Human Rights Policy

HUMAN RIGHTS POLICY

OUR COMMITMENT

Bug Bam Products LLC., its affiliates and subsidiaries, (collectively “Bug Bam”, “we”, “us” or “our”) are committed to respecting and promoting internationally recognized human rights principles throughout our global enterprise. As such, we have a long-standing commitment to ethical and responsible conduct in all our operations, to improve the quality of life in the communities we serve, and to respect the human rights of all people. This policy is aligned with our values and our aspiration to make the world greater, together.

We are committed to the principles set forth in the UN Guiding Principles (UNGP) on Business and Human Rights, the Universal Declaration of Human Rights (UDHR), the International Covenant on Civil and Political Rights (ICCPR), the International Covenant on Economic, Social, and Cultural Rights (ICESCR), and the International Labor Organization’s (ILO) Declaration on Fundamental Principles and Rights at Work.

Through proactive due diligence aligned with the UNGP on Business and Human Rights, we seek to avoid adverse human rights impacts and complicity in the adverse impacts caused by others. We are committed to effective remedies, if we cause or contribute to an adverse impact. This commitment extends to collaborating with others to find solutions and not obstructing access to other remedies that reduce human rights impacts. Our ongoing work is to embed human rights considerations in all relevant business decisions. This commitment applies globally to our own operations, our products, and our business relationships, including our supply chain. In addition, we will continue to look for ways to promote and advance human rights within our sphere of influence.

OUR AREAS OF IMPACT

We have three priority areas of impact:

Our Employees
Our employees around the world deserve to be treated with respect and dignity and we share that responsibility individually and collectively. Employees are required to complete Bug Bam Code of Conduct and Ethics training annually to ensure their understanding of our commitment and expectations.

Bug Bam requires employees and management who have direct responsibility in Supplier Compliance to take annual trainings. The training topics are focused on issues and concerns pertaining to the supply chain, including human trafficking and slavery, with a focus on mitigating risks.
Our Supply Chain Partners
We have a responsibility to respect the human rights of people who help make our products. Our commitment applies not only to our workforce but also to the businesses we contract with around the world in our supply chain. We strive to ensure that human rights are upheld for all workers involved in our supply chain, and that those individuals experience safe, fair and non-discriminatory working conditions. We do not tolerate any human rights abuses, including but not limited to, human trafficking, child labor, and forced labor. We expect that our business partners will share this commitment.

Through Manufacturing Agreements, we outline the guiding principles and set standards of workplace conduct for the factories that produce our products. Areas of focus include the following topics: Child Labor, Involuntary Labor, Coercion and Harassment, Nondiscrimination, Association, Health and Safety, Compensation, Hours of Work, Protection of the Environment and other applicable areas of concern. We implement our human rights commitment and enforce it through our factory audits, training and remediation.

We evaluate our supplier’s compliance with the Manufacturer Code through audits conducted by Bug Bam employees and/or third-party compliance auditing firms.

As part of our risk assessment, we require completion of a factory self-assessment of all potential Tier 1 and Tier 2 component suppliers. We evaluate the responses and determine if follow-up questions are needed. A manufacturer’s geographic location, the nature of its manufacturing activities and anticipated production output are included in our evaluation of the risk of the supplier.

Supplier and Bug Bam employees that feel ethical standards in business may have been compromised can call in to Bug Bam, which allows for anonymous submissions. Reports received through the hotlines are reviewed and investigated, as appropriate, and remedial actions are taken as necessary.
Our Customers
Bug Bam seeks to respect the human rights of our customers in all countries where we do business. Our main focus areas include: respecting the privacy of our customers by implementing technical and administrative safeguards with respect to the storing of any personal data, as described in our Privacy Policy; and supporting a non-discriminatory experience for our customers.

OUR GOVERNANCE

While human rights is a responsibility of all of us at Bug Bam, executive oversight and responsibility for the implementation of this policy rests with our CEO and Board of Directors who reviews and evaluates company programs, policies and practices relating to social and environmental issues and impacts to support the sustainable growth of our business.

OUR IMPLEMENTATION

As a global company we are committed to protecting and respecting human rights of our employees, our supply chain partners, and our customers. This commitment is reflected in our policies and procedures. Through proactive due diligence, we seek to avoid adverse human rights impacts, and, when identified, we work swiftly to remedy any issues. In order to integrate human rights considerations into the management of our business, human rights due diligence is part of our risk assessment for new production and sales locations. For existing production and sales locations, we will evaluate human rights related risks and conduct human rights impact assessments on high-risk markets. Risk and impact assessments are used for identifying actual and potential human rights impacts from our business activities, which are then managed by the relevant business functions.