- Legal compliance
Company conducts its business in full compliance with the laws, rules and regulations of the countries where it operates.
- Organizational governance
Company has appropriate policies, procedures and management systems (informal or formal) in place to enable us to make and implement decisions, including decisions about SR.
- Anti-bribery and corruption
3.1 Company has a zero tolerance approach to bribery and corruption. Company is committed to conducting itself fairly, honestly and lawfully in all its business dealings and relationships globally. Company employees, agents and other representatives are prohibited from giving or receiving money or gifts which could be construed as bribes.
3.2 Company is bound by the laws of the UK, including the Bribery Act 2010, which governs our conduct both in the UK and worldwide. Company is also committed to upholding all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate.
- Anti-trust and fair competition
Company prohibits practices which seek to increase sales other than through legitimate sales and marketing efforts.
- Information security
Company seeks to maintain the confidentiality of commercial and personal information in its charge. Company has established an Information Security Management System (ISMS) framework to protect its information assets. An information asset is any information or information system which is sensitive, confidential or has value to Company, including third party information processed by Company.
- Whistleblowing
Employees can be the first people who realise in the event that there may be something wrong within the organization for which they work but sometimes feel inhibited in expressing their concerns. Company has a Whistleblowing Policy and provides a whistle-blower hotline to raise serious concerns to Company.
- Human rights, slavery & labour practices
Company treats its workers with respect, and works to ensure that their basic human rights are protected and promoted, including but not limited to:
7.1 Employment relationships
7.1.1 Company has a process that enables us to ensure that all workers on our premises are documented, and have a right to work legally.
7.1.2 Company ensures that all workers are provided with written and understandable information about their employment conditions, including wages, hours, and holidays, before they enter into employment; and about details of their wages for the pay period concerned each time that they are paid.
7.2 Employment is freely chosen
7.2.1 All work is conducted on a voluntary basis, and not under threat of any penalty or sanctions.
7.2.2 Workers are not required to lodge “deposits” or their identity papers with Company, labour providers or agencies to obtain work, and are free to leave after reasonable notice.
7.3 Modern Slavery
7.3.1 Company has a zero tolerance approach to Modern Slavery. It takes action to prevent slavery, servitude, forced or compulsory labour and human trafficking (modern slavery), a crime and a violation of fundamental human rights within its own business and supply chain, in line with the UK Modern Slavery Act (2015) requirements and guidance, and other country specific legislation.
7.3.2 Company reserves the right to require contractors, suppliers and other business partners to provide assurance that neither they, nor their own suppliers, engage in any form of Modern Slavery.
7.4 Freedom of Association and right to collective bargaining is respected
7.4.1 Workers, without distinction, have the right to join or form trade unions of their own choosing and to bargain collectively, without prior authorisation from management, according to national law.
7.4.2 Company adopts an open attitude towards worker representation and the activities of trade unions.
7.4.3 Company does not discriminate against or otherwise penalise worker representatives and gives worker representatives access to the workplace in order to carry out their representative functions, in accordance with national law and international labour standards.
7.4.4 Where the right to freedom of association and collective bargaining is restricted or prohibited under law, Company does not hinder workers from developing alternative mechanisms to express their grievances and protect their rights regarding working conditions and terms of employment.
7.5 Working conditions are safe and hygienic
7.5.1 Company provides a safe and hygienic working environment, bearing in mind the prevailing knowledge of the industry, legal requirements and of any specific hazards. Adequate steps are taken to prevent accidents and injury to health arising out of, associated with, or occurring in the course of work, by minimizing, so far as is reasonably practicable, the causes of hazards inherent in the working environment.
7.5.2 Workers receive regular and recorded health and safety training, and such training shall be
repeated for new or reassigned workers.
7.5.3 Access to clean toilet facilities and to potable water and, if appropriate, sanitary facilities for food storage is provided.
7.5.4 Accommodation, where provided, is clean, safe, and meets the basic needs of the workers.
7.5.5 Responsibility for health and safety shall be assigned to a senior management representative and regular risk assessments must be carried out.
7.5.6 Access to adequate medical assistance and facilities must be provided.
7.6 Child labour shall not be used
7.6.1 There is no recruitment of child labour. Company implements robust age verification checks as part of the recruitment process.
7.6.2 Company does not employ any person under the age of 15, unless local minimum age law stipulates a higher age for work or mandatory schooling, in which case the higher age shall apply. If, however, local minimum age law is set at 14 years of age in accordance with developing country exceptions under ILO Convention No. 138, the lower will apply.
7.6.3 Children and young persons under 18 are not employed at night or in hazardous conditions.
7.7 Compensation is paid
7.7.1 Company ensures that wages and benefits paid for a standard working week meet, at a minimum, national legal standards or industry benchmark standards, whichever is higher.
7.7.2 Company has a transparent process to ensure that workers understand their wages before they enter employment, and about the particulars of their wages for the pay period concerned each time that they are paid.
7.7.3 Company does not make deductions from wages as a disciplinary measure, nor shall any deductions from wages not provided for by national law be permitted without the expressed permission of the worker concerned. All deductions are recorded.
7.7.4 Wages are paid regularly and on-time.
7.8 Working hours are not excessive
7.8.1 Working hours comply with national laws, collective agreements, and the provisions of 7.8.2 to 7.8.5 below, which are based on international labour standards, whichever affords the greater protection for workers.
7.8.2 Working hours, excluding overtime, are defined by contract, and shall not exceed 40 hours per week*. All overtime is voluntary. Overtime is used responsibly, taking into account all the following: the extent, frequency and hours worked by individual workers and the workforce as a whole. It is not used to replace regular employment.
7.8.3 The total hours worked in any seven-day period shall not exceed 60 hours, except in exceptional
circumstances where all of the following are met:
- This is allowed by national law;
- It is allowed by a collective agreement, freely negotiated with a workers’ organization representing a significant portion of the workforce;
iii. Appropriate safeguards are taken to protect the workers’ health and safety;
- Company can demonstrate that exceptional circumstances apply, such as unexpected production peaks, accidents or emergencies;
7.8.4 Workers are provided with at least one day off in every seven-day period or, where allowed by national law, two days off in every 14-day period, as well as national holiday.
* International standards recommend the progressive reduction of normal hours of work, when appropriate, to 40 hours per week, without any reduction in workers’ wages as hours are reduced.
7.9 Discrimination and equal opportunities
7.9.1 Company treats all workers with respect and dignity.
7.9.2 Company bases the employment relationship on the principle of equal opportunity and fair treatment. Company does not engage in, support or tolerate discrimination in any area of employment.
7.9.3 Company does not discriminate against any worker based on race, caste, social or national or ethnic origin, language, belonging to an indigenous people, citizenship, economic grounds, religion, age, disability, gender identity or expression, marital status, pregnancy, maternity, paternity, caring responsibilities, sexual orientation, union membership or political affiliation or other opinion in hiring or employment practices such as applications for employment, compensation, rewards, access to training, promotion, job assignments, discipline, termination or retirement.
7.9.4 Company has an equal opportunity policy that promotes gender equity in employment practices, and states maternity and paternity leave provision and support for family care where appropriate.
7.10 Regular employment is provided
7.10.1 To every extent possible, work performed is on the basis of recognised employment relationships established through national law and practice and international labour standards.
7.10.2 Obligations to workers under labour or social security laws and regulations arising from the regular employment relationship are not avoided through the use of labour-only contracting, sub-contracting, or home-working arrangements, or through apprenticeship schemes where there is no real intent to impart skills or provide regular employment, nor shall any such obligations be avoided through the excessive use of fixed-term contracts of employment.
7.11 No harsh or inhumane treatment is allowed
7.11.1 Company commits to a workplace free of inhumane treatment and harassment.
7.11.2 Company prohibits, and does not tolerate, physical abuse or discipline, the threat of physical abuse,
sexual or other harassment and verbal abuse, corporal punishment, mental coercion, physical coercion or other forms of intimidation. Any disciplinary measures taken are recorded.
7.11.3 Company provides training on non-discrimination and harassment where possible.
7.12 Disciplinary procedures and grievances
7.12.1 Company has established written disciplinary procedures and explains them in clear and understandable terms to its workers. All disciplinary actions and performance management actions are recorded and explained to workers. Workers have the right to trade union or other appropriate representation at disciplinary action which may lead to significant disciplinary penalties or dismissal.
7.12.2 Company provides a grievance mechanism for workers (and their organizations, where they exist) to raise workplace concerns. This grievance mechanism involves an appropriate level of management and addresses concerns promptly, using an understandable and transparent process that provides timely feedback to those concerned, without any retribution. The mechanism also allows for anonymous complaints to be raised and addressed. The existence and scope of this mechanism is clearly communicated to all workers and their representatives, and all workers have equal access.
7.12.3 Company has developed processes for communicating and consulting with workers and their democratically elected representatives to share information on the business and to gather feedback.
- Environment
Company complies with all local and national environmental regulations. We seek to protect the environment and work to minimize negative environmental impacts from our operations, products, services and supply chain. Where practical to do so, actions include the prevention of pollution, reduction of waste, reduction of impacts associated with energy use and minimizing the use of natural resources. We also seek to undertake initiatives to promote greater environmental responsibility where possible.
- Community involvement and development
Where practical and appropriate, Company actively contributes to our local communities, undertaking activities such as: contributing to environmental protection, enhancing local environmental quality, supporting the education of communities at all levels, in particular the education of children, women and vulnerable groups in the local community and supply chain, the creation of employment opportunities, skills development, health improvement initiatives and social investment and philanthropy.