As you are well aware, Universal Parks & Resorts (UPR) partners with many reputable companies and their brands. Embedded in our contractual relationship with these companies is a requirement to protect their reputation and brand identity in the public record and with UPR guests.
Therefore, the NBCUniversal's (NBCU) Global Responsible Sourcing (GSR) program is not simply in place to protect the NBCUniversal brands but also to serve as a champion of all our partners' social compliance programs as well.
UPR is committed to unyielding integrity and high standards of business conduct in our dealings with suppliers. Our quest for competitive excellence begins and ends with our commitment to ethical conduct. UPR's Supplier Relationship Policy requires that we source only from suppliers who comply with local laws and any applicable NBCU standards in such sensitive areas as labor, environment, health, and safety.
As a vendor of UPR, your commitment to and compliance with high ethical standards is an essential and mandatory part of our business relationship.
As part of the NBCU family, UPR's supplier relationship policies require that UPR source only from suppliers who comply with local laws and any applicable NBCU standards in such sensitive areas as labor, environment, health, and safety.
NBCU is committed to the highest standards of social and environmental responsibility and ethical conduct, and UPR expects the same commitment to be shared by all vendors and manufacturers of UPR merchandise. Further, UPR requires that all manufacturers of UPR merchandise comply with all applicable national and local laws and regulations, including, but not limited to, those related to labor, immigration, health, safety, and the environment.
At a minimum, UPR requires that all manufacturers of UPR merchandise meet the following standards:
UPR manufacturers will not use child labor. Production facilities that employ individuals less than 16 years of age would be considered in violation of the GSR Code of Conduct and subject to immediate termination of the contract.
Student Worker Protections
The only potential exception to the Child Labor requirement is employment pursuant to a government-approved vocational workforce program that permits employees less than 16 years to work for educational credit on the condition that they are not exposed to potential health or safety hazards. Manufacturers shall ensure management of student workers through proper maintenance of student records, rigorous due diligence of educational partners, and protection of students' rights in accordance with applicable law and regulations.
Prevention of Involuntary Labor and Human Trafficking
All labor must be voluntary. Manufacturers will not use any forced, involuntary, prison, bonded or indentured labor and shall not engage in or support trafficking in human beings. Employees must be allowed to maintain control over their identity documents.
Each employee will be treated with respect and dignity and will not be subject to violence, punishment, or abuse.
Manufacturers will employ fair practices in hiring and other employment-related practices, including but not limited to terms of employment, salary, benefits, and advancement. Termination or other employment actions on the basis of race, religion, age, nationality, social or ethnic origin, gender, political opinion, or disability are prohibited.
Freedom of Association
Employees' rights to associate, organize, and bargain collectively will be respected by the manufacturer without penalty to employees.
Health & Safety
Manufacturers will provide employees with a safe and healthy workplace in compliance with all applicable laws and regulations. The same requirements will be met for employee housing that is provided for by the manufacturer. Manufacturers must take proactive measures to prevent workplace and housing hazards.
Compensation and Labor Hours
At minimum, manufacturers will comply with all applicable wage and working hour laws and regulations, including those relating to minimum wages, overtime, maximum hours and other elements of compensation, and will provide legally-mandated benefits. If local law does not require overtime pay, manufacturers will pay at least regular wages for overtime work. Manufacturers will be entitled to at least one day off in every seven-day period.
Protection of Environment
Manufacturers will comply with all applicable environmental laws and regulations including local and national codes, and all laws related to waste disposal, air emissions, discharges, toxic substances and hazardous waste disposal.
Manufacturers will not engage in corruption, extortion, embezzlement, or bribery. Manufacturers and any persons acting on their behalf, will not, directly or indirectly, give, offer, or authorize the offer of anything of value (such as money, gifts, business entertainment, meals, travel, discounts, jobs for relatives, charitable contributions, goods or services), regardless of the amount of value, to a supplier, customer or government official in order to obtain any improper advantage including but not limited to actions taken to obtain government-issued licenses and permits necessary for their operations. Manufacturers agree not to offer, pay, promise to pay, or authorize the payment of any money or anything of value to NBCUniversal auditors. Manufacturers will comply with all applicable anti-corruption laws and regulations of the countries in which they operate, the U.S. Foreign Corrupt Practices Act (FCPA), the U.K. Anti-Bribery Act, and applicable international anti-corruption conventions.
Audits, Compliance and Corrective Actions
Manufacturers will authorize NBCU and its designated partners (including third parties) to engage in audit and monitoring activities to review compliance with each element of this GSR Code of Conduct, including but not limited to, on-site inspections of manufacturing facilities and employee housing, review of records relating to employment, and the conduct of interviews with employees. Manufacturers are required to maintain all documentation to demonstrate compliance with this GSR Code of Conduct, and to have a process for timely correction of any deficiencies or violations identified by an internal or external audit, assessment, inspection, investigation, or review.
Manufacturers will not use subcontractors for the manufacture of UPR merchandise or components thereof without UPR's express, written, advance consent.
To minimize UPR's reputational risk, NBCUniversal auditors will conduct initial onsite due diligence at suppliers sites prior to contracts or purchase orders being issued. NBCU auditors will conduct periodic follow-up on site due diligence to determine continued adherence to local laws and applicable NBCU standards. UPR reserves the right of termination if a supplier's performance creates an unreasonable risk. While this program is designed to protect NBCU's assets against sourcing from sub-standard vendors & factories, UPR is committed to the organic growth of its business partners to achieve NBCU's high level of social responsibility for UPR's customers and stake holders. UPR's goal is not to reject factories until all potential solutions have been exhausted and a consensus between vested parties is reached.
Areas of coverage of the NBCUniversal audit checklist