Human Rights Policy
I. Purpose
Centuri Group, Inc., and its subsidiaries (“Centuri” or the “Company” are committed to compliance with all US laws and regulations, including the prohibition against importing goods mined, produced, or manufactured wholly or in part by convict, indentured, or forced labor, which includes forced or indentured child labor (“forced labor”).
II. Scope
This policy applies to all Centuri entities in their dealings with suppliers and vendors.
III. Policy
The Company strictly prohibits the use of forced labor in its supply chain. It is the Company’s policy not to enter a business relationship with any manufacturers, suppliers, or other vendors (collectively, “suppliers”) that use or are suspected of using any form of forced labor, including in their own supply chains. The Company continuously assesses the risk of labor abuses in its supply chain and undertakes due diligence to ensure that its supply chain is free of forced labor.
If the Company suspects that a supplier or any of the supplier’s subcontractors or other business partners is using forced labor, the Company will immediately commence an investigation. If the Company concludes that forced labor is in fact being used at any point in the supply chain, the Company will, as it considers appropriate under the circumstances, either require the supplier to implement corrective measures that eliminate all forced labor in accordance with a corrective action plan acceptable to the Company, or immediately cease doing business with the supplier.
As part of our forced labor due diligence, it is the Company’s policy to:
- Vet new and existing suppliers for forced labor risks, through questionnaires, on-site inspections, and other means.
- Conduct audits, which may be announced or unannounced, of our suppliers’ operations, to be performed by Company personnel, third-party auditors, or both.
- Require our suppliers to agree in writing to adhere to our Supplier Code of Conduct, which requires our suppliers to:
- ensure that neither they nor their sub-contractors or other supply chain business partners use forced labor at any point in the production process;
- maintain a reliable system to verify the eligibility of all workers, including age eligibility and the legal status of foreign workers; and
- promptly report to us any violation of our Supplier Code of Conduct that the supplier becomes aware of, including the use of forced labor at any point in their own supply chain.
- Include terms and conditions in our contracts and purchase orders that:
- prohibit our suppliers from using of any form of forced labor, including in their own supply chains;
- require our suppliers to certify that merchandise sold to us was not produced or manufactured wholly or in part by forced labor;
- require our suppliers to cooperate with any investigation by the Company into the suspected use of forced labor by the supplier or any of its business partners; and
- allow the Company, on discovery of any use of forced labor, to immediately cancel the affected purchases and terminate the contractual relationship or require the supplier to take corrective action within a time frame set out in the terms and conditions.
Senior management is fully committed to ensuring that the Company sources any imported merchandise in compliance with all applicable laws and regulations and in a socially responsible manner. In furtherance of this commitment, senior management will ensure that sufficient resources are provided for the maintenance of internal controls and procedures to implement this policy. The Company’s management will also ensure that the Company’s employees receive sufficient training, appropriate to their responsibilities, to enable them to fulfill their obligations in accordance with this policy.
A. Maintenance and Implementation of Policy
The Corporate Compliance Office has primary responsibility for maintaining and implementing this policy and reviewing the Company’s forced labor due diligence measures to ensure they are functioning properly. The Corporate Compliance Officer will review the effectiveness of these procedures on a regular basis and will update the policy and procedures as necessary. Senior management will provide the Corporate Compliance Office with the necessary support to fully implement this policy and related procedures.
B. Distribution of Policy
The Corporate Compliance Office will distribute this policy to all employees as directed by the Company’s Corporate Compliance Officer. A copy of this policy will also be maintained on the Company’s intranet, CORE.
C. Training
Senior Management will ensure that all Company employees with environmental, social, and governance (ESG) responsibilities and responsibilities relating to the supply chain, including the acquisition and importation of merchandise from foreign suppliers, receive sufficient training to carry out this policy and ensure that the Company does not knowingly purchase or import any merchandise made wholly or in part by forced labor.
Our Corporate Compliance Officer is responsible for coordinating and conducting this training.
D. Employee Responsibilities
It is the responsibility of all Company employees to immediately report any allegations regarding the possible use of forced labor in the Company’s supply chain, either by phone through the Company’s EthicsPoint Helpline at 855-722-2816, online (www.Centuri.EthicsPoint.com), or by contacting the Corporate Compliance Officer at ComplianceOfficer@Centuri.com or 623-879-4293.
Any employee who becomes aware of any governmental inquiry or investigation regarding the possible use of forced labor in the Company’s supply chain must immediately notify the Legal Department.
Any employee who knowingly violates this policy is subject to appropriate disciplinary action, up to and including termination of employment.
E. Questions Concerning the Policy
Any questions concerning the Company’s policy on forced labor should be directed to the Corporate Compliance Office.
IV. Roles and Responsibilities
Employee
- Immediately report any suspected use of forced labor in the Company’s supply chain
Senior Management
- Provide resources and support for the implementation and maintenance of this policy
Corporate Compliance Officer
- Implement, maintain, and update policy as appropriate
- Distribute policy
- Answer questions regarding policy
- Investigate any reports of violations of policy