Human Rights and Labor Practices Policy

Purpose and Summary

Respect for human rights is deeply ingrained in our values, in how we run our business, interact with stakeholders, and engage with our global community. At NIBLL , we value diversity and equal opportunity and do not tolerate discrimination or harassment of any kind.

NIBLL  is committed to our employees, customers, future generations, and the communities where we live and work. This policy communicates our expectations with respect to human rights and labor practices and the high standard of conduct expected of our employees worldwide. This includes, but is not limited to, ethical and lawful practices concerning: discrimination, workplace health and safety, freedom of association, collective bargaining, child labor, human trafficking, forced or compulsory labor, and indigenous rights.


This policy applies globally to 1) all NIBLL employees including full time, part-time, and fixed-term employees; and 2) contingent workforce, including consultants, temporary workers and third-party vendors or consultants engaged on our behalf.


NIBLL adheres to the highest ethical conduct as outlined in the NIBLL  Business Code of Conduct in all aspects of business including inclusion and diversity, anti-discrimination and harassment, workplace safety, privacy, anti-corruption, human rights, and corporate sustainability. NIBLL operates on a foundation of our core values of accountability, customer focus, inclusiveness, innovation, integrity, and partnership which are expected to be followed by all employees, management and the board.

NIBLL respects fundamental human rights and views them as a key component of responsible corporate citizenship. In addition to supporting the fundamental principles contained in the United Nations Universal Declaration of Human Rights, we are committed to applying those principles in our daily operations, interactions with customers and vendors, and in our communities. We continue to work with suppliers to help uphold ethical human rights standards, as outlined in the NIBLL Vendor Code of Conduct.

Framework and principles

NIBLL  aims to abide by and uphold the principles of the Corporate Responsibility to Respect Human Rights that are part of the United Nations “Protect, Respect and Remedy framework.” NIBLL  also recognizes the UN Guiding Principles on Business and Human Rights as the global standard for identifying, preventing, and addressing the risk of adverse impacts on human and labor rights linked to our business activity. 

Risk assessment, prevention, and remediation

It is the responsibility of management to be alert to any potential violations and to ensure compliance with this policy. If a potential violation arises, then the manager must promptly notify our Corporate Compliance department and/or their Human Resources representative.

Should NIBLL  identify any risk of contributing to an adverse impact in the area of human or labor rights, it will take the necessary steps to cease or prevent its contribution and use its leverage with internal and external business networks to mitigate any remaining impacts to the greatest extent possible.

By doing so, and in accordance with its core business, NIBLL  pays special attention to international labor standards such as:

  • Non-discriminatory treatment and anti-harassment
  • Workplace health and safety
  • Minimum wages
  • No child labor
  • Voluntary employment
  • Freedom of association
  • Anti-slavery and human trafficking
  • Non-discriminatory treatment and anti-harassment

We are committed to an inclusive workplace environment free from acts of discrimination and harassment and strive to make all employment decisions based on job-related qualifications without regard to race, color, sex, age, disability, medical condition, physical appearance, marital status, national origin, ancestry, alienage or citizenship status, pregnancy, ethnicity, religion/creed, disability, genetic information, gender (including gender identity or gender expression, or status as a transgender person), sexual orientation, military or veteran status, marital or familial status, status as a victim of domestic violence, stalking or sex offenses, or any other category protected by applicable law (“protected characteristics”).

Workplace health and safety

We are committed to the health and safety of our employees, per our Workplace Health and Safety and Global Workplace Anti-Violence policies. We maintain a global program of regular education, emergency response planning and training to ensure individuals are equipped to identify and manage potential risks in our office workplaces. 

Minimum wages

We comply with local minimum wages. We use market and industry standards to apply fair wages where no wage law is in existence.

No child labor

We abide by local minimum age laws and do not use or condone child labor in any circumstance.

Working hours

We abide by all local working hour laws including local statutory limits on weekly hours worked. All overtime and/or statutory holiday hours are administered fairly; recorded accurately; paid correctly; and compliant with applicable employment standards legislation for the purposes of overtime pay.

Voluntary employment

We do not use forced or compulsory labor. All employment is voluntary.

Freedom of association

We respect the right of our employees to freely participate in labor unions, or choose not to participate, and the right to collectively bargain, in accordance with local law.

Anti-slavery and human trafficking

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labor, and human trafficking, all of which have in common the deprivation of a person’s liberty by another for personal or commercial gain.

NIBLL  has a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains.

We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we require commitments against the use of forced, compulsory or trafficked labor, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.

We prohibit trafficking of all persons in a range of exploitative practices, as defined by the United Nations Office of the High Commissioner for Human Rights.