Ethics and compliance

Business Partner Standard

Croxley seeks to establish mutually beneficial, sustainable relationships with its suppliers and vendors and prefers to work with business partners who share our values. The following Business Partner Standards define the minimum standards for Croxley business partners.

1. Employment Practices and Human Rights

Child Labour

Business partners shall not employ persons under the age of 14 or under the age for completing compulsory education or the minimum age for employment in their country, whichever is greatest.

Forced Labour

Business partners shall not use forced labour, including prison labour, bonded labor or indentured labour.

Prohibition of Discrimination, Harassment and Abuse

Business partners shall not discriminate based on personal characteristics or beliefs. Business partners shall treat every employee with respect and dignity, and shall not subject any employee to physical, verbal, sexual or psychological harassment or abuse, nor use physical violence or punishment as a form of discipline.


Business partners shall comply, at a minimum, with all applicable wage and hour laws, including those relating to minimum wages as applicable in their country. Additionally, business partners shall compensate employees for overtime hours at the applicable premium rate in their country. In countries with no overtime premium rate, employees shall not be paid at less than their regular hourly rate for overtime work.

Freedom of Association and Collective Bargaining

Business partners shall recognize and respect the right of employees to freedom of association. Further, business partners shall recognize the lawful rights of their employees to choose or not choose collective bargaining representation.

Safety and Health

Business partners shall comply with all applicable health and safety laws and regulations and provide a healthy and safe work environment, conducting operations in a manner designed to prevent injuries and illnesses. Where applicable, this also pertains to housing and eating facilities.

Hours of Work

Business partners will comply with all local laws and regulations regarding work hours. Generally, employees should not be required to work in excess of sixty hours in a week except due to unusual and infrequent business circumstances, and employees should have at least one day off each seven-day period.

2. Environment

Business partners are expected, at a minimum, to comply with all applicable environmental protection laws and regulations and are encouraged to exceed legal requirements to reduce their operations’ environmental impact.

3. Conflicts of Interest

Business partners should avoid situations where personal or other, non-business-related interests conflict or appear to conflict with the best interests of Croxley or otherwise cast doubt whether the decision is made objectively based on the business relationship. Conflicts of interest may arise when doing business with an entity that employs, is owned, in whole or part, by an Croxley associate or an associate’s close relative or someone with whom an associate has a close personal relationship.

4. Gifts and Entertainment

While gifts and entertainment can be an appropriate way to build goodwill and develop a business relationship, they also raise the potential for a conflict of interest or create the perception that a business decision is based on something other than service, quality, or price. As a result, Croxley associates may not accept gifts, unless the gift is unsolicited, nominal in value (less than $20 NZD), in line with local business practices, infrequent, and not in cash or cash equivalents. Meals, travel and entertainment are appropriate where unsolicited, infrequent, in the ordinary course of business, reasonable in value, in a setting that is appropriate and fitting for its business purpose, and attended by both the giver and recipient. In no case shall any gift, favour or entertainment be provided or accepted if it would obligate or appear to obligate the recipient.

5. Anti-Corruption

Croxley strictly complies with all applicable laws relating to anticorruption, fraud and bribery, including the Foreign Corrupt Practices Act. Business partners are expected to do so as well. Consistent with this commitment, gifts to government officials are prohibited.

6. Fair Competition

Suppliers must comply with all applicable laws and regulations regarding fair competition and antitrust.

7. Protection of Croxley Information

Croxley’s confidential and proprietary information such as its strategies, plans, technology, supply chain information, customers, financial information, and products is critical to Croxley’s business and success. Business partners shall safeguard Croxley’s confidential information.

8. Accuracy of Business Records

Business partners shall record and report information accurately and honestly.

9. Communication of These Standards

Business partners shall communicate these standards to their employees and business partners as is necessary to guarantee compliance.

10. Legal Compliance

Business partners must comply with all applicable laws.

11. Reporting and Monitoring

Business partners shall report to Croxley if they become aware of any instances of non-compliance with these Standards and then develop and put in place steps necessary to correct them. Further, Croxley reserves the right to monitor and audit compliance, including conducting inspections through independent third-parties.

12. Doing the Right Thing

Croxley expects its associates and its business partners to do the right thing every time. Business partners are expected to meet the letter and spirit of these Standards. Non-compliance may cause Croxley to terminate the business relationship.

Read about our Sustainability Policy.

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