SUPPLIER CODE OF CONDUCT
Introduction
Aaron’s, LLC (“Aaron’s”) is committed to providing quality products and uncompromising service to our customers, and engaging in ethical business practices. This commitment extends to the suppliers with whom we chose to do business. Aaron’s expects the same level of honesty and integrity of its suppliers that it expects of its own employees. To clarify the exact nature of these expectations, Aaron’s has prepared this Supplier Code of Conduct (“Code”) which applies to all suppliers who are part of its supply chain. Compliance with this Code is expected for all suppliers as the actions of those with whom we do business may be attributed to Aaron’s and potentially adversely impact Aaron’s reputation. Suppliers are expected to take all appropriate steps necessary to ensure compliance with this Code. Suppliers are also expected to be familiar with the business practices of its own suppliers to ensure that they operate within the guidelines of this Code.
COMPLIANCE WITH LAWS AND REGULATIONS
Obeying the law is one of the foundations on which our ethical policies are built. Aaron’s suppliers are required to abide by all applicable national, state, provincial, regional, municipal, and local laws, codes, regulations, rules, ordinances, decrees, permits, registrations, and orders, as well as standards applicable to its particular industry. Suppliers are also expected to comply with the standards set forth in this Code. Suppliers shall actively assess and monitor their day-to-day management processes to ensure compliance with applicable laws, industry standards, and this Code. Supplier shall also ensure that its workers are advised of the requirements of this Code.
EMPLOYMENT PRACTICES
Aaron’s expects suppliers to respect its workers and to be in compliance with the specific requirements relating to employment and working conditions contained herein.
Fair compensation: Supplier will fairly compensate its workers, complying with the local and country laws and regulations governing wages and overtime payment for workers.
Working Hours: Supplier will comply with all applicable legal limits for working hours and days of service. Supplier will not permit its workers to work more than six consecutive days.
Child Labor: Aaron’s respects the right of children to development and education. Exploitation of child labor is totally unacceptable. All workers engaged in the production of products or provision of services for Aaron’s must be at least 16 years of age, or the age required by applicable law, if higher.
Forced Labor: The use of forced or involuntary labor will not be tolerated by Aaron’s. Supplier will comply with all labor laws and regulations regarding the fair and humane treatment of its workers and will not use forced, prison or indentured or involuntary labor of any type in the production of products or the provision of services for Aaron’s.
Human Trafficking: Supplier shall maintain and commit to maintaining a work environment that is free from human trafficking in the production of products for Aaron’s.
Non-discrimination, Harassment & Disciplinary Practice: Supplier’s workers must be employed, engaged, paid, promoted and terminated based on occupational ability and not based on personal characteristics or beliefs, such as race, national origin, sex, religion, ethnicity, disability, age and other characteristics protected by local law (excepting compliance with affirmative preferences that may be required by applicable law). Supplier will not tolerate or condone physical, sexual, psychological or verbal harassment or abuse of any supplier worker.
Health & Safety: Suppliers must provide their workers with a safe and healthy working environment, and where provided, a safe and healthy living environment. If supplier provides residential housing for its workers, supplier must ensure the housing is healthy and safe.
ENVIRONMENTAL
Suppliers shall comply with all applicable environmental laws and regulations. This shall include having processes in place to ensure compliance with those regulations relating to the handling, recycling, and disposal of dangerous or hazardous materials. Aaron’s favors suppliers that share its commitment to sustainable business practices.
SECURITY
Suppliers will maintain adequate security at all production and warehousing facilities and implement supply chain security procedures designed to prevent loss. Each supplier facility must have written security procedures to document adequate security controls.
PROTECTION OF PERSONAL INFORMATION
If applicable to the services/goods provided by supplier, supplier will protect the personal data of Aaron’s and any of Aaron’s customers to the extent that supplier is exposed to or comes into possession of such data, and will enact reasonable and generally accepted means of protecting such data from unauthorized exposure.
FCPA, ANTI-TRUST AND COMPETITION LAWS
Supplier shall abide by all applicable anticorruption regulations and laws of the countries in which it operates, including the Foreign Corrupt Practices Act (“FCPA”) and applicable international anti-corruption laws, rules and conventions. Supplier shall comply with all applicable laws that prohibit unlawful restraint of trade at all times designed to protect against unfair business practices and to promote competition including laws that prohibit agreements or activities that reduce competition, such as price fixing, bid rigging, boycott of specified suppliers or customers, market allocation or the limitation of product lines, sales or production for anticompetitive purposes. Supplier should restrain from discussions with competitors about prices, costs, profit margins, production volumes, bids, quotes, or specific customers. Deceptive practices are also prohibited such as making false or misleading statements and representations about products or services including Aaron’s products or services, as well as Aaron’s competitors and their products or services.
GIFT AND MEALS & ENTERTAINMENT POLICY
Aaron’s employees are prohibited from soliciting or accepting any gifts, gratuities or other monetary incentives that are designed to improperly influence business decisions or as a condition of doing business, and we expect our suppliers to adhere to these gift giving guidelines. Aaron’s recognizes that reasonable gifts, meals and entertainment with Aaron’s suppliers help build stronger relationships and reflect common social and business customs. There is nothing wrong with establishing good will and creating sound working relationships by giving gifts, but those activities must follow the guidelines set forth below in order to avoid even the appearance that we are receptive to being improperly influenced. Likewise, it is important to ensure that meals and entertainment are appropriate and are not excessive or abused in a way that might suggest that they are being used as an improper inducement. Gifts should never be offered, given, provided, or accepted by any Aaron’s employee unless they:
(a) Are not a cash gift;
(b) Are not solicited;
(c) Do not exceed $500.00 in value in any 12-month period from any one supplier;
(d) Are not tied to action or inaction on the part of the recipient or can otherwise be construed as a bribe, kickback or payoff;
(e) Are customary and would not cause embarrassment to Aaron’s if publicly disclosed; and
(f) Do not violate any laws or regulations. The supplier has an affirmative duty to report any such request or demand immediately to Aaron’s.
Like gifts, sharing meals with or entertaining Aaron’s suppliers helps to build business relationships, and there is nothing necessarily wrong with either. It is important to ensure that meals and entertainment are appropriate and are not excessive or abused in a way that might suggest that they are being used as an improper inducement. Providing and accepting meals and entertainment must meet the following criteria:
(a) Are not solicited;
(b) Are not tied to action or inaction on the part of the recipient or can otherwise be construed as a bribe, kickback or payoff;
(c) Are customary and would not cause embarrassment to Aaron’s if publicly disclosed; and
(d) Do not violate any laws or regulations.
CONFLICT MINERALS
Supplier will be compliant with Aaron’s Conflict Minerals Policy, if applicable (see below).
MONITORING OF THE CODE
Aaron’s will review this Code on a regular basis and will revise it to incorporate additional parameters when necessary. Suppliers are invited to contribute towards the further development of the Code. Aaron’s shall have the right to periodically audit and inspect suppliers and their facilities to verify compliance with this Code either directly or through a third-party. Suppliers are also required to disclose all material facts relating to production of products or provision of services for Aaron’s upon request. Any violations of this Code may cause Aaron’s to cease doing business with Supplier, especially in the event that a continuous and measurable improvement over time is not assessed. This Code is a general statement of Aaron’s expectations with respect to its suppliers. The Code should be read in conjunction with the supplier’s obligations set forth in any agreements between Aaron’s and the supplier. In the event of a conflict between this Code and any such agreement, the agreement shall control. Questions about this Code should be directed to:
Aaron’s, LLC
400 Galleria Pkwy SE
Suite 300
Atlanta, Georgia 30339
Attention: Director of Compliance & Privacy
legal@aarons.com
LAST UPDATED: October 19, 2020
AARON’S COMMITMENT TO THE USE OF CONFLICT-FREE MINERALS
Aaron’s, LLC supports efforts to further the humanitarian goal of ending the violence and human rights abuses in the mining of certain minerals in the Democratic Republic of Congo and surrounding countries (collectively, the “DRC”). We are committed to supporting legitimate commercial ventures in the region and to refraining from actions, directly or indirectly, which contribute to the financing of such conflict or the support of such abuses.
Aaron’s is fully committed to complying with applicable U.S. federal, state and local legislation, as well as, applicable regulatory requirements, intended to address these humanitarian and commercial concerns. Rules adopted by the U.S. Securities Exchange Commission (“SEC”), as required under the Dodd-Frank Act, impose disclosure and reporting requirements on the use of “conflict minerals” (tantalum, tin, tungsten and gold, or “3TGs”) in manufactured products, if such minerals originated in the DRC.
As a public company subject to these reporting requirements, we strive to increase transparency and ensure responsible procurement by our suppliers and sub-suppliers to ensure all components, parts and materials used to manufacture our products contain minerals from conflict-free sources. Aaron’s will not knowingly tolerate, or profit from, contribute to, assist or facilitate any activity that fuels conflict or encourages abuses of human rights.
We are committed to working with our suppliers to increase transparency regarding the origin and traceability of 3TGs contained in our products. We strive to ensure that all of our suppliers who provide us with components, parts or materials containing the 3TGs commit to conflict-free sourcing and develop policies and procedures to prevent the sourcing of 3TGs or their derivative metals from mines or smelters controlled by armed groups in the DRC. We expect our suppliers to comply with the OECD guidance and industry standards and to ensure that their supplier chain conforms to this policy and OECD guidance as well. We require our suppliers to document their efforts to determine the source of any conflict minerals (or derivatives) and to provide us with written evidence, reliable representations and certifications of such efforts. Specifically, we expect our suppliers to confirm to us that any 3TGs in components, parts or materials provided to us for use in our products are either sourced only from mines or smelters outside of the conflict region or from mines or smelters certified by an independent third party as “DRC conflict-free” if sourced within the DRC. We may request additional information of the supply chain when necessary.
We have incorporated the principles of this commitment into our Purchase Order procedures and documents. We aim to develop and maintain long-term relationships with our suppliers; however, if we identify a reasonable risk that a supplier is violating our policy or unwilling to comply with our policy, we will require them to implement a corrective action plan. We may also take other appropriate actions to transition the affected product to be “conflict-free.” Continued non-compliance by a supplier with our policy will result in termination of the relationship.