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Supplier Code of Conduct

Purpose

The Dualit Ltd Supplier Code defines the standards that we expect our Suppliers to respect and adhere in order to ensure human rights and the environment are respected within our supply chain. The document is based on our continued commitment to international standards such as;

  • The UN Guiding Principles on Business and Human Rights.
  • The International Labour Organisation Declaration on Fundamental Principles and Rights at work.
  • The OECD Guidelines for Responsible Business Conduct

We also expect our Suppliers to meeting their obligations under the modern slavery act

Modern slavery is a crime resulting in an abhorrent abuse of human rights. The modern Slavery Act 2015 is intended to address the offences of slavery, servitude and forced or compulsory labour and human trafficking

For the purposes of this policy modern slavery relates to:

  • Slavery - The status or condition of a person over whom any or all of the powers attaching to the right of ownerships are exercised.
  • Forced Labour - Employed against a persons will.
  • Human Trafficking - Where a person arranges or facilitates the travel of another person with a view to them being exploited.

    Provisions of the Code

1. Employment is freely chosen

There is no forced, bonded or involuntary prison labour. Workers are not required to lodge 'deposits' or their identity papers with their employer and are free to leave their employer after reasonable notice.

2. Freedom of association and the right to collective bargaining are respected

Workers, without distinction, have the right to join or form trade unions of their own choosing and to bargain collectively.

The employer adopts an open attitude towards the activities of trade union and their organisational activities. Worker's representatives are not discriminated against and have access to carry out their representative functions in the workplace. Where the right to freedom of association and collective bargaining is restricted under law, the employer facilitates, and does not hinder, the development of parallel means for independent and free association and bargaining.

3. Health & Safety

A safe and hygienic working environment shall be provided, bearing in mind the prevailing knowledge of the industry and of any specific hazards. Adequate steps shall be taken to prevent accidents and injury to health arising out of associated with, or occurring in the course of work, by minimising, so far as is reasonably practicable, the cause of hazards inherent in the working environment.

Workers shall receive regular and recorded health & safety training, and such training shall be repeated for new or reassigned workers.

Access to clean toilet facilities and to drinkable water, and if appropriate sanitary facilities for food storage shall be provided.

Accommodation where provided shall be clean, safe, and meet the basic needs of the workers.

The company observing the code shall assign responsibility for health & safety to a senior management representative.

4. Child labour shall not be used

The ETI state that a child is any person under than 15 years of age, 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.

There shall be no new recruitment of child labour. Companies shall develop or participate in and contribute to policies and programmes, which provide for the transition of any child found to be performing child labour to enable her/him to attend and remain in quality education until no longer a child.

Children and young persons under 18 shall not be employed at night or in hazardous conditions. These policies and procedures shall conform to the provisions of the relevant ILO standards.

5. Wages

Wages and benefits paid for a standard working week meet, at a minimum, national legal standards, or industry benchmark standards, whichever is higher. In any event wages should always be enough to meet basic needs and to provide some discretionary income.

All workers shall be provided with written and understandable information about their employment conditions in respect to wages before they enter employment and about the particulars of their wages for the pay period concerned each time that they are paid.

Deductions from wages as a disciplinary measure shall not be permitted nor shall any deductions from wages not provided for by national law be permitted without the expressed permission of the worker concerned. All disciplinary measures should be recorded.

6. Working hours are not excessive

The Supplier must ensure that it's employees work in compliance with all applicable laws and mandatory industry standards pertaining to regular working hours, and overtime hours, including for breaks , rest periods, holidays and maternity and paternity leaves. Working hours, excluding overtime, shall be defined by contract.

All overtime shall be voluntary. Overtime shall be used responsibly, considering all the following: the extent, frequency and hours worked by individual workers and the workforce. It shall not be used to replace regular employment. Overtime shall always be compensated at a premium rate.

The total hours worked in any 7-day period shall not exceed 60 hours, except only in exceptional circumstances where all of the following are met:

  • This is allowed by national law.
  • This is allowed by a collective agreement freely negotiated with a workers organisation representing a significant portion of the workforce.
  • Appropriate safeguards are taken to protect the workers health & safety
  • The employer can demonstrate that exceptional circumstances apply such as unexpected production peaks, accidents, or emergencies.

Workers shall be provided with at least one day off in every 7-day period or, where allowed by national law, 2 days off in every 14-day period.

7. No discrimination is practiced & grievance system in place

There is no discrimination in hiring, compensation, access to training, promotion, termination, or retirement based on race, caste, national origin, religion, age, disability, gender, marital, status, sexual orientation, union membership or political affiliation.

All Suppliers must have in place procedures that enable workers to raise any grievances that they have and to have access to a fair hearing and remedy when the grievance is upheld. A grievance committee with decision making power, that is impartial, accessible and gender sensitive, should be in place.

8. Regular employment is provided

To every extent possible work performed must be based on recognised employment relationships established through national law and practice.

Obligations to employees under labour or social security laws and regulations arsing from the regular employment relationship shall not be avoided through the use of labour only contracting, subcontracting or home working arrangements or through apprenticeship schemes where this 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.

9. No harsh or inhumane treatment is allowed

Physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation be prohibited.

10. Grievance

Our Suppliers should have a grievance mechanism in place that enables individuals, workers, companies, including whistle blowers to raise their grievances. A grievance committee with decision making power, that is impartial, accessible and gender sensitive, should be in place to continuously monitor the grievance mechanism, keep records on the issues raised and take appropriate actions in a confidential manner.

11. Traceability & Record Keeping

Our Suppliers should have a system in place to ensure the traceability and accounting of certified and conventional volumes. There should be transparent and up to date records to demonstrate compliance with this.

12. Environment

We require our Suppliers to comply with all applicable legal environmental requirements and to demonstrate continual improvement of its environmental performance. The Supplier shall make sure it obtains, keeps current and follows the reporting guidelines of all the required environmental permits and registrations. This should cover all aspects of environmental protection including (as appropriate) such issues as energy management, pollution prevention, deforestation, biodiversity, waste and water management.

13. Anti-Bribery & Corruption

Our Suppliers must conduct business in an honest and ethical manner. As part of that, they must take a zero-tolerance approach to bribery and corruption and be committed to acting professionally, fairly and with integrity in all its business dealings and relationships, wherever it operates, and implementing and enforcing effective systems to counter bribery.

14. Continuous Improvement

We recognise that meeting our Standards is a dynamic process and non-compliance may not necessarily lead to disengagement. Instead, we encourage our Suppliers to work towards continuously improving their systems and we will support our Suppliers in their efforts to do so. By doing so we will ensure that we have prevented any potential negative impacts to our aim of respecting human rights and the environment in our supply chain and our own operations.