At Fitbit, we are a passionate team dedicated to the health and wellness of those who are helping to build our products that help people transform their lives. This passion and dedication is evident not only in the products we build, but in our approach to doing business. To ensure we provide products to our customers that are grounded in the social responsibility values, we aim to only work with Business Partners that share our same philosophy.

 

To that end, we continue to take the steps necessary to ensure that we are manufacturing and sourcing from socially responsible Business Partners who:

 

• comply in a timely manner with all applicable laws and regulations;
• conduct assessments as needed in support of such compliance;
• promote continual improvement through monitoring and training; 
• make available independent avenues for workers to raise concerns related to responsible supply chain sourcing; and
• proactively participate in industry level initiatives and coalition.
  

 

In furtherance of these efforts, we are a member of the Responsible Business Alliance (RBA). This Supplier Code of Conduct (the “Code”) is based on the RBA Code of Conduct and other standards including, the Universal Declaration of Human Rights, International Labour Organization’s International Labour Standards, and Organisation for Economic Co-operation and Development Guidelines for Multinational Enterprises. This Code must always be followed by our Business Partners as it provides the bedrock necessary to allow our company to continue to invent the future in a socially responsible manner. We appreciate all the hard work it takes to do business right and are committed to supporting our Business Partner’s efforts to do so.

 

To report any violations to Fitbit Supplier Code of Conduct, please use the confidential and anonymous compliance hotline: fitbit.ethicspoint.com.

 

 

Labour

 

We believe all workers in our supply chain deserve a fair and ethical workplace. Workers must be treated with dignity and respect and our Business Partners must uphold certain standards of human rights. The labour standards set forth in this Code must be applied to all types of workers, including temporary, migrant and student. Those labour standards are:

 

Freely Chosen Employment

Forced, bonded (including debt bondage) or indentured labour, involuntary or exploitative prison labour, slavery or trafficking of persons shall not be used. This includes transporting, harbouring, recruiting, transferring or receiving persons by means of threat, force, coercion, abduction or fraud for labour or services. There shall be no unreasonable restrictions on workers’ freedom of movement in the facility in addition to unreasonable restrictions on entering or exiting company-provided facilities. As part of the hiring process, workers must be provided with a written employment agreement in their native language that contains a description of terms and conditions of employment prior to the worker departing from his or her country of origin and there shall be no substitution or change(s) allowed in the employment agreement upon arrival in the receiving country unless these changes are made to meet local law and provide equal or better terms. All work must be voluntary and workers shall be free to leave work at any time or terminate their employment. Employers and agents may not hold or otherwise destroy, conceal, confiscate or deny access by employees to their identity or immigration documents, such as government-issued identification, passports or work permits, unless such holdings are required by law. Workers shall not be required to pay employers’ or agents’ recruitment fees or other related fees for their employment. If any such fees are found to have been paid by workers, such fees shall be repaid to the worker.

 

Young Workers

Child labour is not to be used in any parts of the business. The term “child” refers to any person under the age of 15, or under the age for completing compulsory education, or under the minimum age for employment in the country, whichever is greatest. The use of legitimate workplace learning programmes, which comply with all laws and regulations, is supported. Workers under the age of 18 (Young Workers) shall not perform work that is likely to jeopardise their health or safety, including night shifts and overtime. Business Partners shall ensure proper 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. Business Partner shall provide appropriate support and training to all student workers. In the absence of local law, the wage rate for student workers, interns and apprentices shall be at least the same wage rate as other entry-level workers performing equal or similar tasks.

 

Working Hours

Working hours are not to exceed the maximum set by local law. Further, a work week should not be more than 60 hours per week, including overtime, except in emergency or unusual situations. Workers shall be allowed at least one day off every seven days.

 

Wages and Benefits

Compensation paid to workers shall comply with all applicable wage laws, including those relating to minimum wages, overtime hours and legally mandated benefits. Workers shall be compensated for overtime at pay rates greater than regular hourly rates. Deductions from wages as a disciplinary measure shall not be permitted. For each pay period, workers shall be provided with a timely and understandable wage statement that includes sufficient information to verify accurate compensation for work performed. All use of temporary, dispatch and outsourced labour will be within the limits of the local law.

 

Humane Treatment

There is to be no harsh and inhumane treatment including any sexual harassment, sexual abuse, corporal punishment, mental or physical coercion or verbal abuse of workers; nor is there to be the threat of any such treatment. Disciplinary policies and procedures in support of these requirements shall be clearly defined and communicated to workers.

 

Non-Discrimination

We are committed to a workplace that is free of harassment and unlawful discrimination. Business Partner shall not engage in discrimination based on race, colour, age, gender, sexual orientation, gender identity and expression, ethnicity or national origin, disability, pregnancy, religion, political affiliation, union membership, covered veteran status, protected genetic information or marital status in hiring and employment practices such as wages, promotions, rewards and access to training. Workers shall be provided with reasonable accommodation for religious practices. In addition, workers or potential workers should not be subjected to medical tests or physical exams that could be used in a discriminatory way.

 

Freedom of Association

In conformance with local law, Business Partners shall respect the right of all workers to form and join trade unions of their own choosing, to bargain collectively and to engage in peaceful assembly as well as respect the right of workers to refrain from such activities. Workers and/or their representatives shall be able to openly communicate and share ideas and concerns with management regarding working conditions and management practices without fear of discrimination, reprisal, intimidation or harassment.

 

 

Health and Safety

 

We believe a healthy work environment is core to a company whose mission it is to help people lead healthier, more active lives. Therefore, our Business Partners are required to maintain a work environment that meets the health and safety standards set forth in this Code. Workers must always have the right to refuse unsafe work and report unhealthy working conditions. Those health and safety standards are:

 

Occupational Safety

Worker exposure to potential safety hazards (e.g. chemical, electrical and other energy sources, fire, vehicles and fall hazards) must be identified, assessed and controlled through proper design, engineering and administrative controls, preventative maintenance, and safe work procedures (including lockout/tagout), and ongoing safety training. Where these hazards cannot be adequately controlled by these means, workers shall be provided with appropriate, well-maintained, personal protective equipment, as well as educational materials about risks associated with these hazards. Reasonable steps must also be taken to remove pregnant women/nursing mothers from working condition with high hazards, remove or reduce any workplace health and safety risks to pregnant women and nursing mothers including those associated with their work assignments, as well as include reasonable accommodations for nursing mothers.

 

Emergency Preparedness

Potential emergency situations and events are to be identified and assessed, and their impact minimised by implementing emergency plans and response procedures including: emergency reporting, employee notification and evacuation procedures, worker training and drills, appropriate fire detection and suppression equipment, clear and unobstructed egress adequate exit facilities and recovery plans. Such plans and procedures shall focus on minimising harm to life, the environment and property.

 

Occupational Injury and Illness

Procedures and systems are to be in place to prevent, manage, track and report occupational injury and illness including provisions to: encourage worker reporting; classify and record injury and illness cases; provide necessary medical treatment; investigate cases and implement corrective actions to eliminate their causes; and facilitate return of workers to work.

 

Industrial Hygiene

Worker exposure to chemical, biological and physical agents is to be identified, evaluated and controlled according to the hierarchy of controls. Potential hazards are to be eliminated or controlled through proper design, engineering and administrative controls. When hazards cannot be adequately controlled by such means, workers are to be provided with and use appropriate, well-maintained, personal protective equipment. Protective programmes shall include educational materials about the risks associated with these hazards.

 

Physically Demanding Work

Worker exposure to hazards of physically demanding tasks, including manual material handling and heavy or repetitive lifting, prolonged standing and highly repetitive or forceful assembly tasks is to be identified, evaluated and controlled.

 

Machine Safeguarding

Production and other machinery must be evaluated for safety hazards. Physical guards, interlocks and barriers are to be provided and properly maintained where machinery presents an injury hazard to workers.

 

Sanitation, Food and Housing

Workers are to be provided with access to clean toilet facilities, potable water, as well as hygienic food preparation, storage and eating facilities. Where dormitories are provided, the dormitories must be maintained clean and safe, including, providing for appropriate emergency exits, hot water for bathing and showering, adequate lighting, heat and ventilation, and reasonable personal space, as well as reasonable entry and exit privileges.

 

Health and Safety Communication

Business Partners must provide workers with appropriate workplace health and safety information and training in the language of the worker or in a language the worker can understand for all identified workplace hazards that workers are exposed to, including mechanical, electrical, chemical, fire and physical hazards. Health and safety related information shall be clearly posted in the facility or another place readily accessible by workers. Training is provided to all workers prior to the beginning of work and regularly thereafter. Workers shall be encouraged to raise safety concerns.

 

Environmental

 

We recognise that we can't help change peoples’ lives without ourselves working closely with our Business Partners to minimise any adverse effects our manufacturing operations may have on the community, environment and natural resources. Therefore, we require our Business Partners to meet the environmental standards set forth in this Code. Those environmental standards are:

 

Environmental Permits and Reporting

All required environmental permits, approvals and registrations are to be obtained, maintained and kept current by Business Partners and their operational and reporting requirements are to be followed.

 

Pollution Prevention and Resource Reduction

Emissions and discharges of pollutants and generation of waste are to be minimised or eliminated at the source or by practices such as modifying production, maintenance and facility processes, or by other means. The use of natural resources, including water, fossil fuels, minerals and virgin forest products, is to be conserved or by practices such as modifying production, maintenance and facility processes, materials substitution, re-use, conservation, recycling or other means.

 

Hazardous Substances

Business Partners must implement a systematic approach to identify, manage and reduce chemicals and other materials posing a hazard to humans or the environment, including that such chemicals are to be identified, labelled and managed to ensure their safe handling, movement, storage, use, recycling or reuse and disposal.

 

Solid Waste Management

Business Partners shall implement a systematic approach to identify, manage, reduce and responsibly dispose of or recycle solid waste (non-hazardous).

 

Air Emissions Management

Air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting chemicals and combustion by-products generated from operations are to be characterised, routinely monitored, controlled and treated as required prior to discharge. Business Partners shall conduct routine monitoring of the performance of their air emission control systems.

 

Material Restrictions

Business Partners are to adhere to applicable laws, regulations and customer requirements regarding prohibition or restriction of specific substances in products and manufacturing, including labelling for recycling and disposal.

 

Water Management

Business Partners shall implement a water management program that documents, characterises and monitors water sources, use and discharge, seeks opportunities to conserve water, and controls channels of contamination. All wastewater is to be characterised, monitored, controlled and treated as required prior to discharge or disposal. Business Partners shall conduct routine monitoring of the performance of their wastewater treatment and containment systems to ensure optimal performance and regulatory compliance.

 

Energy Consumption and Greenhouse Gas Emissions

Energy consumption and all relevant Scopes 1 and 2 greenhouse gas emissions are to be tracked and documented, at the facility and/or corporate level. Business Partners are to look for cost-effective methods to improve energy efficiency and to minimise their energy consumption and greenhouse gas emissions.

 

Ethics

 

We believe that underpinning the standards discussed above is the need to uphold the highest standards of ethical conduct in all business dealings. Therefore, we require that our Business Partners meet the standards of business ethics set forth in this Code. Those ethical standards are:

 

Business Integrity

Business Partners must have a zero tolerance policy to prohibit any and all forms of bribery, corruption, extortion and embezzlement.

 

No Improper Advantage

Bribes or other means of obtaining undue or improper advantage are not to be promised, offered, authorised, given or accepted, either directly or indirectly through a third party. This prohibition covers promising, offering, authorising, giving or accepting anything of value, either directly or indirectly through a third party, in order to obtain or retain business, direct business to any person, or otherwise gain an improper advantage. Monitoring and enforcement procedures shall be implemented to ensure compliance with anti-corruption laws.

 

Disclosure of Information

All business dealings should be transparently performed and accurately reflected on Business Partners’ business books and records. Information regarding participant labour, health and safety, environmental practices, business activities, structure, financial situation and performance is to be disclosed in accordance with applicable regulations and prevailing industry practices. Falsification of records or misrepresentation of conditions or practices in the supply chain are unacceptable.

 

Intellectual Property

Intellectual property rights are to be respected, including that the transfer, use and storage of confidential information is to be done in a manner that reasonably protects intellectual property rights and confidentiality.

 

Fair Business, Advertising and Competition

Standards of fair business, advertising and competition are to be upheld.

 

Protection of Identity and Non-Retaliation

Programme that ensures the confidentiality, anonymity and protection of Business Partner and employee whistleblowers are to be maintained, unless prohibited by law. A formal process by which personnel are able to raise any concerns without fear of retaliation is to be communicated to workers.

 

Responsible Sourcing of Minerals

Business Partners shall have a programme that reasonably assures that the tantalum, tin, tungsten and gold in the products they manufacture do not directly or indirectly finance or benefit armed groups that are perpetrators of serious human rights abuses in the Democratic Republic of the Congo or an adjoining country. Business Partners shall exercise due diligence on the source and chain of custody of these minerals and make their due diligence measures available to us upon request. Fitbit’s policy on the responsible sourcing of minerals is available at fitbit.com/legal.

 

Privacy

Business Partners must take reasonable measures to protect the privacy of personal information of everyone it does business with, including Business Partners, customers, consumers and its employees. At a minimum, Business Partners must comply with all applicable privacy and information security laws and regulations when personal information is collected, stored, processed, transmitted and shared.

 

Management System

 

We believe that paramount to a Business Partner ensuring its compliance with the standards set forth in this Code is the implementation by Business Partner of a management system designed to identify and mitigate operational risks related to this Code and seek continual improvement of its business operations. Core to any such management system are the following elements:

 

Company Commitment

Corporate social and environmental responsibility policy statements affirming Business Partner’s commitment to compliance and continual improvement, endorsed by executive management and posted in the facility in the local language.

 

Management Accountability and Responsibility

The Business Partner clearly identifies senior executive and company representative(s) responsible for ensuring implementation of the management systems and associated programmes. Senior management reviews the status of the management system on a regular basis.

 

Legal and Other Requirements

A process to identify, monitor and understand applicable laws, regulations and customer requirements, including the requirements of this Code.

 

Risk Assessment and Management

A process to identify the legal, compliance, environmental, health and safety, security, labour practices, and ethics risks associated with a Business Partner’s operations. Business Partners must determine the relevant significance for each risk and implement appropriate procedural and physical controls to control the identified risks and ensure regulatory compliance.

 

Improvement Objectives

Written performance objectives, targets and implementation plans to improve the Business Partner’s social and environmental, including a periodic assessment of Business Partner’s performance in achieving those objectives.

 

Training

Programmes for training Business Partner’s workforce to implement its policies, procedures and improvement objectives and to meet applicable legal and regulatory requirements.

 

Communication

A process for communicating clear and accurate information about its policies, practices, expectations and performance to workers, Business Partners and customers.

 

Worker Feedback, Participation and Grievance

Ongoing processes, including an effective grievance mechanism to assess employees’ understanding of, and obtain feedback on, or violations against practices and conditions covered by this Code and to foster continuous improvement.

 

Assessments

Periodic self-evaluations to ensure conformity to legal and regulatory requirements, the content of the Code and customer contractual requirements related to social and environmental responsibility.

 

Corrective Action Process

A process for timely correction of deficiencies identified by internal or external assessments, inspections, investigations and reviews.

 

Documentation and Records

Creation and maintenance of documents and records to help ensure regulatory compliance and adherence to company requirements along with appropriate confidentiality to protect privacy.

 

Supplier Responsibility

A process by which each Business Partner communicates the requirements of this Code to its suppliers and to monitor its suppliers compliance to this Code.