California Water Service Group Supplier Code of Conduct

(Effective Date: April 25, 2023)

California Water Service Group and its subsidiaries (together the “Group”) conduct business based on the highest standards of ethics, integrity, honesty, and professionalism in our dealings with each other, our customers, our stockholders, the public, and government agencies. Such standards are essential to our long-term success. As such, we expect all suppliers to conduct their Group-related business at standards that reflect our commitment to ethical business practices.

Specifically, in addition to complying with all applicable laws, rules, and regulations, the Group suppliers shall adhere to the following Supplier Code of Conduct.  Any non-compliance may negatively impact our business relationship with a supplier.

Fair Dealing

  • Suppliers shall not engage in coercive, collusive, corrupt, fraudulent, obstructive, or otherwise prohibited practices in connection with any business relating to the Group, including during any competitive procurement process.
  • Suppliers shall seek to obtain competitive advantage solely through superior performance and/or products, and never through unethical, anticompetitive practices. Suppliers shall not take unfair advantage of anyone through manipulation, exaggeration, concealment, misrepresentation of facts, abuse of confidential or privileged information or any like practices.
  • The Group prohibits its suppliers from engaging in any form of corruption or bribery. Consistent with these prohibitions, suppliers must comply with the U.S. Foreign Corrupt Practices Act (FCPA), and any applicable local anti-corruption and anti-bribery laws. The Group encourage its suppliers to have anti-corruption and anti-bribery policies in place.
  • Suppliers must neither offer nor accept bribes, kickbacks, facilitation payments or any other similar inducements with the expectation of favored treatment.
  • Group employees are prohibited from soliciting or accepting gifts or business courtesies, including services, discounts or anything else of value when doing so may influence, or be perceived as influencing, a decision or action. Group employees may not accept non-cash gifts from anyone with whom the Group does business, unless that gift is nominal in value. Gifts of nominal value are those that do not exceed $150. Cash gifts or cash equivalents such as gift cards, gift certificates, checks or loans are never permitted. Immediate family members of the Group employees are subject to the same policy.

Conflicts of Interest

Suppliers and their respective personnel and affiliates shall be free from conflicts of interest when conducting business with the Group. A supplier may be considered to have a conflict of interest if:

    • It has at least one or more controlling partners who have a significant financial interest (more than 5% of a business ownership or more than 1% of the outstanding securities of a public company) in another bidder during a competitive procurement by the Group;
    • It has a relationship that may provide access to undisclosed information about a competitive procurement that could influence the decisions of the Group;
    • It participates in more than one bid for a single sourcing event for the Group; or
    • It has a family relationship with a member of the Group’s board of directors; senior executive team, or staff who is directly or indirectly involved in any part of a procurement decision, unless the conflict stemming from this relationship has been disclosed and resolved in a manner acceptable to the Group.
  • Suppliers shall disclose to the Group’s Procurement Department whenever they see an individual who, in the course of performing their work, is, can be, or appears to be influenced to subvert a Group decision making process for their or others’ gain.
  • Suppliers shall disclose to the Group’s Procurement Department any actual or potential conflicts of interest that impact or may impact their capacity to serve the best interest of the Group. Suppliers may also contact the Group’s Ethics Hotline at (408) 501-1720 with any concerns.

Providing a Safe and Secure Workplace

  • Suppliers shall establish and maintain a safe work environment, reducing and eliminating hazards and risks, establishing sound emergency procedures, and integrating safety management practices across their businesses.
  • Suppliers shall have a written policy that reflects a zero-tolerance policy regarding the possession and use of alcohol, drugs, fireworks, and firearms while on any Group property or while engaged in work for the Group.
  • We encourage our suppliers to have a Health and Safety Management Plan that is in compliance with the Group standards. Suppliers shall also conduct health and safety training periodically.

Maintaining Proper Conduct in the Workplace

  • Suppliers shall not discriminate against employees or applicants for employment on the basis of race, national origin, age, sexual orientation, gender identity, medical condition, marital status, disability, immigrant status, veteran status, union status, or any other characteristic protected by law or any other non-job-related factor in all areas of employee relations.
  • Suppliers shall prohibit unlawful harassment, including sexual harassment while on any Group property or while engaged in work for the Group.
  • While engaged in any business related to the Group, or whenever present on Group property or property of Group’s customers, suppliers shall require their employees, subcontractors, and representatives to comply with standards prohibiting conduct that is discriminatory, assaulting, threatening, sexual or of a suggestive nature, hostile, or in any other manner that might reasonably be construed as confrontational.
  • Suppliers shall provide excellent service and care of Group customers and the general public. Providing excellent service and care includes treating all personal interactions with professionalism, friendliness, and courtesy, regardless of the circumstances of the interaction. At no time shall suppliers’ employees or subcontractors use profane language or insult, demean, or otherwise use any disparaging terms, colloquialisms, or racially-biased language in communicating with the Group, its customers, government officials, government employees, or the general public in connection with any business related to the Group.

Safeguarding Confidential Information

  • Confidential Information is any information designated by the Group or its suppliers that could reasonably be considered confidential or proprietary at the time of disclosure, including information relating to critical infrastructure or trade secret information or any other Group intellectual property. Suppliers shall take all reasonable steps, including with respect to cybersecurity protections, to safeguard Confidential Information and prevent disclosure of Confidential Information to any third parties without prior approval by the Group.

Environmental Management

  • Suppliers shall conduct business in an environmentally responsible manner that actively mitigates environmental risks, conserves natural resources, and protects the environment.
  • Suppliers shall establish a systematic approach to manage risks, hazards, and opportunities associated with the environment.
  • Suppliers shall be able to identify specific design and supply chain activities that enable mitigation of the adverse environmental impact of its products and services throughout the life-cycle by considering factors such as energy consumption, materials use, and end-of-life treatment.
  • Suppliers shall be able to, upon request:
    1. Declare the full material content of products supplied to the Group.
    2. Declare product energy consumption and product energy efficiency.
    3. Supply life-cycle inventory data for supplier processes and products.
    4. Provide information concerning the process for handling and treatment of delivered products at the end of the products’ life.
  • To ensure compliance with environmental management standards and product safety, the Group may from time to time conduct on-site audits and assessments of suppliers.

Human Rights

  • Suppliers shall treat people with respect and dignity, encourage diversity, promote equal opportunity for all, and help create an inclusive and ethical culture.
  • We encourage our suppliers to treat their employees and to interact with their communities in a manner consistent with the United Nations Guiding Principles to Business and Human Rights in their business operations.

Labor Practices

  • We expect our suppliers to conform to the International Labor Organization Core Labor Standards, and the California Department of Industrial Relations Sweatfree Code of Conduct.
  • Forced Labor
    • Suppliers shall provide voluntary employment, where workers are free to leave work and terminate their employment or other work status with reasonable notice.
    • Suppliers shall never use involuntary labor or require the payment of fees or the surrendering of identification (immigration or work permit documents) as a condition of employment.
    • Suppliers shall never traffic workers or in any other way exploit workers by means of threat, force, coercion, abduction, or fraud.
  • Child Labor
    • Suppliers shall ensure that child labor is never used. Child labor refers to any person under the minimum legal age for employment where the work is performed. Under no circumstances shall a supplier permit children to perform work that exposes them to undue physical risks that can harm their physical, mental, or emotional development or improperly interfere with their education or vocational needs.
  • Working Hours and Wages
    • Suppliers shall follow all applicable laws and regulations with respect to wages, working hours, days of rest, and worker benefits.
  • Collective Bargaining
    • Suppliers shall recognize and respect the rights of employees to freedom of association and collective bargaining in accordance with local laws.
    • Suppliers shall not penalize or subject to harassment or intimidation workers for the non-violent exercise of their right to join or refrain from joining such associations and worker organizations.

Supplier Code of Conduct Flow Down

  • We encourage our suppliers to have practices in place to support compliance with laws, regulations, and expectations related to, or addressed expressly within the Supplier Code of Conduct. We encourage our suppliers to implement their own written code of conduct, and to apply the principles of such code of conduct to the entities that furnish goods and services to the supplier.

Supplier Diversity

  • It is Group policy that diverse business enterprises, including those categories recognized under the California Public Utilities Commission General Order 156 (for California Water Service Company) and Federal Subcontracting Programs (for all Group companies) shall have the maximum practicable opportunity to participate in the performance of contracts.
  • Suppliers agree to use their best efforts to award subcontracts (when applicable and available, and as required by contract with a Group company) with such diverse suppliers consistent with the efficient performance of their contract, and accurately report diverse subcontracting.

Supplier Compliance

  • Suppliers shall provide an anonymous complaint mechanism for workers to report workplaces grievances.
  • If a supplier believes that an employee or someone acting on the Group’s behalf has engaged in illegal, unethical or otherwise improper conduct or violated this Supplier Code of Conduct, the supplier shall immediately report this concern to:

    Shawn Bunting
    Vice President, General Counsel
    Address: 1720 N. First Street, San Jose, CA 95112
    Email: [email protected]

    Ethics Hotline, External: (408) 501-1720 | Internal: extension 80000

  • We reserve the right to verify compliance with this Supplier Code of Conduct. Suppliers shall maintain documentation to demonstrate their compliance and provide such documentation and any other relevant information to the Group upon request.
  • A supplier’s relationship with the Group will not be affected by a good faith report of potential misconduct.