Ethical Sourcing Policy

Mitchells Nutrition Ltd

Ethical Sourcing Policy

1. Purpose

To ensure that all products, raw materials, packaging, and services sourced by Mitchells Nutrition Ltd are produced, delivered, and traded in ways that are socially responsible, environmentally sustainable, and legally compliant. This applies to all our suppliers—local (within NZ) and international—and extends throughout the supply chain.

2. Scope

• Applies to all suppliers, subcontractors & agents providing goods, services, materials, packaging etc. to Mitchells Nutrition Ltd.
• Includes any tier in the supply chain (raw materials, components, manufacturing, packaging, logistics).
• Covers labour practices, health & safety, environmental performance, and business integrity.

3. Core Principles

3.1 Legal Compliance

Suppliers must comply with:

• All applicable laws and regulations in the country(ies) where they operate.
• Relevant New Zealand laws/regulations for imports, food safety, labour, environment, and trade.

When local laws are less stringent than international human rights or environmental norms, we expect suppliers to follow higher standards where feasible.

3.2 Human & Labour Rights

• No forced, bonded, indentured labour, slavery or human trafficking.
• No child labour (workers must meet the legal minimum working age in their country; where legal minimum is lower than international standards or norms, the higher standard applies).
• Fair wages and benefits: at least meeting local minimums; enough for a decent standard of living (as far as possible).
• Reasonable working hours: in line with local law and internationally accepted norms; rest periods and leave must be respected.
• Freedom of association: workers should be free to join trade unions or equivalent, and collective bargaining where allowed by law.

3.3 Health, Safety, and WellBeing

• Safe, hygienic working conditions; conforming to all relevant health & safety regulations.
• Adequate training, supervision, protective equipment.
• Clean facilities: drinking water, sanitation, rest and break areas.
• Where accommodation is provided by supplier, it must be safe and meet basic welfare standards.

3.4 Environmental Responsibility

• Suppliers must strive to minimise adverse environmental impacts: waste, pollution, resource use (water, energy).
• Suppliers should comply with environmental laws and regulations in their countries.
• Use of environmentally preferable materials (e.g. recyclable, certified, sustainably sourced) where possible.
• Support for continuous improvement in environmental performance.

3.5 Business Ethics & Integrity

• No bribery, corruption, fraud, extortion or any form of unethical business practices.
• Transparency in business dealings, including accurate records, open communication.
• Avoid conflicts of interest.
• Respect for intellectual property, confidentiality, data protection as relevant.

3.6 Sustainable Sourcing Preference

We aim to favour:

• Suppliers who meet thirdparty certifications (e.g. organic, fair trade, forestry certifications, etc.).
• Local NZ suppliers where possible, especially where they have strong ethical, environmental, and quality credentials.
• Suppliers who can show traceability in their supply chain and who are working on continuous improvement in ethical and environmental practices.

4. Supplier Responsibilities & Monitoring

• Suppliers must provide documentation or evidence of compliance (e.g. certification, audits, policies).
• Mitchells Nutrition Ltd may conduct supplier evaluations or audits (self‐assessment, thirdparty audits) especially for high risk or large scale suppliers.
• Suppliers should permit facility inspections where required.
• If noncompliance is identified, supplier must work with us to rectify, with a corrective action plan.

5. Risk Assessment & Priorities

• Supplier risk assessment based on factors like country of origin, type of product/material, labour risk profile, environmental risk.
• Focus monitoring and continuous improvement on highrisk suppliers or supply chains.

6. Continuous Improvement & Transparency

• We will continuously review this policy, supplier practices, and industry best practices.
• We will engage with suppliers to provide support, training or capacity building if needed.
• We will report (in our sustainability or annual report) on progress, challenges, and improvements in our supply chain.

7. Enforcement & Consequences

• Compliance with this policy is a condition of doing business with Mitchells Nutrition Ltd.
• Persistent or serious breaches (especially those involving forced labour, child labour, major environmental damage, or corruption) may lead to termination of supplier contracts.

8. Stakeholder Engagement

• We will engage with relevant stakeholders (NGOs, auditors, industry bodies, customers) to understand expectations, emerging risks, and improvements.
• We will seek feedback from suppliers, employees, and other stakeholders on the implementation of this policy.

9. Policy Governance

• The policy is authorised by the Board / Executive Team of Mitchells Nutrition Ltd.
• Daytoday responsibility for implementation falls to procurement / supply chain management.
• Regular reviews (annually) of the policy and practice to ensure relevance, effectiveness.