Terms of Implementation

All Vendors must post the Comnez Code of Conduct in places in their offices or premises readily accessible to workers, translated into the language of the workers and supervisors and communicate these provisions to all workers. Vendors shall take appropriate steps to ensure the provisions of this Code of Conduct are communicated to all workers. Upon employment, as part of worker orientation, the Comnez Code of Conduct shall be presented to workers and explained to them. From time to time Vendors shall periodically review the Comnez Code of Conduct with workers.

All Vendors are obliged to take the measures necessary to implement the COMNEZ Code of Conduct:

Management Responsibilities

  • By informing management and Vendors about the content of the Comnez Code of Conduct.
  • By establishing where responsibility lies within the company’s organization regarding Comnez Code of Conduct issues.
  • By appointing one or more management employees to be responsible for implementation of the Comnez Code of Conduct.
  • By monitoring company compliance with the Comnez Code of Conduct and implementing necessary changes at its facilities.

Legal Requirements

  • By complying with all legal requirements applicable to the conduct of their respective businesses. This not only includes compliance with this Code of Conduct but also compliance with the terms and conditions of contracts issued on behalf of Comnez.
  • By compliance with all laws and regulations of the United States Customs and Border Patrol, and all other governmental regulatory agency policies.

Employee Awareness

  • By giving a statement of their support for the principles of the Comnez Code of Conduct to their employees and by informing and instructing their employees and those of their subcontractors regarding the contents of the Comnez Code of Conduct. The company must have the Comnez Code of Conduct translated in its entirety into the appropriate local language(s) ad have it displayed in a prominent position at its facility and other premises. Employees must also receive verbal orientation and information regarding Code of Conduct in a language they understand.


  • By keeping records of names, ages, working hours and the wages paid to all employees and making those documents available to auditors on request.
  • By keeping up to date documentation regarding relevant statutory requirements and regulations.

Complaints and Corrective Action

  • By appointing an employee responsible for handling complaints related to Comnez issues.
  • By documenting and investigating complaints from the employees or third parties related to Comnez issues, and reporting on their substance and any necessary corrective measures arising from them.
  • By making the resources available to implement necessary corrective measures.
  • By refraining from dismissals or other disciplinary measures against employees who pass on information regarding compliance with the Comnez Code of Conduct.


  • By making the introduction of social standards and compliance with the Comnez Code of Conduct a condition of all contracts into which it enters with sub-contractors.
  • By asking Vendors to report regularly about their progress in implementing the Comnez Code of Conduct.


  • By providing Comnez representatives with relevant information about their activities and all production sites.
  • By allowing audits of their business premises and activities and those of their subcontractors to be carried out at any time with or without prior notice by organizations acting on behalf of Comnez.

Consequences of Non-Compliance
Vendors must apply these principles at all times and must be able to demonstrate that they are doing so. However, if a Vendor fails to meet the requirements of the Comnez Code of Conduct Comnez and/or our representatives will work with the Vendor to establish the necessary improvements. We will also take action which may involve cancelling contracts if Vendors are not prepared to make appropriate changes. If no solutions can be agreed upon and implemented within a reasonable amount of time, Comnez and/or our representatives may choose to halt current production, cancel corresponding contracts, suspend future contracts and/or terminate the business relationship with the noncompliant Vendor. If an audit reveals less than full compliance with the Comnez Code of Conduct, the Vendor must take the prescribed corrective actions without delay. The period of time the Vendor has to implement corrective measures will be agreed upon with Comnez and/or our representatives and will correspond to the severity of the violation, but may not exceed twelve months. If a Vendor excluded in the past on grounds of noncompliance can later show full compliance with the Comnez Code of Conduct, there is, in principle no reason why a business relationship cannot be resumed.