This Vendor Code of Conduct (this “Code”) applies to all vendors who provide goods or services (“Vendors”) to Tractor Supply Company, or to any of its subsidiaries or affiliates (“Tractor Supply Company”). Vendors must be committed to the highest standards of ethical conduct in their business practices. This Code sets forth the basic requirements that all Vendors must comply with in order to do business with Tractor Supply Company. If Tractor Supply Company believes that any Vendor has violated this Code, Tractor Supply Company has the right to terminate its business relationship with the Vendor and to proceed to secure any and all rights or remedies available. Tractor Supply Company reserves the right to make reasonable changes to the requirements of this Code, and the latest version of this Code can be found on Tractor Supply Company websites and vendor portals.
a. Compliance with Laws and Tractor Supply Company Policies: Vendors must fully comply with all applicable laws, regulations, and with Tractor Supply Company policies published on its vendor portals, including but not limited to, the Human Rights Policy and the Conflict Minerals Policy. To the extent that Tractor Supply Company policies impose a higher standard than what is required by any applicable law or regulation, Tractor Supply Company policies shall prevail.
b. Conflicts-of-Interest: Vendors shall not engage in any activity which could create either the appearance of, or an actual conflict-of-interest, between the personal interests of Tractor Supply Company associates or their immediate family members and Tractor Supply Company interests.
c. Gifts and Benefits: Tractor Supply Company prohibits Vendors from giving gifts or entertainment exceeding nominal value to Tractor Supply Company associates or their immediate family members. “Nominal value” is defined as $50.00 or less. Tractor Supply Company associates must obtain prior written approval before receiving any gift, entertainment, favor or payment in excess of $50. The following types of gifts and entertainment may never be offered, regardless of value: cash or cash equivalents (i.e. gift cards); gifts that are or could be illegal; gifts or entertainment (including meals, transportation and travel accommodations) offered in connection with an inspection, audit, or during a bidding process involving the Vendor, or anything offered to an agent or consultant working on behalf of Tractor Supply Company in connection with an inspection, audit, or bidding process involving the Vendor. This policy remains in effect during traditional gift-giving seasons.
d. Former Tractor Supply Company Associates: For a period of one year following separation, Tractor Supply Company will not conduct business with a former Tractor Supply Company employee operating on Vendor’s behalf if the business relates to an area in which the former employee worked or had influence while employed by Tractor Supply Company.
e. Sourcing: Tractor Supply Company encourages all Vendors supplying goods and services to Tractor Supply Company, its stores or facilities, to share Tractor Supply Company’s commitment, where possible, to utilizing small, woman, minority,veteran, disability, and/or LGBTQ-owned businesses for subcontracting opportunities in connection with Tractor Supply Company contracts.
f. Conflict Minerals: Vendors shall avoid using columbite-tantalite (tantalum), cassiterite (tin), wolframite (tungsten) or gold, determined by the Secretary of State to be financing conflict in the Democratic Republic of the Congo or an adjoining country (“Conflict Minerals”) in any products that are sold to Tractor Supply Company. To comply with this obligation, Vendors shall conduct due diligence, maintain records, and provide Tractor Supply Companywith verification of the source of the materials used in any products, as well as any additional relevant information at Tractor Supply Company’s request.
g. Anti-Corruption: Vendors must not tolerate, permit, sanction, or engage in bribery, corruption or unethical practices whether in dealings with public officials, or individuals in the private sector. Vendors must comply with all applicable anti-corruption laws and regulations, including the United States Foreign Corrupt Practices Act (“FCPA”), in connection with the provision of any goods or services to Tractor Supply Company.
h. Subcontracting: In the event that Vendors are permitted to use subcontractors in accordance withthe terms of any agreement with Tractor Supply Company, Vendors shall ensure that any such subcontractors comply with this Code in connection with providing goods or services to Tractor Supply Company. Vendors shall not retain any subcontractor that fails to comply with this Code.
i. Confidential Information: Vendors must respect and protect Tractor Supply Company intellectual property rights, and maintain the confidentiality and security of any information entrusted to them by Tractor Supply Company or its customers, unless otherwise expressly permitted by the terms of any agreement with Tractor Supply Company.
j. Information Privacy and Security: Vendors must protect information security with proper technical, physical, and administrative measures. Vendors are expected to respect and protect the information privacy of individuals whose personal information is entrusted to them, directly or indirectly, by these individuals or by Tractor Supply Company. Vendors may only use, retain, and disclose entrusted information for the purpose of conducting business with Tractor Supply Company or as otherwise permitted by Tractor Supply Company. Vendors must comply with all applicable privacy and data security laws.
k. Fair Dealing: Vendors must not manipulate, conceal, or misrepresent facts, misuse information, or otherwise act illegally, unfairly, dishonestly or unethically.
l. Fair Competition: Vendors must adhere to any applicable fair competition laws prohibiting activities that restrain trade and create anticompetitive markets
a. Forced Labor: Vendors shall not use any form of forced, bonded, indentured, trafficked, slave, or prison labor. All work must be voluntary, and workers shall be free to leave work or to terminate their employment. Vendors must not require workers to surrender any government-issued identification, passport, or work permit as a condition of employment.
b. Child Labor: Child labor is strictly prohibited. Vendors shall hire workers who meet at least the legally specified minimum age for employment, or the minimum age for completing compulsory education in the country where any product is manufactured or where any service is rendered, whichever is higher. No worker may be hired under the age of 16.
c. Working Hours: Working hours are not to exceed the maximum set by local law. Further, Vendors shall limit workers’ working hours to sixty (60) per week, including overtime, except for emergencies or extraordinary circumstances. Workers shall be allowed at least one (1) day off every seven (7) days.
d. Employment Practices: Vendors must have hiring practices that accurately verify a worker’s legitimate eligibility to work.
e. Compensation: Vendors shall pay all workers at least the minimum wage and benefits required by any applicable laws and regulations. Workers shall also be compensated for overtime hours at the rate required by any applicable laws and regulations.
f. Freedom of Association: Vendors must respect the rights of all employees to lawfully associate, or not to associate, with groups of their choosing, as long as such groups are permitted by law. Vendors shall not unlawfully interfere with, obstruct, or prevent lawful employee associations and any related activities.
g. Non-Discrimination: Vendors shall follow all applicable laws and regulations and shall prohibit discrimination or harassment on the basis of sex, race, color, religion, national origin, age, disability, marital status, gender identity, gender expression, or sexual orientation. All Vendors are expected to maintain a working environment free from discrimination or harassment.
h. Diversity and Inclusion: Tractor Supply Company expects Vendors to foster a culture and working environment that value and respect worker diversity and inclusivity.
i. Fair Treatment: Vendors are expected to maintain a working environment free from harassment and abuse. No form of physical, sexual, psychological or verbal abuse or harassment shall be tolerated.
j. Health and Safety: Vendors shall provide all workers with a safe work environment, appropriate personal protective equipment, workplace health and safety information, and relevant health and safety training.
k. Working Conditions: Vendors shall provide all workers with access to clean toilets and potable water. Vendors shall also provide workers with access to sanitary food preparation, storage, and dining areas. If Vendors provide worker dormitories or other housing, these locations must be clean and safe while allowing entry and exit privileges for those housed.
a. Environmental Permits: Vendors shall obtain and comply with all required environmental permits, including any regular reporting obligations.
b. Water Management: Vendors shall implement a thorough water management process that identifies and monitors water sources, uses and conservation opportunities. Vendors shall also monitor and control wastewater and discharge.
c. Waste Management: Vendors shall implement a thorough waste management process that identifies, monitors, and reduces sources of solid waste while prioritizing recycling where possible.
d. Energy Efficiency: Vendors shall monitor energy consumption and should look to maximize energy efficiency while reducing consumption and greenhouse gas emissions wherever possible.
e. Emissions Management: Vendors shall implement a thorough process to monitor, control and treat hazardous air emissions.
f. Hazardous Chemicals: Vendors shall implement a thorough process to identify, label, and manage hazardous chemicals in order to ensure their safe storage, use, and disposal.
g. Restricted Materials: Vendors shall implement a thorough process to comply with all applicable laws, regulations, and Tractor Supply Company requirements in order to restrict or prohibit the use of specific materials in the manufacture, labelling or packaging of any products.
a. Monitoring and Enforcement: Tractor Supply Company, whether acting by itself or through a third party, will take affirmative measures such as inspections and audits to ensure compliance with this Code. Vendors must maintain all documentation to demonstrate compliance with this Code and shall make such documentation available to Tractor Supply Company or a Tractor Supply Company authorized third-party agent upon request.
b. Management Systems: Vendors shall implement management systems that facilitate compliance with this Code and any applicable laws and regulations, identify and mitigate risks relating to this Code, and which facilitate continuous improvement.
c. Whistleblower Protection and Non-Retaliation: Vendors shall create programs to ensure the protection of worker whistleblower confidentiality, and to prohibit retaliation against workers who participate in such programs in good faith, or who refuse an order that violates this Code. Vendors shall provide an anonymous complaint mechanism for workers to report any workplace grievances or Code violations in accordance with any applicable laws and regulations. Violations of this Code can be reported confidentially and in a local language. Please contact Tractor Supply Company through one of the following channels: Vendor may report concerns to the General Counsel and/or the Vice President of Internal Audit or anonymously to the Tractor Supply Company Out Here Hotline. The Out Here Hotline may be accessed at www.reportlineweb.com/TSC (from anywhere in the world) or by calling 1-877-888-0002 (from U.S. only).