1. INTRODUCTION
Kaizen and Kindness are two of Huda Beauty’s core values. Huda Beauty aims to realise these values in our day-to-day operations and with our business partners. With these values in mind, Huda Beauty outlines these Third-Party Ethical Standards to ensure that its approved partners (such as third-party suppliers) not only respect and comply with laws (whether local or international) but, also, its approved partners engage in good and ethical business practices.
2. BUSINESS PARTNER EXPECTATIONS
Huda Beauty uses its best endeavors to provide products and services that offer peace of mind and safety to customers and that are friendly to both society and the environment, while also conducting its business operations in a sincere manner as it strives to achieve a sustainable society.
To achieve this end, it is essential for Huda Beauty to collaborate with our business partners and, together, committing ourselves towards a sustainable society through demonstrably ethical and lawful practices in our activities.
In recognition of our core values and beliefs, these Standards specifies the non-negotiable minimum standard of conduct that Huda Beauty expects of its suppliers and subcontractors (both in substance and in spirit).
Recent years have seen increasingly serious social and environmental issues, and companies have been under strong pressure to not only comply with the laws and regulations of each country but also to respect international conventions and rules and to make a strong commitment to realizing a sustainable society with the suppliers forming their supply chain.
3. OUR RESEARCH
Huda Beauty works collaboratively with its partners to ensure compliance with these Ethical Standards. We expect our partners to support us in ensuring compliance with these Ethical Standards and, where required, those partners will work collaboratively with us to provide the information needed. For example, business partners will provide us with information about their suppliers or partners.
Where required, Huda Beauty will work with third parties to inspect, audit and verify our business partners’ compliance with these Ethical Standards.
As laws and regulations mature, we will work together with our business partners to develop our understanding and those standards required to continue to comply with applicable laws.
4. LEGAL REGULATORY COMPLIANCE
Huda Beauty’s Mission
: Huda Beauty is committed to conducting its business in
accordance with the highest ethical standards and in compliance with
all applicable laws and regulations in the territories in which we do
business. We aim to exceed requirements of applicable environmental,
health and safety laws and regulations, corporate standards and other
standards and we reasonably expect our business partners to do the
same. Our business partners shall comply with all applicable laws and
regulations of the countries and territories in which they conduct
their business operations. Our business partners shall strive to
comply with industry standards and international standards regarding
fair business operations, human rights, labor and the environment (as
described more particularly below).
Compliance with
Applicable Laws
: Huda Beauty’s business partners are expected to
comply with the law in all circumstances. In cases where applicable
law conflicts with the provisions in this policy, our business
partners are expected to comply with the law, while seeking to meet
the underlying spirit and principles of this policy.
Anti-Bribery and
Corruption (including gifting)
: Huda Beauty requires full compliance
with the Foreign Corrupt Practices Act (FCPA), the UK Anti-Bribery
Act 2010 and any other applicable anti-bribery and anti-corruption
legislation in any territory where our business partners operate.
Relevant anti-bribery and corrupt payment provisions of applicable
legislation make illegal any corrupt offer, payment, promise to pay,
or authorization to pay any money, gift, or anything of value to any
foreign official, any foreign political party, candidate or official,
or any person for the purpose of influencing any act or failure to
act, in the official capacity of such a foreign official or party, or
inducing such a foreign official or party to use influence to affect
a decision of a foreign government or agency, in order to obtain or
retain business for anyone, or direct business to anyone, or to
obtain a competitive advantage.
Improper Payments,
Gifts and Entertainment
: Notwithstanding the provisions of any
anti-bribery or related legislation, business partners should be
aware that Huda Beauty’s employees may not give or receive gifts or
entertainment unless such gifts are:
- not provided in exchange for goods or services;
- modest in value;
- infrequent;
- unsolicited;
- given on a customary gift giving occasion;
- reasonable and customary in our business’ and
- permissible under the rules of the suppliers’ organization.
Cash and cash equivalents such as gift cards and gift cheques are never acceptable. Gifts of tickets for entertainment of any nature (theater, sporting event, etc.) require that the donor attend the event with the recipient.
Huda Beauty understands that gifting can be an acceptable courtesy especially in cultural or educational contexts. However, gifting must never be provided for the purpose of influencing a third party’s any act or failure to act to obtain or retain business for anyone or to obtain a competitive advantage.
Money laundering, trade restrictions and international sanctions: Huda Beauty requires its business partners to commit to taking all appropriate measure to prevent their operations (especially those involving Huda Beauty’s business) from being used as vehicles for money laundering. Money laundering may occur where efforts seek to mask or hide the origin of money or assets associated with criminal or other illegitimate activities.
Huda Beauty commits to respecting and complying with trade restrictions especially international sanctions. Therefore, our business partners must respect international trade restrictions and sanctions considering any changes in these measures, especially export restrictions.
Respecting Competition Law: Huda Beauty seeks to comply with applicable competition laws, such as anti-trust laws. Consequently, our business partners must be committed to compliance with applicable competition laws including without limitation those around concerted practices, unlawful agreements and abuse of dominance.
5. ETHICAL LABOR PRACTICES AND SOCIAL RESPONSIBILITIES
Overall: The nature of our business is such that we are committed to providing a transparent approach to our supply chain scrutiny, including where applicable publishing statements under prevailing legislation to demonstrate our compliance with (inter alia) The Modern Slavery Act 2015 (UK); Modern Slavery Act 2018 (Commonwealth Act); and the California Transparency in Supply Chains Act, among others.
We apply the requirements, principles and spirit of the above legislation to our global business; and our business partners are required to be compliant with the same requirements and principles or their equivalent local legislation (regardless of where they are based).
Child Labor: Huda Beauty’s suppliers must not employ child labor under any circumstances. The term “child” means any person under the age of 15 or under the minimum age for employment in the relevant country where our business partner operates, whichever is greater. In addition, business partners shall take sufficient care to ensure that there will not be any prevention of the opportunity for education to be provided to children.
Forced labor: business partners shall not be involved, in any way, in any forced labor, including labor under conditions of slavery, labor with physical or psychological constraint, and human trafficking.
Voluntary employment: In hiring their employees, business partners shall explain the employment conditions so that employees will be able to enter the business partner based on their own discretion after having fully understood such conditions. Further, business partners shall grant their employees the right to freely leave their employment with the business partner in accordance with prevailing legislation.
Unless otherwise expressly set forth in the laws or regulations, suppliers shall not restrict the freedom of their employees, including by way of unduly imposing fees or advance payments relating to their employment, or confiscating or destroying passports, identification documents or work permits, etc.
Working conditions: In relation to employment conditions, business partners shall comply with all applicable labor-related laws and regulations of the countries and territories in which suppliers conduct their business operations and shall agree to conditions under which human rights are respected.
Working Hours: Huda Beauty’s business partners must uphold the local legal limit on hours worked.
Wages: Huda Beauty’s business partners must pay their employees the legal minimum wage (where applicable in the relevant territory) or the prevailing industry wage (whichever is higher) as well as any legally prescribed benefits. Workers must not be subject to financial penalties for poor performance or face illegal deductions.
Discrimination: Huda Beauty’s business partners must not subject their workers to any unfair or unjustified discrimination with regard to hiring, remuneration, promotion or termination. Any employment decisions must be based on worker ability and not on personal characteristics such as race, creed, color, religion, gender, age, national origin, alienage or citizenship status, sexual orientation, gender identity or expression, marital, partnership or familial status, disability, genetic information, veteran/military status, domestic violence victim status or any other characteristic protected by law.
Harassment or abuse: our business partners must treat their employees and contractors with respect and dignity; moreover, they must not tolerate or engage in any corporal punishment, physical, sexual, verbal or psychological harassment or any other kind of abuse at any time.
Freedom of Association: Huda Beauty’s business partners must recognize applicable laws which protect the right of employees to freely associate and to select or not to select workplace representatives whether under collective agreements or otherwise.
Health and Safety: Huda Beauty’s business partners must ensure that their workers perform their work in clean, healthy and safe environments. Any residential facilities must be similarly maintained. Work areas must be of a standard to prevent accidents and illnesses and to ensure an adequate level of sanitation. These standards shall also apply to any housing provided by our business partners to those workers.
Communication: Huda Beauty business partners must make all reasonable efforts to communicate these Ethical Standards to workers, contractors and sub-contractors and must ensure that those workers have the opportunity to ask questions and make complaints under these Ethical Standards.
Human Rights: Huda Beauty’s suppliers must always treat their workers with respect and dignity. They must not engage in any kind of physical, verbal, psychological or sexual abuse or misconduct.
Business partners shall respect the land rights, culture, custom, and religion of indigenous people and shall conduct their business operations based on such respect. Business partners shall respect the traditional knowledge and the rights in relation to genetic resources of indigenous people and shall strive not to exploit the interests of indigenous people in a one-sided manner.
Business partners shall treat migrant workers in the same capacity as local workers. In addition, business partners shall treat foreign workers and migrant workers in a just manner and provide such workers with transparent employment conditions as well as good working and living conditions.
Business partners shall also: (i) reimburse migrant workers’ employment-related commissions, etc.; (ii) not hire any illegal migrant workers; (iii) neither confiscate ID documents of migrant workers nor keep migrant workers’ money in trust; and (iv) understand the scope of this Ethical Standards includes workers employed through an agency or contractor.
6. ENVIRONMENT PROTECTION AND ETHICAL TESTING
Overall: Business partners shall recognize the importance of preserving the environment, and, through their business activities, shall maintain a proactive stance toward such preservation and work to contribute to the development of a sustainable society through measures such as preserving biodiversity, controlling greenhouse gas emissions, reducing waste materials and drainage, conserving resources, recycling, and preventing pollution.
Business partners shall comply with (a) all environment-related laws and regulations applicable to the countries and territories where suppliers conduct their business operations and (b) the Responsible Sourcing of Palm Oil standards as set out by the Round Table on Sustainable Palm Oil.
Animal Testing: Huda Beauty is fundamentally opposed to any animal testing in its product supply chain and suppliers will be required to comply and collaborate with us in our (a) auditing activities under these Ethical Standards and (b) Leaping Bunny compliance requirements. Huda Beauty will review its continued business partnership where we consider that a business partner’s activities may detrimentally impact our reputation (including any certification or similar approvals).
Reduce waste and materials: our supply chain business partners in particular will continuously improve to minimize their use of raw materials and packaging materials as well as maximise the use of recycled and recyclable materials in the production of Huda Beauty products. Moreover, our supply chain business partners (upstream and downstream)
7. LOSS PREVENTION
Huda Beauty expects each of its suppliers to have in place a loss prevention plan. The loss prevention plan should address at the very least the following areas (i) safety of personal, (ii) security of information, (iii) assets and products, (iv) financial losses.
8. NON-COMPLIANCE
Where a business partner is non-compliant with these Ethical Standards, Huda Beauty will work with them to develop a corrective action plan. We expect our business partners to develop and implement such corrective action plan immediately.
In serious cases of non-compliance, Huda Beauty may terminate its commercial relationship with the relevant business partner(s).
9. APPROVALS AND REVIEWS
Huda Beauty’s continuing review and approval of suppliers is subject to compliance with these Ethical Standards and, where applicable, any audits to verify compliance, whether such audit is conducted by Huda Beauty or by authorised third parties on our behalf.
It is a fundamental requirement of our ongoing relationship with our business partners that they cooperate with and freely engage with us in our audit processes in all respects.
Updated as of January 2023