Fathm Supplier Code of Conduct

Background and Introduction

Fathm’s Supplier Code of Conduct is an essential part of our supplier procurement process. It helps us make sure that the ethics and values we uphold as a company are shared by our suppliers so that we don’t engage with suppliers that may cause damage to our company, our planet, or the people that are part of our global community.

This Code applies to people and companies (collectively, “Suppliers”) that do business with Fathm Ltd. Suppliers, including their workforce, contractors, and subcontractors, are expected to comply with all aspects of this Code that are relevant to their business, or be working towards compliance. We also ask our Suppliers to be working to ensure their own supply chain adheres to these principles.

When there is a difference between a local law and our Supplier Code of Conduct, the law must always be upheld however we seek to apply the higher standard.

As a responsible business, we aim to be an example for others and hold ourselves to the same standards that we ask of our Suppliers.

Suppliers and other relevant external stakeholders can submit any questions or report any violation or grievance to Fathm by emailing: admin@fathm.co

Retaliation of any kind against those reporting a good faith concern about improper business conduct will not be tolerated and suppliers are required to provide details of grievance channels to all workers and ensure this Code of Conduct is freely available.


Commitment: Suppliers will have an environmental policy that includes actively reducing emissions and other adverse effects from their operations on community, environment, and natural resources, whilst safeguarding health and safety.

1. Environmental Permits and Reporting

All required environmental permits, approvals, and registrations will be obtained, maintained, and kept current and their operational and reporting requirements will be followed.

2. Pollution Prevention and Resource Reduction

Emissions and discharges of pollutants and generation of waste are to be minimised or eliminated. 

The use of natural resources, including water, fossil fuels, minerals, and virgin forest products, is to be conserved by practices such as modifying activities, changing maintenance and facility processes, materials substitution, re-use, conservation, recycling, or other means.

3. Energy Consumption and Greenhouse Gas Emissions

Suppliers are to establish an organisation-wide greenhouse gas reduction goal ensuring energy consumption and all greenhouse gas emissions are tracked, documented, and reported against the greenhouse gas reduction goal.

4. Hazardous Substances

Chemicals, waste, and other materials posing a hazard to humans or the environment are to be identified, labelled, and managed in accordance with applicable laws and standards to ensure their safe handling, movement, storage, use, recycling or reuse and disposal.

5. Solid Waste

Suppliers will implement a systematic approach to identify, manage, reduce, and responsibly dispose of or recycle solid waste (non-hazardous).

6. Air Emissions

Air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting substances, and combustion byproducts generated from operations are to be identified, monitored, controlled, and treated as required prior to discharge. 

Ozone depleting substances are to be effectively managed in accordance with the Montreal Protocol and applicable regulations. 

7. Materials Restrictions

Suppliers will adhere to all applicable laws and regulations and customer requirements regarding prohibition or restrictions of specific substances in products and manufacturing, including labelling for recycling and disposal.

8. Water Management

Suppliers will implement a water management program that documents, characterises, and monitors water sources, use and discharge; seeks opportunities to conserve water; and controls channels of contamination prior to discharge or disposal.

9. Recycling

Suppliers will identify and implement organisation-wide strategies to increase recycling including during manufacturing, through purchasing, at equipment end of life, and at the post-consumer stage.

10. Premises

Suppliers will actively seek to improve the environmental profile of premises to reduce any negative impact on the environment.

11. Transport

Through strategic planning of purchasing and vehicle use, adoption of clearer alternative fuels, and promotion of environmentally friendly transport alternatives to the workforce, Suppliers will reduce the environmental impact of transport activities.


Commitment: Suppliers will conduct their businesses in accordance with applicable laws and regulations and with a commitment to attaining the highest standards of ethical behaviour.

1. Business Integrity

Suppliers will not take unfair advantage of Fathm, or anyone else, through abuse of privileged or proprietary information, misrepresentation of material facts, or any other unfair or dishonest practises.

Suppliers will not engage in collusive bidding, price fixing, price discrimination or other unfair trade practices in violation of antitrust laws.

2. Bribery, Kickbacks and Fraud

Suppliers will maintain the highest standards of integrity including a zero-tolerance policy that strictly prohibits any and all forms of bribery, corruption, extortion and embezzlement.

No funds or assets of the supplier shall be paid, loaned or otherwise disbursed as bribes, “kickbacks”, or other payments designed to influence or compromise the conduct of Fathm, its employees or representatives.

3. Charitable Contributions

Fathm’s choice of supplier is not influenced by a supplier giving or not giving to any particular charity and Fathm does not solicit charitable donations from other companies or suppliers. 

4. Other Conflicts of Interest

Where a director, employee, agent, or other representative of one party identifies that an individual they have a family or close relationship with is a director, employee, agent, or representative of the other party, this information will be disclosed at the earliest opportunity and any actual or perceived conflict of interest will be addressed.

5. Disclosure of Information

All business dealings should be transparently performed and accurately reflected on suppliers’ business books and records. Information regarding workforce, health and safety, environmental practises, business activities, structure, financial situation, and performance is to be disclosed in accordance with applicable regulations and prevailing industry practises.. 

6. Intellectual Property

Intellectual property rights are to be respected; transfer of technology and know-how is to be done in a manner that protects intellectual property rights. 

8. Privacy

Suppliers will commit to meeting legal requirements for protecting personal information of everyone they do business with and to meeting their reasonable privacy expectations. This includes, but is not limited to, suppliers, customers, consumers, and workforce.

9. Information Security

Suppliers will comply with information security laws and regulations and take all necessary steps to ensure data security.

10. Protection of Identity and Non-Retaliation programs

Programmes that ensure the confidentiality, anonymity and protection of suppliers and employee whistleblowers are to be maintained, unless prohibited by law.

11. Responsible Minerals Sourcing

Suppliers will adopt a policy and exercise due diligence to ensure minerals in their supply chains originating from conflict-affected and high-risk areas (CAHRAs) do not directly or indirectly finance or benefit armed violence or contribute to human rights abuses.

Workforce Rights and Practises

Commitment: Suppliers will ensure workforce rights are upheld and protected and that workplace practices are ethical.

Fathm’s supplier Code of Conduct adheres to the key principles of the International Labour Organization’s (ILO) ten fundamental conventions:

    1. Freedom of Association and Protection of the Right to Organise Convention
    2. Right to Organise and Collective Bargaining Convention
    3. Forced Labour Convention
    4. Abolition of Forced Labour Convention
    5. Minimum Age Convention
    6. Worst Forms of Child Labour Convention
    7. Equal Remuneration Convention
    8. Discrimination (Employment and Occupation)
    9. Occupational Safety and Health Convention
    10. Promotional Framework for Occupational Safety and Health Convention

    In accordance with the ILO fundamental conventions, suppliers will commit to uphold human rights of all workers and treat them with dignity and respect. Suppliers will also respect the rights of vulnerable groups particularly relevant to their industry, including, for example, women and migrants.

    1. Freely Chosen Employment

    Suppliers will not use forced, bonded, or indentured labour, involuntary or exploitative prison labour, slavery, or trafficking of persons.

    Identification and immigration documents will not be unlawfully withheld, destroyed, concealed, confiscated or denied.. 

    Workers will not be required to pay employers’ or agents’ recruitment fees or other related fees.

    2. Young Workers

    • Child: any person under the age of 15, or under the age for completing compulsory education, or under the minimum age for employment in the country, whichever is greatest. 
    • Young Worker: any person under the age of 18 who does not meet the definition of ‘child’.

    Suppliers will not use child labour and will verify the age of young workers to ensure they are above the minimum age of employment. 

    Workers under 18 will not perform work that is likely to jeopardise their health and safety, including night shifts and overtime.

    Suppliers will ensure proper management, support, and training of young workers and protection of their rights in accordance with applicable laws and regulations.

    3. Working Hours

    A standard work week (one without overtime) must not exceed 48 hours. All overtime must be voluntary meaning workers must be given a choice about whether to undertake overtime.

    Working hours will include the minimum breaks and rest periods set by law. Workers will be allowed at least one day off every seven days.

    4. Working and Living Conditions

    Working, and living (if applicable), conditions must meet, at a minimum, standards set by local law and workers must not face any undue health or safety risks from working or living conditions.

    5. Humane Treatment

    Suppliers will not subject or threaten workers to inhumane treatment, including violence, gender-based violence, sexual harassment, sexual abuse, corporal punishment, mental or physical coercion, bullying, public shaming, or verbal abuse; nor is there to be the threat of such treatment. 

    Suppliers will clearly define and communicate disciplinary policies and procedures in support of these requirements to the workforce.

    6. Wages and Benefits

    Compensation paid to workers will comply with all applicable wage laws and regulations, including those relating to minimum wages, overtime hours and legally mandated benefits and workers will be compensated for overtime at pay rates greater than regular hourly rates. 

    Deductions from wages as a disciplinary measure will not be permitted. 

    Workers will be provided with a timely and understandable wage statement that includes sufficient information to verify accurate compensation for work performed and workers will be informed of all deductions from their pay.

    All workers will be paid equally for work of equal value, regardless of gender or any other characteristic.

    Suppliers will ensure workers earn enough to meet their basic needs by providing a living wage.

    7. Non-Discrimination

    Suppliers must commit to a workforce free of harassment and discrimination and will not engage in or permit discrimination or harassment based on race, color, age, gender, sexual orientation, gender identity and expression, ethnicity, national origin, disability, pregnancy, religion, political affiliation, union membership, covered veteran status, protected genetic information, or marital status.

    Workers or potential workers will not be subjected to medical tests or physical exams that could be used in a discriminatory way.

    8. Freedom of Association

    Suppliers will respect the right of workers to form and join trade unions of their own choosing, to bargain collectively, to engage in peaceful assembly, and to choose to refrain from such activities. 

    Suppliers will ensure workers can pursue alternative forms of organising (e.g., worker councils or worker-management dialogues) where there are regulatory constraints on freedom of association.

    Workers and/or their representative will be able to openly communicate and share ideas and concerns with management regarding working conditions and management practices without fear of discrimination, reprisal, intimidation, or harassment.

    Health and Safety and Emergency Preparedness

    Commitment: Suppliers will minimise injury and illness to achieve a safe and healthy work environment and workers will be encouraged to raise any health and safety concerns without being disciplined or subject to any form of retaliation.

    1. Occupational Safety

    Worker exposure to potential safety hazards is to be identified, assessed, and mitigated.

    Reasonable steps will be taken to remove or reduce workplace health and safety risks to pregnant women and nursing mothers, and including reasonable accommodations for nursing mothers. 

    2. Emergency Preparedness

    Potential emergency situations and events are to be identified and assessed, and their impact minimised by implementing emergency plans and response procedures.

    Emergency plans should include appropriate fire detection and suppression equipment, a sufficient number of clear and unobstructed exit routes, contact information for emergency responders, and recovery plans that consider the wider impact of the event on the community and the environment.

    3. Occupational Injury and Illness

    Suppliers will put in place procedures and systems to prevent, manage, track and report occupational injury and illness. This includes provisions to: encourage worker reporting, classify and record injury and illness cases, provide necessary medical treatment, investigate cases and implement corrective actions to eliminate their causes, and facilitate return of workers to work.

    4. Industrial Hygiene

    Suppliers will identify, evaluate, and control worker exposure to chemical, biological, and physical agents. Potential hazards are to be eliminated, controlled, or reduced.

    When hazards cannot be adequately controlled, workers are to be provided with and use appropriate, well-maintained, personal protective equipment free of charge. 

    5. Physically Demanding Work

    Worker exposure to physically demanding tasks, including manual material handling and heavy lifting, prolonged standing and highly repetitive or forceful assembly tasks is to be identified, evaluated and controlled

    6. Machine Safety

    Production and other machinery will be evaluated for safety hazards and suppliers will provide and properly maintain physical guards, interlocks, and barriers for hazards in machinery used by workers.

    7. Sanitation, Food, and Housing

    Workers are to be provided with ready access to clean toilet facilities, potable water, and sanitary food preparation, storage, and eating facilities. 

    Worker accommodation will be clean and safe, providing workers with hot water for bathing and showering, adequate lighting, heat and ventilation, individually secured accommodations for storing personal and valuable items, and reasonable personal space along with reasonable entry and exit privileges.

    8. Health and Safety Training and Communication

    Suppliers will provide workers with appropriate and accessible workplace health and safety information and training, both at the beginning of work and regularly thereafter, for all identified workplace hazards that workers are exposed to.

    Health and safety related information will be clearly posted in the facility or placed in a location identifiable and accessible by workers. 

    How we will implement our Supplier Code of Conduct during the procurement process – including measuring compliance and implementation.

    We have created a Supplier Code of Conduct Questionnaire to use alongside this document to help us make decisions about which Suppliers to work with during our procurement process. In some instances we may ask Suppliers or potential Suppliers to complete the questionnaire, or we may undertake this on our Suppliers behalf using information obtained from public sources and from the Supplier directly.

    You can view our Questionnaire as follows:

    Supplier Questionnaire

    – Small Supplier Questionnaire

    The information we gather through the Supplier Code of Conduct Questionnaire will be used alongside the other information we need to make an informed decision about our Supplier. Our Supplier Procurement Policy provides more details.

    We don’t expect all elements of this Code of Conduct to be applicable to the business and operations of all our Suppliers and we don’t expect all Suppliers to have achieved full compliance across all areas – we recognise that environmental targets in particular are a work in progress for many at this time. 

    We do however expect our suppliers to be 100% legally compliant in all their activities and to be actively working towards compliance across all other areas with at least 50% compliance either achieved or in progress for every category.