Vendor Code of Conduct and Ethics

The Vendor Code of Conduct and Ethics for Alberta Gaming, Liquor & Cannabis Commission (AGLC) reflects our commitment to ensuring vendors align themselves with all of AGLC’s values and provides a framework to guide ethical conduct in a way that upholds the integrity and reputation of AGLC. We expect all of our vendors to behave in a way that aligns with this Code. While this Code does not cover every specific scenario, we expect our vendors to use this Code to guide their conduct and exercise care and diligence in the course of work with AGLC. All aspects of the operation of AGLC must be conducted with integrity, trust, impartiality and in accordance with generally accepted standards of behaviour.

AGLC Values:

• Integrity -  We hold ourselves to a high standard. That means operating fairly and honourably with colleagues, customers and stakeholders, even when no one is watching.
• Respect - We listen and empower. Our culture adapts and ensures all are heard to build a vibrant Alberta. And when we misstep, we take accountability.
• Collaboration - We harness the power of multiple minds and ideas. By breaking down internal and external boundaries to work together, we amplify our achievements.
• Innovation - We are always reinventing. The first answer is not always the best answer, so we let our curiosity continuously challenge the status quo.
• Inclusion - We embrace the power of diversity. Each of our unique talents, experiences and relationships come together to form one stronger AGLC.

Application

This Code is not to be read in lieu of, but in addition to, the vendor’s obligations as set out in any contracts between the AGLC and the vendor. In the event of a conflict between this Vendor Code of Contract and Ethics and an applicable contract, the contract will govern.

If specific situations arise that have not been outlined in this Code or any applicable contract, they will be administered according to the performance standards established in this Code.

Performance Standards

Vendors are expected to provide consistent and continuous focus on protecting the health, safety and welfare of workers, minimize their operational impact on the environment and have adopted and encourage ethical business practices.

Social Responsibility

Forced Labour

Vendors must employ workers who choose to be employed by the vendor. The vendor must not use any forced, bonded or indentured labour or involuntary prison labour. All work shall be voluntary and workers must be free to leave upon reasonable notice.

Child Labour

Vendors must commit to a zero-tolerance policy toward the use of child labour in any stage of manufacturing. The term “child” refers to any person under the age of 15 (or 14 where the International Labour Organization (ILO) exemption for developing countries allows), unless local minimum age law stipulates a higher age for work or mandatory schooling, in which case the higher age would apply, as defined by the International Labour Organization. Where local laws do not exist or where they set lower standards than the ILO, the ILO standards shall prevail. The use of legitimate workplace apprenticeship programs, which comply with all laws and regulations, is permitted.

Equality and Non-discrimination

Vendors must promote cooperation, accountability and acceptance of diversity among its employees, subcontractors and agents. Vendors must not engage in discrimination based on race, religious beliefs, colour, gender, gender identity, gender expression, physical or mental disability, ancestry, marital status, family status, source of income, age, place of origin and sexual orientation in hiring and employment practice, such as promotions, rewards and access to training. In addition, workers or potential workers should not be subject to medical tests that could be unlawfully used in a discriminatory way.

Employee Treatment, Harassment and Abuse

Vendors must ensure its employees are treated with respect and dignity and that disciplinary policies and procedures are clearly defined and communicated to employees before application. Vendors must ensure that its employees are not subject to inappropriate treatment, including any sexual harassment, workplace bullying, or workplace harassment, nor to the threat of any such treatment.

Health and Safety

Vendors must comply with all laws relating to occupational health and safety in all applicable jurisdictions. Without limiting the foregoing, Vendors must also ensure that all workers are provided with a healthy and safe work environment. Vendors must ensure that conditions in all work and employer-provided residential facilities are safe, clean and consistent with all applicable Laws regarding occupational health and safety. Vendors must adequately inform employees of the vendor’s health and safety guidelines in terms of equipment, training, management and work practices.

Freedom of Association and Collective Bargaining

Vendors must work directly with employees to find solutions to any outstanding legal and employment issues while at all times respecting worker rights to obtain representation, join labour unions and bargain collectively. Workers must be able to communicate openly with management regarding working conditions without fear of reprisal, intimidation or harassment.

Wages and Benefits

Vendors must comply, as a minimum, with all applicable local Laws, including, but not limited to, those relating to minimum wage and compensation.

The vendor must:

• meet legislated minimum wage rates and comply with all employment standards and related laws in the jurisdiction(s) of production with respect to compensation, including wages and benefits for goods and services produced in Canada
• meet national or international standards, whichever is higher, for wages and benefits within the country of production, regardless of special status granted to a company, worksite, or geographic area that permits the organization to compromise applicable standards for goods and services produced outside of Canada
• Compensate employees for overtime hours at such premium rate(s) as is legally required in the jurisdiction(s) of production; in those countries where such laws do not exist, compensation must be made at a rate at least equal to the employees’ regular hourly compensation rate

Hours of Work

For goods and services produced in Canada, vendors will comply with all employment standards and related laws in the jurisdiction(s) of production and provision of services with respect to hours of work and overtime hours.

For goods and services produced outside of Canada, vendors will ensure that: regular working hours do not exceed forty eight (48) hours per week; that the combination of regular hours and required overtime hours do not exceed sixty (60) hours per week except in emergency circumstances; that hours worked in excess of sixty (60) hours per week are on a voluntary basis; and, that workers are provided at least one (1) day off during every seven (7) day period.

Environmental Requirements

Vendors to AGLC must strive to reduce or eliminate the negative environmental impacts of the goods they provide, the services they perform and construction they complete for AGLC. The minimum environmental standards for vendors include:

• Compliance with the environmental laws, approvals or permits that relate to a vendor’s product or service in all jurisdictions in which the supplier operates
• Identification, minimization and management of the environmental impacts of a vendor’s activities and goods. Typical environmental impacts include, but are not limited to, solid waste, wastewater discharge, air emissions, hazardous (toxic) substances and restricted substances and resource use.

Business Ethics Standards

AGLC, as a crown commercial enterprise of the Government of Alberta, must maintain the public’s trust and confidence and thus it is imperative that AGLC contract only with vendors that conduct business ethically and with integrity.

AGLC employees and elected officials are also held to high standards of conduct and professionalism. As such, vendors must not pressure or attempt to induce AGLC employees or elected officials to breach those standards of conduct and professionalism.

Vendors must comply with high ethical standards in doing business, including but not limited to the following:

• Refrain from exerting pressure of any kind on, or offering money or gifts to, AGLC employees, officials or directors of any entity sourcing goods, services, intellectual property rights, or construction, whether through a competitive or non-competitive sourcing process, in order to gain an advantage of any kind over other participants or potential participants in the sourcing process
• Comply with all applicable domestic and international laws
• Abide by any standards, rules and codes of conduct set out by any bodies which govern the vendor
• Without limiting the foregoing, refrain from engaging in any reviewable conduct or offences under the Competition Act (R.S.C., 1985, c. C-34)
• Refrain from knowingly providing inaccurate or misleading information or withholding information in response to any kind of invitation to submit a bid or proposal
• Refrain from intimidating or attempting to intimidate any other participants or potential participants in any competitive or non-competitive sourcing process
• Refrain from engaging in questionable or unethical financial practices
• Refrain from engaging in any deceptive marketing practices
• Refrain from engaging or attempting to engage in any other corrupt or otherwise unethical business practices
• In addition, suppliers and its subcontractors must not permit their employees to work if they are impaired or intoxicated, whether from legal or illegal substances, or otherwise not fit for duty/work

Management System Requirements

If the vendor has adversely impacted the environment, failed to meet an environmental performance standard, or has breached the social or ethical standards outlined in this Code or any other contractual requirement of AGLC, it is the responsibility of the vendor to satisfactorily implement corrective actions and if necessary, make any changes to the processes and procedures that govern the activities of the vendor to help ensure the breach does not occur in the future. The vendor should have a system in place to:

• Allow for continual improvement of its social, environmental and ethical performance
• Respond to social, environmental and ethical issues and infractions and report them to the satisfaction of the authority having jurisdiction
• Identify non-conformances and address them via verifiable corrective action plan(s)

Compliance and Implementation

AGLC may require that vendors provide details on factory and production facility locations and such details are subject to public disclosure by AGLC in accordance with the Freedom of Information and Protection of Privacy Act (R.S.A., 2000, c. F-25).

AGLC may ask for proof of compliance with all applicable labour, health, safety, environmental and other laws and business ethics requirements and may inspect work locations at any time (or request independent verification of compliance). Vendors must maintain current and sufficiently detailed records to substantiate their compliance with this Code and  AGLC may ask that they are independently verified. The independent verification will be at AGLC’s expense if compliance is verified and at the vendor’s expense if compliance is not verified.

Vendors must comply with and ensure that, its employees, subcontractors and agents comply with, the Lobbyists Act (Alberta), as amended from time to time.

In the event that an active vendor of AGLC becomes aware of any matter that causes or is likely to cause a conflict of interest in relation to the supply of goods or the performance of services, the vendor must immediately disclose such matter to AGLC in writing. Upon such disclosure, the vendor must not commence or continue performance of the Services without the prior written consent of AGLC.