Vendor Code of Conduct

When Alex Lee, Inc. was founded in 1931 by Alex and Lee George established a culture focused on doing what is best for its customers, employees, and vendor partners. Today, Alex Lee, Inc. and its affiliates (“Alex Lee”) continue to maintain that culture through establishment of and adherence to the nine values below (“Values”). These Values actively live throughout the Alex Lee organization and dictate our operations and business decisions.

Accountability: We accept responsibility for actions and consequences.

Profitability: Profits are essential to our survival and growth.

Family: We believe in the importance of family relationships.

Excellence: We demand excellence in our services, products, and relationships.

Frugality: We manage our resources carefully and deploy them with economy.

Innovation: We continually improve the services and products offered and the means to deliver them.

Integrity: Integrity is imperative in all dealings with customers, employees, suppliers, and others.

Communication: We encourage and require constant and clear communication among all members of our organization.

Respect: We respect every individual we encounter whether employee, customer, supplier, or stranger, including diverse points of view.

To continue to promote the Alex Lee mission, we expect our business partners to share in our Values. This Vendor Code of Conduct (“Code”) is designed to guide vendors, suppliers, business partners, and any other parties with whom Alex Lee does business (collectively, “Vendors”) in upholding the high standards and strong Values espoused by Alex Lee. By signing a contract, providing goods or services, or accepting a purchase order, each Vendor acknowledges, accepts, and agrees to remain compliant with this Code throughout their business relationship with Alex Lee. Vendors are responsible for the activities of any agents or subcontractors acting on their behalf in provision of goods or services and are expected to hold such subcontractors to the same or similar standards they hold themselves. Non-compliance with this Code may result in consequences up to and including termination of the relationship, at the sole discretion of Alex Lee. Alex Lee reserves the right to audit Vendors at any time to ensure compliance with this Code. Additional Alex Lee policies, contracts, or requirements may be applicable for all or certain types of relationships, as determined by Alex Lee.

1. Compliance with laws. We expect Vendors to operate in compliance with all applicable local, state, federal, and international laws and regulations of any country in which the Vendor does business including without limitation trade, export, and anti-trust laws (“Applicable Laws”). All products and services provided to Alex Lee must comply with Applicable Laws and appropriate industry standards and guidelines. Vendors shall obtain all licenses, permits, certifications, and registrations that are required to provide their products or services and maintain the same throughout the relationship with Alex Lee. Vendors are expected to comply with contractual agreements and all Alex Lee policies, procedures, and other expectations as provided by Alex Lee from time to time (“Requirements”). In the event this Code or other Requirements demand more than that mandated by Applicable Law, Vendors must follow the Code and/or Requirements.


2. Human Rights & Labor. Alex Lee believes that all employees deserve dignity, respect, fair treatment, a healthy working environment, and freedom of expression. Our goal is to provide an environment where employees feel fulfilled, appreciated, and adequately rewarded for their work. To maintain the foregoing, Vendors are expected to comply with the following:
   
   
   1. Underage Labor / Fair Treatment. Further, Vendor will not employ any individual under the age of 18 for work which by its nature or the circumstances in which it is carried out is likely to jeopardize the health or safety of such persons under the age of 18. Vendors will not use any form of involuntary labor, including without limitation that which is forced, coerced, bonded, exploited, or trafficked. Vendors will not partner with any third party known to engage in any such practices or any third party that the Vendor reasonably should have known was engaging in such practices.
   
   
   2. Workplace. Vendors must comply with all Applicable Laws regarding working hours, benefits, wages, freedom of association, and nondiscrimination and must verify employment eligibility (in the applicable country) for all workers to ensure workers are authorized to work. Vendors are expected to comply with the following:
      
      
      1. Wages/Benefits. Wages and benefits provided to workers must satisfy legally mandated minimums required by Applicable Laws.
      
      
      2. Working Hours. Vendors must adhere to all Applicable Laws regarding hours worked by personnel, including without limitation regular work hours, overtime, vacation, holidays, and periods of leave.
      
      
      3. Freedom of Association. Where legally authorized, Vendors shall respect their employees’ rights to join or form unions and to collectively bargain, or to conduct similar activities.
      
      
      4. Nondiscrimination/Harassment. Unlawful harassment, including but not limited to sexual harassment, racial harassment, gender-based harassment, or harassment based on any other legally protected status in the workplace will not be tolerated. Vendors will provide a workplace that is free from abuse and harassment. Vendors will not discriminate against workers in employment or hiring practices on the basis of race, gender, sexual orientation, age, disability, nationality, or other protected status. Vendors should establish a mechanism for personnel to report, including anonymously, any discriminatory or harassing conduct in the workplace and Vendors should take all reasonable steps to investigate and remedy, as appropriate, any such reports. Vendors will not retaliate against employees or other personnel who report discrimination, harassment, or any other violations of law or ethical concerns.
      
      
   3. Safety. Vendors must provide a safe, clean, and healthy working environment in accordance with Applicable Laws and relevant industry standards. This includes but is not limited to establishing procedures ensuring appropriate maintenance, monitoring, training, inspection, and safety measures (including emergency preparedness) for prevention of hazardous, unsafe, or unhealthy conditions that may result in accident or injury. Vendors should also establish procedures whereby personnel can report, including anonymously, any unsafe working conditions and promptly remedy any such unsafe working conditions upon actual or reasonable notice.
      
      
3. Anti-Bribery & Anti-Corruption.
   Alex Lee will not tolerate corruption, extortion, or any unlawful, unethical, or fraudulent activity. We expect Vendors to maintain the highest ethical standards of behavior. Vendors must adhere to Applicable Laws regarding anti-bribery, anti-trust, and anti-corruption, including but not limited to the United States Foreign Corrupt Practices Act. Vendors must not accept or offer money, services, or anything else of value to any person (including any government agency or official) intended to improperly influence business dealings or otherwise obtain or retain an improper advantage.
   
   
4. Food Safety.
   We feed people, and we choose to do so with products and services that are responsibly and safely sourced and produced, while maintaining affordability and selection for our customers and guests. Food safety and quality are our top priority, and we expect Vendors to comply with the following:
   
   
   1. Product Safety & Compliance. All products supplied to Alex Lee must be fully compliant with Applicable Laws and meet any applicable industry standards, contractual obligations, and Alex Lee quality and safety requirements. Vendors must implement appropriate systems to monitor product quality and prevent safety hazards and product issues. Vendors must supply relevant and up-to-date food safety certifications to Alex Lee upon request. Vendors must immediately report any issues with product quality or safety to Alex Lee including any and all voluntary or mandatory product recalls, withdrawals, and removals. Vendors shall cooperate with Alex Lee and applicable supervisory authorities in implementing appropriate actions and remediation efforts regarding any product issues or recalls.
   
   
   2. Labeling. Vendors’ products must include clear and accurate labels and descriptions, which are in compliance with Applicable Laws. Vendors must confirm that all labeling meets necessary regulatory guidelines and industry standards for such labeling including but not limited to product and ingredient quality, processing, and packaging standards.
   
   
5. Ethical Standards.
   Integrity is one of Alex Lee’s key values, and we expect our Vendors to maintain policies and controls to uphold the highest ethical standards of behavior in business practices and operations including adhering to the following:
   
   
   1. Conflicts of Interest. Vendors must not engage in activities intending or appearing to create a conflict of interest or improperly influence Alex Lee employees. Conflicts of interest include but are not limited to relationships that may compromise or appear to compromise the integrity, impartiality, or judgment of Alex Lee employees in performance of their job duties. Vendors must disclose to Alex Lee any current or potential relationship or circumstances that may cause or appear to cause a conflict of interest. Cash payments, bribes, business gifts, or entertainment of more than a token value are strictly prohibited.
   
   
   2. Confidentiality / Data Security. During the course of the business relationship, Vendors may have access to information that Alex Lee considers proprietary or confidential which includes but is not limited to pricing, product details, financial information, customer information, and employee information. Vendors will not use or disclose confidential or proprietary information without prior written consent from Alex Lee. In certain circumstances, Vendors may be required to execute a nondisclosure or confidentiality agreement with Alex Lee. Vendors must promptly notify Alex Lee immediately of any unauthorized use or disclosure of confidential or proprietary information. Vendors must ensure that adequate safeguards are in place to prohibit the unauthorized use or disclosure of confidential or proprietary information of Alex Lee and Vendors will make themselves reasonably available for a risk assessment regarding all measures Vendors have in place to safeguard Alex Lee confidential or proprietary information. Vendors must also comply with all applicable privacy and data protection laws and regulations.
   
   
6. Environmental & Sustainability Standards.
   We seek to be good stewards of our environment and protect our resources for future generations. Vendors should manage and minimize their environmental impact by taking appropriate actions within their areas of operation and complying with the following:
   
   
   1. Environmental Responsibility. Vendors must adhere to all Applicable Laws relating to the environment and protection thereof (including without limitation those regulations and guidelines set forth by the Environmental Protection Agency, the United States Department of Agriculture, the Food and Drug Administration, and the Federal Trade Commission) in their business operations. Vendors are expected to have procedures in place for managing wastewater, waste disposal, air emissions, and hazardous materials.
   
   
   2. Animal Welfare. Vendors engaged in the raising, handling, transportation, or processing of animals must adhere to all Applicable Laws in production and operations.
   
   
   3. Product Claims & Certifications. Vendors must provide products that include adequate instructions for use and consumption, accompanied by the necessary disclaimers and disclosures. All products with certifiable or regulated product claims must have appropriate and up-to-date documentation and support, each of which is available to Alex Lee upon request.

We continue to evaluate our Code of Conduct, and these guidelines are subject to change. The Code is available for your review at any time on this page. Vendors may be required to periodically review and reconfirm their commitment to these expectations, as requested by Alex Lee.

Violations or suspected violations to this Code may be reported to the Alex Lee Legal Department at AlexLeeLegal@alexlee.com.