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STANDARDS FOR SUBCONTRACTORS AND SUPPLIERS
STANDARDS FOR SUBCONTRACTORS AND SUPPLIERS
These Standards for Subcontractors and Suppliers (“Standards”) set forth the fundamental expectations of Kellermeyer Bergensons Services, LLC (“KBS”) for its Subcontractors and Suppliers. The Standards cover a wide range of business practices and procedures. They do not cover every legal and ethical issue that may arise but do establish basic principles to guide all Subcontractors and Suppliers in their dealings with or on behalf of KBS. All our Subcontractors and Suppliers must conduct themselves ethically and work to avoid even the appearance of improper behavior.
Violation of these Standards could cause possible termination of contracts or assignments and a permanent bar in doing business with KBS.
- Compliance with Laws
Subcontractors and Suppliers must fully comply with all applicable federal, state and local laws, regulations and licensing requirements, including, but not limited to those related to immigration, equal employment opportunity, anti-harassment, health and safety, and the environment. Complying with the letter as well as the spirit of the law is the foundation of KBS’ Standards.
- Work Hours
Subcontractors and Suppliers must provide workers with schedules of hours that provide for the appropriate meal or rest periods as well as days of rest that are consistent with local, state or federal laws. Similarly, Subcontractors and Suppliers are required to compensate workers in terms of wages, overtime, premium pay, sick hours and other wage and hour standards that meet or exceed local, state and federal laws.
- Hiring and Employment Practices
Prior to employment, Subcontractors and Suppliers must implement hiring practices that confirm a worker’s age (over 18) and ability to work in the United States. All terms and conditions of employment including, but not limited to, hiring, compensation, training, promotion, benefits, and termination must be consistent with all applicable equal employment opportunity and related labor and employment regulations required by local, state or federal laws.
- Freedom of Association and Collective Bargaining
Subcontractors and Suppliers must recognize their obligations under the National Labor Relations Act and any state or local regulations concerning the right of employees to engage in collective organizing activities or the right to refrain from such activities. Subcontractors and Suppliers cannot interfere or subject employees to retaliation for exercising such rights.
- Health and Safety
Subcontractors and Suppliers are required to comply with applicable regulations (such as OSHA or Cal-OSHA) that promote a safe and healthy work environment including taking proactive to minimize known workplace hazards and potentially unsafe working conditions.
- Conflicts of Interest
A conflict of interest may exist when a Subcontractor or Supplier’s personal or private interest conflicts in any way with the interests of KBS. A conflict of interest may arise when family members receive inappropriate personal benefits because of your relationship with KBS. For example, it would be inappropriate to purchase supplies or services from a vendor that may be owned or operated by a family member instead of a more economical alternate supplier and then charge such expenses to KBS without prior disclosure and approval of the vendor by KBS. Transparency in Subcontractor and Supplier business practices with KBS is expected at all times.
Subcontractors and Suppliers must always avoid engaging in business practices with either public officials or representatives of private sector entities that could violate any bribery, corruption or unethical practice regulations that are applicable to KBS or any Subcontractor or Supplier such as the Foreign Corrupt Practices Act or other federal, state or local laws that prohibit payments or unethical relationships in conducting business. For example, it would be inappropriate to offer a public official or a private sector employee (such as a city council member, public employee, executive or employee associated with a building or site or their immediate family members), any type of payment, gratuity, kickback, favor, gift or other item or service of value, whether or not intended to influence a decision about a Subcontractor or Supplier’s business arrangements that relate to KBS.
- Financial Integrity
Subcontractors and Suppliers must keep accurate records of all matters related to their business with KBS consistent with standard accounting practices. All books, records, accounts and financial statements must be timely prepared and must accurately reflect transactions in a transparent manner.
- Gifts and Entertainment
Subcontractors and Suppliers may not offer gifts or entertainment to KBS’ employees or their family members, or anyone working on behalf of KBS, whether or not such gifts or entertainment are intended to improperly influence a business decision (such as price increases, guarantees of contracts, promises of non-termination of contracts or other favorable terms). This prohibition applies not only to any type of cash payments, which are never acceptable, but other types of gifts or entertainment to KBS employees or their family members such as tickets to sporting events, concerts or artistic performances, offers of lodging, hotels, free use of private vacation homes, airline tickets, jewelry, invitations to dinner, drinks, after hours’ venues, gaming establishments or similar forms of entertainment. Lavish holiday gifts (expensive bottles of liquor, crystal, home furnishings, sporting equipment such as golf clubs or bags) to KBS employees or their family members are also prohibited by Subcontractors and Suppliers.
Violations of the KBS Standards can be reported confidentially. If you have knowledge that any of these Standards are being violated, you are encouraged to report the conduct. Contact methods are listed below.
Subcontract Compliance Department
Fax Number: (267) 350-9035