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Supplier COC


May 2024          


Cinas A/S considers a sustainable supply chain to be an important part of our business, and our aim is to cooperate with suppliers that share these ambitions. Cinas A/S includes environmental and social standards when selecting and evaluating suppliers. We can only be successful as a business in the long term if the negative impacts of both our business activities and those of our suppliers are in harmony with people and the environment. Our goal is therefore to strengthen human and environmental rights and to prevent, minimize, and remedy any violations. This commitment applies both to our own business activities and to our global supply chains. We therefore also expect you, as our direct supplier (hereinafter referred to as 'Supplier'), to comply with the aforementioned principles.

The present Cinas A/S Code of Conduct (hereinafter referred to as 'CoC') serves as a cornerstone for the joint and effective implementation of these principles. The CoC defines the expectations of Cinas A/S regarding the protection of human rights and environmental protection in the supply chain, which you as a supplier must observe and comply with in doing business with Cinas A/S. Cinas A/S recognizes that suppliers may be at different maturity levels with regards to the requirements set out in this CoC and hence acknowledges that the transition can take time. Cinas A/S’s suppliers are responsible for setting the same or comparable standards for sub-suppliers to ensure the requirements are fulfilled throughout the supply chain. The following provisions of this CoC are binding in all business dealings between Cinas A/S and their Suppliers. The CoC shall apply for as long as the Supplier is still in a business relationship with Cinas A/S.


2.1 General information on cooperation between Cinas A/S and their Suppliers

Cinas A/S expects that the Suppliers will not violate any of the protected rights laid down in the catalogue of Sections 3 and 4 of this CoC (hereinafter referred to as “human rights and environmental rights”). The Supplier undertakes to protect human rights and environmental rights in its own business area and to comply with the requirements of this CoC. The Supplier must inform its employees about the contents of this CoC and, if necessary, provide training. General training about human rights and environmental protection is equivalent to this. If the Supplier is of the opinion that it cannot fulfil a requirement of this CoC without violating applicable law, it shall inform Cinas A/S thereof without delay. The Supplier is further required to inform if Cinas A/S's sourcing and purchasing practices result in negative impacts on human rights or environmental obligations in products manufactured for Cinas A/S.

2.2 Reporting of violations of human and environmental rights

Without prejudice to its further notification obligations under the provisions below, the Supplier is obligated to report any violation of human rights and environmental rights as outlined in this CoC.

2.3 Information for Cinas A/S risk analysis

The Supplier acknowledges that Cinas A/S is obliged to carry out a risk analysis. Upon request of Cinas A/S, the Supplier shall promptly provide all information that is required by Cinas A/S (or a third party commissioned by it for this purpose) to carry out the risk analysis. The supplier shall also accept that employees or agents of Cinas A/S may inspect the Supplier’s business premises.



3.1 Fair working conditions

All employees must be informed of their rights and of the terms and conditions of their employment (such as remuneration, working time arrangements, and holiday entitlements) in a comprehensible manner and, where national regulations and laws so provide, have written contracts of employment.

 All employees shall be paid in accordance with the statutory minimum wage or, if higher, on the basis of industry standards approved in collective bargaining. Employees must be entitled to adequate remuneration that is sufficient to enable them and their families to live in dignity.

Social benefits must be provided in accordance with the statutory provisions. Remuneration must be paid on time, regularly, in full, and in legal tender. Deductions are only permitted under the conditions prescribed by law or established by collective agreements. Pay deductions as disciplinary measures are not permitted. In addition, locally applicable regulations on working hours (especially with regard to overtime, breaks, and rest periods) as well as holidays, paid sick leave, and special regulations, e.g., to protect pregnant women and employees with special needs, must always be complied with.

The use of overtime must be voluntary or regulated by contract or collective agreement. Employees must not be subjected in the workplace to any inhumane or degrading treatment, to corporal punishment, sexual harassment, psychological or physical coercion, or to any physical or verbal abuse. Disciplinary measures must not be taken if they violate applicable law.

3.2 Freedom of association and collective bargaining

The right of all employees to form and join trade unions and to bargain collectively in a free and democratic manner must be respected at all times. Trade unions must be allowed to operate freely and in accordance with the law of the place of employment; this also applies to the right to strike. Employee representatives must not be denied access to or prevented from interacting with employees.

3.3 Anti-discrimination

Any form of discrimination against employees must be avoided and actively prevented. In particular, no one must be discriminated against on the basis of skin color, gender, age, religion or world view, social background, health, ethnic origin, nationality, membership of employee organizations, political membership or political opinion, or sexual identity. This applies in particular to the recruitment of employees and to their further training, promotion, and remuneration.

3.4 Prohibition of child labor

The minimum age at which a child can be employed must be above the age at which compulsory education ends under the law of the place of employment, but under no circumstances below the employment age of 15 years, unless one of the exceptions recognized by the ILO applies (cf. ILO Convention No. 138) and applicable local law also provides for that exception. In order to ensure compliance with the above, reliable age assessment methods must be used when recruiting staff. However, such methods must not, under any circumstances, lead to any degrading or undignified treatment of employees or applicants.


3.5 Protection of young persons

The worst forms of child labor (as defined in ILO Convention No. 182) are always prohibited for employees under the age of 18. These include, but are not limited to, all forms of slavery and practices similar to slavery, work in illicit activities, and any work which, by its nature or the circumstances in which it is carried out, is likely to be harmful to the health, safety, or morals of children or young persons. If persons under the age of 18 are employed, their working hours must not interfere with their ability to participate in vocational training programs recognized by competent bodies.

3.6 Prohibition of forced labor and slavery

Forced labor is prohibited. This includes any work or the provision of services which are required of a person under threat of punishment (whether physical, psychological, financial, or otherwise) and for which that person has not volunteered. Also prohibited are all forms of slavery, slave-like practices, servitude, or other forms of domination or oppression in the workplace environment, such as extreme economic exploitation, sexual exploitation, or humiliation. All employees shall have the right to terminate their employment in accordance with the contractual or, as the case may be statutory. notice period

It is forbidden to withhold identity documents from employees. Employees, especially itinerant workers and migrants, must not make unlawful payments or deposits to obtain their jobs. Where lawful payments are incurred for job placement services or for obtaining documents necessary for employment, such as work permits, visas, or health checks, these must be borne by the employer. Special care must be taken when using employment agencies, both directly and indirectly. Employment agencies may only be used if they operate lawfully and responsibly. As far as possible, certified employment agencies must be used.

3.7 Occupational health and safety

The occupational health and safety rules that apply according to the law of the place of employment must be complied with at all times. At each operating site, systems that are appropriate in relation to the size and harmful nature of the business must be in place to identify, assess, prevent, and control any potential hazards to the health and safety of employees. Effective measures must be taken to prevent work-related accidents and health hazards, in particular through:

  • sufficient safety standards in the provision and maintenance of workstations, work areas, and work equipment,
  • appropriate protective measures to avoid exposure to chemical, physical, or biological agents,
  • measures to prevent excessive physical or mental fatigue, in particular through appropriate work organization in terms of working hours and rest breaks, and
  • adequate training and instruction of employees as well as the documentation of these measures.

Minimum requirements also include adequate lighting, temperature control, and ventilation, the provision of drinking water, adequate sanitary facilities, and the provision of occupational health care. Where accommodation is provided, it must be clean, safe, and suitable for meeting the basic needs of employees. Employees must have the right to leave the premises in dangerous situations without having to ask for permission. The Supplier shall appoint from its management or from among its senior employees a person responsible for compliance with the aforementioned occupational health and safety obligations.

3.8 Preservation of natural resources and basic human needs

The natural foundations of life must be preserved and safeguarded. In particular, care must be taken within the scope of all business activities to avoid any adverse soil changes, groundwater contamination, air pollution, harmful noise emissions, or excessive water consumption which would result in:

  • a substantial impairment of the natural basis for the preservation and production of food,
  • a person being denied access to safe drinking water,
  • a person having difficulty accessing sanitary facilities or the destruction of such facilities, or
  • damage to the health of a person.

3.9 Rights of local communities, forced evictions

Local, national, international, and traditional land, water, and resource rights shall be respected, especially those of indigenous communities. The free and informed consent of affected communities must be obtained prior to legally permitted land-use changes are made or before water or other resources of local communities are consumed or affected. The consent process must be documented. There must be no unlawful evictions.

3.10 Deployment of security guards

The hiring or use of private or public security guards for the protection of a business project is prohibited if, due to a lack of instruction or supervision on the part of the business, the use of the security guards would result in:

  • a violation of the prohibition of torture and cruel, inhumane and degrading treatment,
  • injury to life or limb, or
  • employees’ freedom of association being affected.


4.1 Resource consumption, avoidance of environmental pollution

In addition to applicable local environmental laws, all internationally recognized environmental standards must be complied with. Throughout the entire supply chain, the aim is to avoid or continuously reduce the negative environmental impact of resource and energy consumption, emissions of greenhouse gases and air pollutants, water consumption and emissions into soil or water, to avoid or reduce waste, to preserve biodiversity, and to promote circular economy. This applies to both goods and packaging.

4.2 Handling of waste

Appropriate measures must be taken to ensure that waste containing persistent organic pollutants (as defined in the Stockholm Convention of 23 May 2001 (POPs Convention) and in applicable legislation adopted on the basis thereof) is handled, collected, transported, and stored in an environmentally sound manner. Local rules and best practices must be followed. The export of hazardous waste and other waste within the meaning of the Basel Convention of 22 March 1989 and within the meaning of Regulation (EC) No 1013/2006 is prohibited if:

  • the importing country is not party to the Basel Convention,
  • the importing country has not given its written consent to the particular import or has even prohibited such import, or
  • it can be assumed that the waste will not be treated in an environmentally sound manner (whether in the importing country or elsewhere). The following are also prohibited:
  • the export of hazardous waste (as defined above) from countries specified in Annex VII to the Basel Convention to countries not listed therein, and
  • the import of hazardous waste and other waste (as defined above) from a country that is not party to the Basel Convention.

4.3 Environmental permits

All local required environmental permits and approvals must be obtained, kept up to date at all times, and complied with.

4.4 Climate protection

Cinas A/S expects appropriate measures to be taken at all levels of the supply chain to reduce the CO2 balance and thus to contribute to achieving the targets agreed at the UN Climate Change Conference in Paris and the 1.5-degree target of the Intergovernmental Panel on Climate Change (IPCC). All Suppliers and their suppliers are encouraged to find economic solutions to improve energy efficiency and to minimize energy consumption and greenhouse gas emissions. The aim is to reduce greenhouse gas emissions as far as possible through avoidance and reduction strategies that are in line with the requirements of the Science Based Target Initiative and only then to compensate for residual emissions. The protection of forests and other valuable ecosystems plays a central role in mitigating climate change and in preserving biodiversity. Cinas A/S expects Suppliers and their suppliers to contribute to net zero deforestation. Suppliers and their suppliers shall endeavor to ensure that no clearing of primary forests and other areas worthy of special protection takes place for the production of raw materials and that compensation is provided through reforestation in the event of any legal deforestation.

4.5 Hazardous substances and product safety

Hazardous substances, chemicals, and materials must be labeled. Care must be taken to ensure their safe handling, movement, storage, recycling, reuse, and disposal. All applicable laws and regulations regarding hazardous substances, chemicals, and materials must be complied with. Applicable substance restrictions and product safety requirements must be observed. Key personnel must be informed and regularly trained in this regard. The following are prohibited:

  • the production, import, and export of products to which mercury has been added,
  • the use of mercury and mercury compounds in manufacturing processes within the meaning of Art. 5(2) and Annex B Part I of the Minamata Convention of 10 October 2013 from the respective phase-out date specified therein,
  • the treatment of mercury waste contrary to Art. 11(3) of the Minamata Convention. The production and use of chemicals listed in Annex A of the POPs Convention are also prohibited. (Reach and RoHS)

4.7 More environmentally friendly packaging

Efforts must always be made to use packaging that is more environmentally friendly. To this end, packaging must, wherever possible, be avoided or reduced or improved in terms of its environmental effects. These principles are to be applied in the order of priority given here – because the best packaging, from an ecological point of view, is one which can be avoided completely. Packaging is considered more environmentally friendly if it is reusable, uses as little material as possible, is recyclable, or consists of secondary raw materials, alternative materials, or certified paper.


The Supplier shall ensure that it truthfully and accurately documents its activities, its group structure and performance and that it discloses them in accordance with applicable regulations and industry standards. The Supplier must conduct its business ethically and without bribery, corruption, or any kind of fraudulent business practices, complying at least with applicable national laws and regulations.

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