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Implemented: 3/12/2025
Revised:

A. Introduction

1. Objectives

Queen’s University (“Queen’s”) recognizes the critical role of its Suppliers¹ in maintaining ethical, sustainable, and socially responsible business practices throughout its supply chain. Queen’s Supplier Code of Conduct (“Code of Conduct”) serves as the foundation for promoting ethical behaviour, environmental stewardship, social responsibility, and integrity within Queen’s supply chain. The Code of Conduct objectives are to:

• Establish minimum conduct standards for Suppliers, with the expectation that they will surpass industry benchmarks and best practices.
• Foster proactive engagement and collaboration between Queen’s and its Suppliers to drive continuous improvement in ethical, social, and environmental performance.
• Enhance transparency, accountability, and trust among all stakeholders involved in Queen’s procurement and supply chain process.

This Code of Conduct is informed by the provisions of and is rooted in the principles of the . It also acknowledges the work of the and reinforces the Broader Public Sector (BPS) Supply Chain Code of Ethics as outlined in the and the university’s Procurement Policy. While this Code of Conduct reflects current standards and guidelines, it may be subject to future changes as policies and regulations evolve.

2. Scope

The Code of Conduct applies to all Suppliers.

Suppliers should not limit themselves to the standards and expectations outlined in this Code of Conduct. These represent a minimum engagement threshold, and Suppliers are encouraged to exceed these standards according to their contractual agreements and specific issues relating to their sphere of activity.

3. Expectation for Suppliers to Adopt the Code of Conduct

Suppliers are expected to fully embrace and adhere to the standards outlined in this Code of Conduct.

Suppliers shall undertake to support and cooperate in the implementation and verification of this Code of Conduct by:

• Informing their workers and subcontractors, both verbally and in writing, in a language they understand about the provisions of this Code of Conduct.
• Implementing and communicating procedures that allow employees to confidentially and anonymously raise and address workplace grievances without fear of reprisal or retaliation.
• Refraining from any disciplinary action, dismissal, or otherwise discriminating against any worker for providing information related to the observance of this Code of Conduct.

4. Compliance and Remediation

Queen’s expects all its Suppliers to meet or exceed the standards set forth in the Code of Conduct.

Queen’s is committed to collaborating with Suppliers to enable compliance as needed, however in instances of non-compliance, Queen’s reserves the right to implement corrective actions, which may include remediation measures or, if necessary, termination of the Supplier relationship.

Suppliers may not advertise or promote in any way that they are compliant with Queen’s Code of Conduct.

5. Limited Exceptions

In recognition of the fact that Queen’s Suppliers operate in a range of industries which may be governed by standards of conduct that differ from the Code of Conduct, Queen’s may, at its sole discretion, and where permitted by applicable law, provide limited exceptions to the Code of Conduct where a Supplier provides written justification to support the need for an exception. Suppliers should submit requests for exceptions in writing to Queen’s Strategic Procurement Services via email (buying@queensu.ca).

B. Supplier Code of Conduct

Standard #1: Ethical and Behavioural Standards

Suppliers shall at all times act with integrity and in an ethical manner, in accordance with applicable laws and regulations. Suppliers must abide by the following:

(a) Ensure fair wages – Suppliers shall pay employees at least the minimum wages required by local laws and provide employees, where  applicable, with a written accounting of hours worked, deductions and regular and overtime wages in a language understood by the worker.

(b) Ensure fair competition – Suppliers shall take all necessary steps to ensure healthy competition amongst subcontractors and sub-suppliers. Suppliers shall not share terms and conditions, bidding strategies, or other information that restricts free and open competition among companies and individuals.

(c) Ensure occupational health and safety – Suppliers shall comply with all applicable occupational health and safety laws and promote safe working practices for its employees. Where appropriate, Suppliers shall provide workers with adequate protective clothing and equipment to prevent, as far as can be reasonably practicable, adverse effects to health and safety.

(d) Conflicts of interest – Suppliers shall declare to Queen’s any actual or potential conflicts of interest that arise in the course of providing goods and services to Queen’s. Where a conflict of interest arises, it must be evaluated and an appropriate mitigating action must be taken.

(e) Avoidance of bribery and kickbacks – Suppliers shall not engage in any form of bribery or otherwise provide benefits to Queen’s employees or their family members in an attempt to influence or attain potential business opportunities with Queen’s.

Standard #2: Environmental Responsibility

Suppliers shall operate in an environmentally responsible and resource-efficient manner in accordance with applicable legislation, regulations and best practices. Suppliers should, wherever possible, proactively undertake initiatives to promote greater environmental responsibility within their own organization to:

(a) Reduce greenhouse gas consumption – Suppliers shall strive to reduce greenhouse gas emissions wherever possible. Suppliers should develop processes to monitor, measure and evaluate their emissions to contribute to Queen’s Net-Zero targets.

(b) Reduce waste – Suppliers shall have appropriate provisions in place to ensure the safe handling, storage, reuse or management of waste, wastewater and air emissions that protects the wellbeing of human health and biodiversity.

(c) Promote biodiversity and responsible resource management – Natural resources shall be used in an environmentally sustainable way including the avoidance of practices which contribute to deforestation and to refrain from conducting activity in areas that have high biodiversity value.

Standard #3: Social Responsibility

Suppliers shall at all times uphold the human rights of employees, communities and vulnerable populations. Suppliers must ensure the following:

(a) Human rights – Suppliers are expected to comply with all applicable human rights laws and uphold the central principle of anti-discrimination set out by the . Suppliers are also expected to adhere to Queen’s University’s Harassment and Discrimination Prevention and Response Policy. Suppliers shall continuously support human rights and must ensure they are not willfully or passively compliant in human rights violations. Where human rights violations are discovered, Suppliers must notify Queen’s and immediately seek to implement a substantive remedy. This notification is expected to be in writing and must include all information known at the time of discovery, along with the planned remediation. This information should be disclosed to Queen’s by submitting to Queen’s Strategic Procurement Services via email (buying@queens.ca).

(b) Prohibition of child labour – Suppliers shall not engage child labour² as that term is defined in section 2 of the Canadian Fighting Against Forced Labour and Child Labour in Supply Chains Act, as amended or replaced from time to time.  Where a child worker must be displaced, adult family members should have the opportunity to assume the child’s position to maintain family livelihoods.

(c) Prohibit all forms of forced/involuntary/indentured labour – Suppliers shall not engage forced labour³ as that term is defined in section 2 of the Canadian Fighting Against Forced Labour and Child Labour in Supply Chains Act, as amended or replaced from time to time. Suppliers shall not recruit or onboard employees in any way that contravenes applicable laws and regulations nor shall suppliers retain employees’ identity papers or passports.

(d) Freedom to associate – Suppliers shall recognize and respect that workers in Canada have the right to form or join trade unions of their own choosing and to collectively bargain.

(e) Promote supplier diversity – Suppliers shall engage socially and economically different categories of their suppliers and/or subcontractors through inclusive sourcing processes that promote equal opportunities. Suppliers should also encourage the same principles within their human resources in the recruitment and promotion of staff.

Standard #4: Animal Welfare

Suppliers whose operations or supply chains involve animals must adhere to best practices for animal welfare. They should ensure their activities align with the internationally recognized Five Freedoms for Animals:

i. Freedom from hunger and thirst
ii. Freedom from discomfort
iii. Freedom from pain, injury or disease
iv. Freedom to express normal behaviour
v. Freedom from fear and distress

Where local animal welfare laws and regulations differ from the Five Freedoms, the stricter requirements shall prevail and must be respected by Suppliers.