Manufacturer Code of Conduct
At NBCUniversal, we are committed to:
– a standard in excellence in every aspect of our business
– ethical and responsible conduct in all of our operations
– respect for the rights of individuals
– respect for the environment
We expect that these same commitments to be shared by all manufacturers of NBCUniversal
Merchandise. At a minimum, we require that all manufacturers of NBCUniversal merchandise meet the
following standards:
Child Labor NBCUniversal manufacturers will not use child labor. Production
facilities that employ employees less than 16 years of age would be
considered in violation of the code of conduct and subject to immediate
termination of contract. The only exception to this requirement is applicable
to an approved vocational program workforce in Brazil where employees
under 16 years are allowed to work for credit only and are not exposed to
any potential health & safety hazards.
Involuntary Labor Manufacturers will not use any forced or involuntary labor, whether prison,
bonded, indentured or otherwise.
Harassment Each employee will be treated with respect and dignity and will not be
subjected to violence, punishment or abuse.
Nondiscrimination Manufacturers will employ fair practices in hiring and other practices
not limited to salary, benefits, advancement, termination on the basis of
race, religion, age, nationality, social or ethnic origin, gender,
political opinion, or disability.
Association The rights to associate organize, and bargain collectively will be respected
by manufacturers without penalty.
Health & Safety Manufacturers will provide employees with a safe and healthy workplace in
compliance with all applicable laws and regulations. The same
requirements will need to be met for employee housing.
Compensation At minimum, manufacturers will comply with all applicable wage and hour
laws and regulations including those relating to minimum wages, overtime,
maximum hours, and other elements of compensation, and provide legally
mandated benefits. If local laws do not provide for overtime pay,
manufacturers will pay at least regular wages for overtime work. Employees
will be entitled to at least one day off in every seven day period.
Protection of Environment Manufacturers will comply will all applicable environmental laws and
regulations including local and national codes.
Improper Payments Manufacturers will comply with all laws dealing with improper or illegal
payments and agrees to not pay, promise to pay or authorize the payment
of any money or offer anything of value to the NBCUniversal auditors
throughout the auditing process.
Monitoring & Compliance Manufacturers will authorize NBCUniversal and its designated partners
including third parties) to engage in monitoring activities to confirm
compliance with this code of conduct including on site inspections of
manufacturing facilities and employee housing, review of records relating
to employment and conduct interviews with employees. Manufacturers will
be required to maintain all documentation to demonstrate compliance with
this code of conduct.
NBCUniversal’s goal is that all findings are closed within the next 90 days for Red Flag and in 365 days for all
Yellow Flag findings. The factory should prepare a corrective action plan (CAP) with specific goals to close the
findings, including projected dates of completion.
NBCUniversal understands that certain findings will require action by local government agencies operating
outside the control of the factory. The factory must demonstrate their efforts to obtain permits,
certifications, licenses, etc., by supplying electronic evidence of applications, invoices, or any other certified
document as proof of their attempt to close the finding. When the official documents are issued by the local
agency, copies will need to be sent electronically to auditor for verification and to close the finding.
A representative from our auditing company will be contacting the site personnel within the next seven days
to help coach them through the follow-up process, to collect electronic evidence of the corrective actions,
and to document the progress. The audit closing specialist will also report the progress of the factory to their
NBC partners and vendor/licensee.
NBCUniversal reserves the right to conduct a follow-up audit of your manufacturing facility at any time if
needed. There will be annual re-audits of the facility at the discretion of NBCUniversal.