the CAP at its own discretion. Rejection of the CAP may result in termination of the business relationship with the Supplier.

 

Other Violations

Within 48 hours of notification to the other violations, a detailed Corrective Action Plan (CAP) addressing all violations shall be submitted to FLTR for review and approval. The CAP must include a timeline for rectifying the violations. FLTR then works with the Supplier on addressing the violations over a reasonable time frame until full compliance is achieved. If continuous improvement and eventual full compliance are not achieved within a reasonable time frame, FLTR may terminate the business relationship with the supplier.

 

Audit Requirements

FLTR reserves the right to audit or authorize a third-party to audit any Supplier that participates in the production of FLTR products. In some cases, FLTR Customers will require their own audits of FLTR Suppliers. Such audits may include any Subcontractor used by the Supplier and may occur with or without advance notice.

  • Supplier’s management shall provide access to the Factory and all books and records that will allow for a comprehensive Code of Conduct audit to be conducted, including an opportunity for confidential and private interviews with Employees selected by the auditor. Prior coaching of interviewees is not allowed, nor is any retaliation against any Employee or auditor.

  • Supplier must maintain documentation necessary to verify compliance with the Code and all Applicable Laws. Supplier must be transparent and provide real documents to FLTR personnel or third-party auditors, including but not limited to licenses, permits, certifications, policies and procedures, employee contracts, employee wage records, and other facility records.

     

Hiring & Responsible Recruitment

 

Hiring

Supplier shall follow all Applicable Laws related to the hiring of employees. The Employees legal status shall be verified, and Employees shall be provided a written Employment Contract, in their local language, outlining the terms of employment.

  • At time of hiring, all employees shall be of at least fifteen (15) years of age, or legal age as established by local law if higher than fifteen. Official and verifiable documentation of each employee’s date of birth shall be maintained in the employee’s file (Zero Tolerance). Suppliers shall have a system in place to report and remediate cases of child labor.

  • Employees under the age of eighteen (18) are considered juvenile workers. Suppliers are required to follow all Applicable Laws related to juvenile workers, including that they shall not perform hazardous work that may jeopardize their health or safety.

  • Pregnancy or HIV test, or birth control, shall not be required as a condition of employment.

     

Responsible Recruitment

Suppliers shall only use legally recognized employment agencies with a current license, to hire foreign migrant workers. Supplier shall have a written contract with the employment agency incorporating all the principles of responsible recruitment, including the prohibition of the foreign migrant worker paid recruitment fees and related costs. Suppliers must ensure that all foreign migrant workers are in the country legally and have valid work permits.

  • Supplier shall pay all fees related to the hiring of migrant workers. Foreign migrant workers shall not pay any fees, whether to the Supplier or any employment agency, in their home country or destination country, for the purpose of being hired or as a condition of employment. No deposits may be held by the Supplier or the employment agency. If it is discovered that the migrant worker has paid recruitment fees, these fees are to be reimbursed by the Supplier within a reasonable time.

  • Employees shall be provided with an Employment Contract in their home country, in their local language, that outlines all the terms of employment. Contracts shall specify rights with regards to payment of wages, work hours and overtime, annual and sick leave, medical insurance and benefits, retention of identify documents, specific job responsibilities, housing and accommodation provided, and other such issues related to their employment. This contract must be signed before the Employee leaves their home area or country. Terms of the Employment Contract signed in the home area or country cannot be changed in the destination area or country without the expressed written consent of both parties.

  • Employees shall maintain possession and control of their personal identity, passport, or travel documents. In some cases, lockers should be provided to the migrant workers to store their documentation.

  • Employees’ freedom of movement shall not be restricted. Migrant workers shall not be subject to threats of termination or deportation. Migrant workers shall be free to return to their home area or country, in accordance with Applicable Law. Suppliers shall ensure the safe return of foreign migrant workers at the expiry of the worker’s contract.

 

Terminations

Employee terminations must be in full compliance of all Applicable Laws and copies of the termination records must be maintained for a minimum of one (1) year.

Final payment to terminated Employees must be completed within the appropriate time frame per Applicable Law.

Wages & Compensation
Wages & Benefits

Supplier shall maintain accurate payroll and production records to ensure that Employee wages can be accurately calculated. An appropriate time-keeping system shall be in place that is impervious to manipulation.

  • Employees shall be paid at least the legal minimum wage. All overtime hours worked by the Employee must be paid in accordance with Applicable Law. Employees shall receive all legally required benefits as per Applicable Law.

  • Wages shall be paid a minimum of monthly. Wages shall be paid directly to the Employee, whether in person or to an Employee controlled account, and the employee shall receive an itemized wage statement, in their local language, indicating the pay period, wages earned for the pay period, rate of pay for regular and overtime hours, and any deductions required by law or for Employee benefits. There should be no late payment of wages.

  • Unless allowed by Applicable Law, there should be no deductions. Suppliers shall not withhold or engage in illegal deductions or deposits, particularly as a means of punishment, to recover costs associated with the recruitment process, or to prevent Employees from leaving their employment.

Working Hours

Suppliers shall maintain complete and accurate time records. No time records shall be changed without the Employee’s written verification.

  • Employees combined regular and overtime hours shall not exceed sixty (60) hours per week. All overtime hours must be voluntary, and Supplier must maintain sufficient records to show Employee’s approval of overtime prior to their shift. Employees must be allowed to refuse overtime without punishment, penalty, or disciplinary action.

  • Employees shall be informed of overtime policies and processes prior to employment. All overtime is voluntary on the part of the Employee.

  • Employees shall receive rest breaks during and between shifts as required by Applicable Law. For vulnerable categories, such as pregnant workers, juvenile workers, elderly or disabled workers), Supplier will provide appropriate breaks as required by Applicable Law.

  • At least one day off for every 7 working days is required for all Employees, including office staff, production workers, security staff, cleaning staff, and canteen staff.

Fair & Ethical Treatment of Workers

All employees shall work on a voluntary basis and not subject to any form of exploitation.

  • All employees should be treated with dignity and respect. Harassment of any kind, whether physical, sexual, verbal abuse, mental abuse, coercion or threats, corporal punishment, or other such abuses, is strictly prohibited (Zero Tolerance).

  • Supplier shall have established written policies to address and prevent workplace violence. Suppliers should communicate the policy to all personnel in the workplace.

  • Supplier shall have written disciplinary policies and procedures and shall maintain records of any disciplinary actions for all employees. Monetary fines are prohibited.

  • Supplier should establish written policies governing freedom of association and collective bargaining. Employees shall be allowed to join trade unions or worker organizations of their choosing and participate in collective bargaining. Suppliers must consult with Employees through trade unions or other elected representatives when making workplace decisions that may seriously affect the Employees.

  • Supplier shall establish and participate in a functional grievance syst

  • em for persons who may be negatively impacted by their business practices. The grievance mechanism should include a defined process for receiving, assessing, investigating, and resolving grievances. It should include anonymous channels for reporting, confidentiality for victims, and a no-retaliation policy to protect Employees who report grievances.

Health & Safety
  • Suppliers shall maintain applicable building and construction permits, licenses, and / or certifications. Supplier must obtain an occupancy certificate from the local fire service / authority which must be updated if alterations occur to the structure(s) (e.g. erection of roof structures or extensions, conversion of building use, etc.).

  • Uniforms and appropriate personal protective equipment (PPE), if required, shall be provided at no cost to Employees. Personal protective equipment includes, but is not limited to face masks, eye protection, gloves, welding masks, hard hats, safety shoes, insulated clothing, and hearing protection.

  • Employees shall have unlimited and free access to toilet facilities. Adequate and clean toilet and hand-washing facilities shall be provided with running water and necessary supplies (i.e. toilet paper, soap, and drying facilities). Such facilities shall be well-lighted, ventilated, separated by gender, and each toilet shall have a privacy door. Housekeeping procedures shall be documented and kept available for review.

  • Employees shall have unlimited and free access to safe, potable drinking water. Suppliers shall conduct water quality tests for drinking water annually, or more frequently if required by Applicable Law.

  • Suppliers shall maintain and monitor lighting and noise levels, as required by law. Where lightening and / or noise levels depart from the legal limit, Suppliers shall comply with legally required remedial action (e.g., PPE, and soundproofing).

Emergency Preparedness

Suppliers shall train all employees in basic fire and emergency preparedness per local law and maintain a log of the training.

  • Suppliers shall assign emergency response personnel (e.g. first aid manager) that are certified and / or trained, and responsible for management of emergency and health and safety policies and procedures. Emergency response personnel shall be present at every shift, and easily identifiable by all employees in the event of an emergency.

  • Suppliers shall conduct evacuation drills (for fires and natural disasters) at least once every six months for all shifts and floors, including dormitories, and maintain documentation of the two most recent evacuation drills.

  • Emergency exits shall be clearly marked, free of any obstructions, unlocked and provided with signs understood by all Employees. Emergency exits shall open in the direction of travel with a single release. A minimum of two exits or exit doors shall be provided on every floor or any space greater than 450 m2 (or according to local law, whichever is more stringent) and be placed a distance apart, equal to or not less than 1⁄2 of the length of the maximum overall diagonal dimension of the building.

  • Suppliers shall ensure that emergency exists are unblocked and not locked at any time (Zero Tolerance). Systematic blocking of emergency exists and emergency exit routes by production materials or machinery is also considered a Zero Tolerance violation.

  • Emergency exit routes shall be clearly marked with direction of travel, free of any obstructions and well-lighted. Emergency exit routes shall lead to a safe assembly area. Emergency evacuation plans shall be posted along emergency exit pathways and entrances to stairs. Evacuation plans shall be accessible, shall have pictures or diagrams that reflect the facility’s layout accurately and contain the accurate location of the assembly point as well as a “You Are Here” mark. Evacuation plans should be in all languages understood by the employees.

  • Manual or automatic emergency alarm system shall be present in production, distribution and living areas. Manually operated emergency alarm shall be designated, accessible and clearly visible. Alarms shall have notification lighting in areas where the noise level is observed to be above ambient. Alarm signs shall be in any languages understood by employees or provided through pictures or diagrams. The emergency alarm system shall be tested annually by an approved contractor, or more frequently if required by law.

First Aid

Suppliers shall have first aid kits with sufficient and unexpired supplies (including basic supplies such as bandages, pain relievers, anti-bacterial ointment, tourniquets, tape, etc.). Supplies must be accessible to all employees during all working hours.

  • There shall be an adequate number of employees trained for first aid for all shifts. Suppliers shall provide and maintain first aid training records.

  • Suppliers shall have qualified medical professionals to administer medical care, as required by law. Suppliers shall provide accurate qualification records for all professionals.

  • Suppliers shall have a clinic and maintain complete medical records, as required by law.

  • The Supplier shall maintain a document with emergency procedures and numbers in the event of injury or accidents at each first aid location. Suppliers shall report, investigate, and maintain records of employee and facility accidents, as required by law.

  • Eye-wash stations and/or chemical showers shall be provided when required by law

 
Fire Safety

Suppliers shall have a valid fire license or acceptance letter from the local fire service authority and have it available for review.

  • Fire extinguishers shall be present, mounted, the appropriate type and size for the type of production, clearly marked, free of any obstructions, and be inspected monthly.

  • Flammable and combustible materials should be stored in a safe location with proper controls and appropriate warning signs (e.g. “No Smoking” Signs).

  • Suppliers shall maintain all legally required fire suppression systems, such as sprinklers or fire hydrants. Fire suppression systems shall have quarterly inspection tags and be inspected annually by a licensed third-party, or more often as required by law.

  • Where applicable, Suppliers shall maintain adequate water supply for fire suppression systems. The water supply shall be stored in a suction tank, elevated tank, or reservoir. Suppliers should monitor and inspect water supply level monthly for sufficiency.

     

Electrical Safety

Electrical panels, wiring, and outlets shall be inspected at least monthly, and shall not be damaged, have exposed wires, or pose a trip or electrocution hazard. All electrical outlets must have inner covers.

  • Electrical panels shall be labeled with proper signage, in any language used by Employees, mentioning electrical warnings and maximum voltage handled. To prevent overloading, extension cords shall not be used instead of wall outlets for permanent electrical installations.

  • Suppliers shall provide electrical safety equipment to employees working around high voltage electrical hazards, including electrical safety matting, insulated tools, etc.

  • Supplier shall train employees on the importance of wearing proper protective clothing (including proper footwear) and use of specialized equipment to protect against electrical hazards.

  • Suppliers should have a certified electrician (with a valid license) to perform all electrical work at the factory and its related facilities (dormitory, canteen, and childcare). Suppliers shall keep an up-to-date copy of the certified electrician’s license.

  • A lightning protection system (LPS) shall be installed in the premises as protection from lightning strikes.

Chemical Safety

Suppliers shall establish and implement a policy governing the correct identification, labeling, maintenance, storage, use, of chemicals and / or hazardous materials, including Emergency Management Systems (EMS). Suppliers shall train employees at all levels on how to follow and implement the supplier's chemicals and hazardous materials policy.

  • Suppliers shall provide specialized training to relevant employees on how to safely handle chemicals and hazardous materials. Only trained and authorized employees shall handle chemicals and hazardous materials.

  • Suppliers shall maintain complete Material Safety Data Sheets (MSDS) in compliance with established policies and procedures. Suppliers shall post MSDS in chemical use or storage areas in a language(s) understood by all employees.

  • A functioning eyewash station shall be present and located at proper distance, as required according to MSDS. Chemical showers shall be present for facilities where employees risk partial or full body contact with chemicals.

  • Suppliers shall store hazardous materials in a safe and secure manner. Hazardous materials should be stored separately from the production area and other facilitates (e.g. childcare, dormitories and canteen), away from sources of ignition and emergency exit pathways, in a separate/ designated chemical storage area. Suppliers shall have a secondary containment system (considering 110% of actual volume) in place in case of chemical spills.

     

Machine Safety

Suppliers should maintain and keep current all necessary permits, licenses and / or certifications, as applicable, for forklifts, boilers, generators, lifts (elevators), compressors, industrial refrigerators, and other such machinery.

  • Suppliers shall also maintain copies of valid operator licenses for employees or contractors responsible for operating heavy machinery.

  • Suppliers shall establish a policy governing identification and maintenance of safety guards and emergency stops for machinery. Supplier is to track and record the ongoing maintenance plan of each machine.

  • Suppliers shall communicate and train employees at all levels on the Supplier's equipment safety policy.

  • Suppliers shall maintain emergency safety equipment and inspection records, specifically for forklifts, boilers, generators, lifts (elevators), compressors, and industrial refrigerators. Emergency safety equipment should be regularly inspected to ensure proper functioning.

Environmental Protection

Suppliers must fully comply with all local environmental laws and regulations and shall conduct their operations in a way that conserves natural resources. All waste materials and production by-products must be disposed of legally and in an environmentally responsible manner. Suppliers shall establish an environmental management system that ensures compliance with Applicable Laws and mitigates the environmental impact of their operations. It should address chemical, waste, wastewater, air and noise pollution, and other significant environmental impacts.

  • Supplier shall maintain all required environmental permits, licenses, approvals, and/or certifications (e.g.Environmental Impact Assessment) and their operational and reporting requirements are to be followed.

  • Chemical and other materials posing a hazard if released to the environment are to be identified and managed to ensure their safe handling, movement, storage, recycling or reuse and disposal. Records of hazardous materials disposition shall be maintained.

  • Waste water and solid waste generated from operations, industrial processes and sanitation facilities are to be monitored, controlled, and treated as required prior to discharge or disposal. Records of effluent monitoring shall be retained for comparison to permitted discharge levels.

  • Air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting chemicals and combustion by-products generated from operations are to be characterized, monitored, controlled, and treated as required prior to discharge. Records of air monitoring shall be retained for comparison to permitted emission levels.

Dormitory, Childcare & Canteen Facilities

Suppliers shall maintain accurate, valid, up-to-date dormitory, childcare, and canteen health and safety permits, licenses and / or certifications, and facilities as required by law.

 

  • Dormitories, childcare facilities, and canteens shall be in an area separate from production, storage, and distribution areas, shall maintain clean / sanitary conditions (e.g. no open sewage, vermin, or insects), and shall comply with all Applicable Laws.

  • Emergency precautions for fire extinguishers, emergency alarms, emergency exits and lighting, evacuation pathways and plans, training drills, electrical safety guidelines, and first aid kit shall equally apply at the dormitory, canteen, and childcare facilities. The emergency alarm system shall be tested annually by an approved contractor.

  • Dormitoriesshallprovidepersonalstoragewithlocksforsafekeepingtodormitoryoccupants.

  • Suppliers shall ensure there is sufficient space for occupants in dormitories and avoid over-crowding. The estimated number of persons in dormitory or dormitory rooms shall be in accordance with local regulations and shall not exceed the number reported by Supplier or maximum occupancy posted near entrance.

  • Employees in dormitories shall have access to sanitary food preparation or eating areas, potable water, hot water, toilets and sleeping quarters segregated by gender.

  • Sleeping areas for unmarried Employees shall be separated by gender.

  • Employees shall be free to leave the Facility grounds during non-working hours. Where curfews apply and are allowed by law, Employees shall be notified of the curfew and instructed on safety risks in and around Employee housing. Foreign or migrant Employees shall not be subject to lock-in / lock-out policies.

Quality Systems

Quality is of utmost importance to FLTR as our Customers rely on us providing the utmost in quality that has been tested to all applicable standards. All Suppliers will undergo a Good Manufacturing Process (GMP) audit following internationally recognized quality standards. FLTR will also look for Suppliers that have or can pass ISO 13485:2016, the Medical Devices – Quality Management System audit.

Suppliers shall implement a comprehensive Quality Management System (QMS) that formalizes and documents processes, procedures, and responsibilities for achieving quality policies and objectives. The policy must coordinate and direct the Supplier’s activities to meet customer and regulatory requirements and improve its effectiveness and efficiency on a continual basis. The Quality Management System should include, at a minimum, the following areas:

  • Quality Objectives

  • Quality Manual

  • Organization Structure and Responsibilities

  • Design Controls

  • Material Controls

  • Production & Process Controls

  • Records, Documents and Change Controls

  • Corrective and Preventative Actions

  • Facility and Equipment Controls

  • Product Testing & Validation

FLTR will place its own Quality Control personnel in every Factory to help monitor both production and the Factory’s Quality Management System to ensure the proper procedures are followed and maintained. The QC personnel will also conduct inline inspections and testing, following AQL standards, and work with the factory on any non-conformances discovered. The FLTR Quality Control team does not replace the Factory’s own Quality team but is an extra level of assurance that proper QC processes are being followed.

Before the launch of any new product, and at a minimum of an annual basis, every major product will undergo independent third- party testing to the appropriate standard(s) in the country or countries of sale. Samples for testing will be pulled randomly from the Factory and send to the third-party lab for full testing. Suppliers are expected to comply with all requests for true production samples, that will be pulled by the FLTR Quality Control staff and sent to the lab for testing. Products will not be sold in any market until an appropriate passing test report is achieved, and each product will undergo a minimum of an annual test to re-confirm conformance.

Should the test result in any non-conformances, the Supplier will need to complete a detailed Corrective Action Plan (CAP), including a root cause analysis of the non-conformance, and submit it to FLTR Quality Control for review and approval. The CAP must include a timeline for rectifying the non-conformance. FLTR then works with the Supplier on addressing the non- conformance over a reasonable time frame until it is resolved. Once resolved, new production samples will be pulled, and the product will be retested.

Security (CTPAT/AEO)

Suppliers are to implement basic security measures based on the Customs-Trade Partnership Against Terrorism (CTPAT) security guidelines issued by the US Customs and Border Protection Agency (CBP) and the Authorized Economic Operators (AEO) guidelines issued by the European Commission

Supplier should have all security procedures documented and applicable personnel trained in those procedures, including but not limited to:

  • Personnel Security – Hiring Policies

  • Personnel Security – Business Partner Requirements

  • Physical Security – Access Controls

  • Physical Security – Facility Access

  • Procedural Security - Documentation

  • Procedural Security – Risk Assessments

  • Procedural Security – Conveyance Security

  • Procedural Security – Seal Control

  • Training & Security Awareness

  • Cybersecurity

  • Information Technology Security

Additional Assistance

It is important to FLTR that our Suppliers understand the Code of Conduct and implement the appropriate policies and procedures to be compliant with the Code. For any additional questions, please email Compliance@fltr.com.

Updated October 2020.