Supplier Ethical Code Policy
1. INTRODUCTION
The Simply Brands (Asia) Ltd Supplier Ethical Code sets out the standards of employment and working conditions that are required throughout Simply Brands (Asia) Ltd’s supply chain. The standards are intended to meet societal and industry expectations, national legislation and International Labour Organisation (ILO) Conventions.
Employers (as defined below) must treat Workers (as defined below) with basic levels of respect and dignity. We use the standards as a tool to assist us in selecting and retaining business partners who follow business practices consistent with our policies and values. As a set of guiding principles, the Simply Brands (Asia) Ltd Code also helps our Suppliers identify potential problems so that we can work together to address issues of concern as they arise.
The Code applies to all organisations that manufacture or procure goods or services for Simply Brands (Asia) Ltd (“Suppliers”), along with Recruitment Agencies, contractors, Sub-Contractors, Labour Providers and Homeworkers who provide labour resources to the supply chain.
Suppliers must comply with all applicable legislation and also with elements of the Code where these go beyond what is required by law.
It is the Supplier’s responsibility to ensure that the requirements of the Code are met across all of its manufacturing sites and by all Sub-Contractors, Recruitment Agencies and Labour Providers who supply labour resources to these sites. Suppliers must be able to demonstrate to Simply Brands (Asia) Ltd that they have carried out sufficient steps to communicate the standards contained within the Code, to monitor levels of compliance and to remediate any areas of non-compliance.
The Employer must implement a culture where all Workers feel safe and are respected by their colleagues. The need for a respectful and dignified working environment must be communicated so everyone understands the boundaries of acceptable behaviour. Simply Brands (Asia) Ltd will support Suppliers and their supply chains who disclose difficulties in meeting the requirements of this Code and seek to work with them to put in place necessary improvements or remediation measures.
1.1. Business Integrity
Simply Brands (Asia) Ltd recognises the importance of the Bribery Act 2010 in combatting global corruption and fosters a culture across its operations to resist and eliminate corruption in all its forms. There shall be no improper advantage sought, including the payment of bribes, to secure business with Simply Brands (Asia) Ltd, or to influence the outcome of an independent audit or review.
As part of our commitment to high standards of business integrity, Simply Brands (Asia) Ltd expects its Suppliers to disclose full and accurate information to personnel carrying out periodic audits or reviews to enable them to make a full assessment of all Supplier sites. Attempts to withhold or falsify essential information requested by an Simply Brands (Asia) Ltd representative shall be treated as a serious non- compliance.
Simply Brands (Asia) Ltd reserves the right to withdraw orders immediately and without notice if there is evidence of a Supplier (or agent of a Supplier) being complicit in bribery or corruption, including any attempt to bribe an Simply Brands (Asia) Ltd representative.
Simply Brands (Asia) Ltd reserves the right to withdraw orders and terminate the Supplier Agreement with any Supplier who conceals, falsifies or withholds information that is material to the business relationship with Simply Brands (Asia) Ltd.
1.2. Compliance with All Applicable Laws & Regulations
Suppliers must understand and comply with all applicable laws and regulations, including laws relating to business integrity, employment, health and safety, and environmental protection. Where the requirements of this Code exceed what is required by law, these requirements must be met in addition to legal compliance.
The Employer must take the necessary measures to ensure that all Workers have a legal right to work.
Simply Brands (Asia) Ltd holds its Suppliers responsible for reporting to Simply Brands (Asia) Ltd any potential or actual breach of applicable laws relating to the operations of Supplier sites and employment of Workers.
Simply Brands (Asia) Ltd requires its Suppliers to actively adopt zero tolerance of any form of forced or compulsory labour associated with the supply chain. This applies to Employers, Sub-Contractors, Recruitment Agencies and Labour Providers used throughout the supply chain. Any actual or suspected cases must be immediately reported to Simply Brands (Asia) Ltd.
2. DEFINITIONS
For the purpose of this Code, Simply Brands (Asia) Ltd recognises the following definitions:
2.1. Child – A “Child Worker” is defined as someone who has not reached their 15th birthday, or any higher age specified in local law for completing mandatory schooling or beginning full time work. However, in strictly limited circumstances, where local law sets the minimum age at 14 years, under ILO convention 138 in accordance with developing country exceptions, the lower will apply.
2.2. Child Worker – a Child who is not legally entitled to work i.e. below the minimum age of employment or is under the age of 15 if this is higher.
2.3. Child Labour – a general term that includes the employment of a Child Worker or a situation where a Young Worker is exposed to Hazardous Work.
2.4. Contract Worker – a contract Worker is someone who is employed, or managed by a third party.
2.5. Destination Country/Territory – the country/territory where the migrant Worker will work.
2.6. Direct employment – an arrangement where a Worker is employed directly by the Supplier.
2.7. Discrimination – any form of unequal treatment that is not permitted by law; to include unequal treatment based on age, disability, gender reassignment, marriage and civil partnership, race, religion or belief, sex, and sexual orientation. Discrimination also includes discrimination on the grounds of work status i.e. part-time Worker, fixed term Employee, Agency Worker or Trade Union membership.
2.8. Employer – an Employer is a legal entity that provides any form of (permanent, casual, full or part time) work in return for remuneration and that controls and directs Workers at the workplace.
2.9. Employment – a situation where someone, who is not self-employed, agrees to perform a job, service or task in return for a form of remuneration. The term covers direct employment i.e. for an Employer, or indirect employment i.e. through a Labour Provider other form of agency. Someone providing work is deemed to be employed, regardless of the nature of (or absence of) an employment contract and regardless of the regularity of work, or number of hours worked.
2.10. Forced or Compulsory labour – all work or service which is exacted from any person under the menace of any penalty and for which the person has not offered himself voluntarily.
2.11. Hazardous Work – any work which, by its nature or the circumstances in which it is carried out, is likely to harm the health and safety of Workers. This includes: working with chemicals, machinery or electrics; working in confined spaces, at height or in excessively hot or cold conditions; being exposed to dust, fumes or loud noise; lifting or carrying heavy loads; working overtime or working at night.
2.12. Homeworker – a Worker who performs a stage of manufacturing, assembly or packaging in his or her home or in other premises of his or her choice, other than the workplace of the Employer.
2.13. Indirect employment – an arrangement where a Worker continues to be employed or managed by an agency or Labour Provider while they are working for the Supplier.
2.14. Labour Provider – an organisation that employs or manages Workers on behalf of a Supplier.
2.15. Migrant Worker – a migrant Worker is a person who migrates from one territory or country to another in order to seek employment.
2.16. Overtime – includes hours worked in excess of normal, agreed or contracted daily or weekly working hours.
2.17. Recruitment Agency – an organisation that arranges work for Workers in return for a fee.
2.18. Sending Country/Territory – the home country, territory or region from which the Worker has migrated.
2.19. Sub-Contractor – any entity (other than a Recruitment Agency or Labour Provider) that provides an element of manufacturing, assembly, packaging or a non-stock service to a Supplier.
2.20. Supplier – an organisation that manufactures or procures goods or services.
2.21. Worker – anyone who is doing work for an Employer, either directly through a Labour Provider or through a third party.
2.22. Young Worker – a young person who is legally entitled to work i.e. above the minimum age of employment of 15 and below the age of 18.
1. TERMS OF EMPLOYMENT
1.1. All Workers’ terms of employment must apply with applicable legislation.
1.2. As a minimum, there must be agreed terms of employment in place between the Worker and the Employer before the Worker commences work.
1.3. Workers must be employed voluntarily and have the freedom to leave their employment.
1.4. Workers must be hired and treated based on their ability to carry out their work and their performance. There must not be any form of discrimination or preferential treatment in the hiring, terms of employment, levels of pay, opportunities and treatment of Workers.
1.5. The Employer must make every effort possible to provide regular, secure employment. The use of temporary contracts or agency labour must not be used as a means of denying Workers their rights or benefits under employment law.
1.6. Apprenticeships and training contracts are encouraged, but must be compensated properly and provide adequate levels of training or development. The health, safety and welfare of apprentices employed under such schemes must be safeguarded.
1.7. The responsibility for communicating terms of employment to Migrant and Contract Workers must be well-defined in contracts between the Supplier and recruitment Agencies or Labour Providers. Such contracts must include responsibility for essential induction training.
2. FORCED OR COMPULSORY LABOUR
2.1. The Employer shall not use forced, bonded or involuntary prison labour. All people working within the supply chain must be;
2.1.1. Voluntarily recruited and employed;
2.1.2. Employed legally with a valid right to work;
2.1.3. Free from any form of coercion or threat;
2.1.4. Free of any debt to their Employer or Recruitment Agency;
2.1.5. Paid in full, on time and at a level that meets or exceeds the applicable minimum wage;
2.1.6. Free to leave their employment, given reasonable notice.
2.2. Workers shall be allowed to consult with doctors during working hours.
2.3. No deposit or fee shall be retained for securing work or accommodation, tools, training or personal protective equipment (PPE) or for any other reason.
2.4. There shall be no unreasonable restrictions on Workers’ freedom of movement relating to entering or exiting accommodation or sites of employment.
2.5. Employers, Recruitment Agencies and Labour Providers must not deny Workers access to their identity or immigration documents. If these are held for safe keeping, it must be done voluntarily with the Worker being able to re-claim such documents on request.
2.6. Workers shall not be required to pay Employers’ or agents’ recruitment fees or other related fees for their recruitment and must not be bonded through other loans or fees. If any such fees are found to have been paid by Workers, such fees must be repaid to the Worker by the Employer, including international travel costs.
3. FREEDOM OF ASSOCIATION AND THE RIGHT TO COLLECTIVE BARGAINING
3.1. Workers must be able to communicate openly with their Employer regarding working conditions without fear of reprisal, intimidation or harassment.
3.2. Workers must be free to associate or to join Trade Unions or other organisations that represent them. The Employer must not prevent, or discriminate against, Workers who wish to associate or bargain collectively. The decision whether or not to associate should be made solely by the Workers.
3.3. Employers must not attempt to influence the election or choice of Worker representatives or seek to influence a Worker representative to act in the management’s interest.
3.4. The Employer shall adopt an open attitude towards the organizational activities of Trade Unions. There should be open communication channels between Employers and Workers regarding conditions without threat of reprisal, intimidation or harassment.
3.5. Where local laws restrict freedom of association and Trade Unions, Employers will allow Workers to form Worker groups/committees, if they so choose. There must not be an unequal representation of management to Workers within these groups/committees.
3.6. Where Employers are legally required to consult with Workers, these requirements must be met in full. Formal committees must meet regularly, be adequately attended and operate effectively in the interests of Workers.
3.7. Workers must be allowed to stand as Worker representatives on Trade Unions, works councils or other formal representative groups. They must not be restricted, penalised or discriminated against and must have access to management and co-Workers in order to carry out their representative functions.
3.8. Where Migrant and/or Contract Workers are employed, they must be adequately represented.
3.9. Agreed collective bargaining documentation shall be communicated to Workers and available for the workforce to review.
4. WAGES AND WORKING HOURS
4.1. Wages and benefits
4.1.1. Workers’ wages for a standard working week should meet or exceed national legal standards or the industry benchmark standards, whichever is higher and be at least sufficient to meet basic needs and provide some discretionary income.
4.1.2. Remuneration must comply with agreed contracts, be on time and made in full. Clear written details must be provided to each Worker, showing how the remuneration has been calculated.
4.1.3. Wages shall be paid at least monthly.
4.1.4. The Employer shall provide to the Workers written and understandable information on the wage calculation including:
• hours worked or piece rate if appropriate;
• pay rate;
• gross pay;
• overtime pay;
• itemised deductions; and
• net pay.
4.1.5. Overtime must be offered fairly, paid and managed in accordance with the employment contract and comply with applicable legislation.
4.1.6. Workers must be provided with all benefits they are entitled to under national or local law e.g. paid leave, bonus, sick pay and/or social security payment contributions and provided to the Worker in a written and understandable form.
4.1.7. Where Workers’ basic remuneration is based on their output (piece-rate), the payment must still meet the legal minimum wage. A formal, agreed piece-rate calculation must be in place which ensures that Workers are paid fairly and are able to meet the legal minimum wage, or above, within normal working hours.
4.1.8. The Employer shall pay wages directly to the Worker concerned in legal tender, except as maybe otherwise provided by national laws or regulations or collective agreement arbitration award.
4.2. Deductions
4.2.1. Legally required deductions that entitle Workers to state benefits must be made and passed on by the Employer to the State.
4.2.2. The cost of clothing and protective equipment required to perform work safely must be paid in full by the Employer.
4.2.3. Deductions from wages or any other form of financial penalty must not be used as a disciplinary measure.
4.3. Working hours
4.3.1. The work schedule shall be documented and communicated to the Workers and include the hours at which work begins and ends, as well as where these duties shall be carried out.
4.3.2. Working hours must comply with national laws and collective agreements.
4.3.3. Further to clause 4.3.2, regular working hours shall not exceed 48 hours per week, or exceed 60 hours in any 7-day period (except where covered by clause 4.3.4).
4.3.4. Working hours may exceed 60 hours in any seven-day period only in exceptional circumstances where all of the following are met:
• this is allowed by national law;
• this is allowed by collective agreement, freely negotiated with the Workers’ organisation representing a significant portion of the workforce;
• appropriate safeguards are taken to protect the Workers’ health and safety.
4.3.5. Workers shall be provided with at least one day off in every 7-day period or, where allowed by national law, two days off in every 14-day period.
4.3.6. Overtime must be offered fairly, contracted voluntarily and paid in accordance with applicable legislation. It must not be used to replace regular employment.
4.3.7. Workers must be able to refuse to work overtime without any form of penalty. Workers who refuse overtime must not be denied the opportunity to work overtime in the future.
4.3.8. There must be adequate management systems in place to ensure weekly working hours are controlled within the above limits, except in emergency or unusual situations.
4.3.9. Every Worker shall be entitled to a period of paid holiday leave each year, which is in line with national law.
4.3.10. Every Worker shall be entitled to take reasonable absence from work on the grounds of genuine incapacity through illness, without financial penalty or threat of dismissal. During any such leave the Worker should continue to receive, as a minimum, a reasonable payment to meet basic needs.
5. CHILD LABOUR AND YOUNG WORKERS
5.1. Child Labour
5.1.1. A “Child Worker” is defined as someone who has not reached their 15th birthday, or any higher age specified in local law for completing mandatory schooling or beginning full time work.
5.1.2. However, in strictly limited circumstances, where local law sets the minimum age at 14 years, under ILO convention 138 in accordance with developing country exceptions, the lower will apply.
5.1.3. Child Workers must not be involved at any point in the manufacture or supply of goods to Simply Brands (Asia) Ltd.
5.1.4. Employers shall develop a system to verify the ages of new Workers including checking original identity documents and cross-referencing with Worker’s photograph.
5.1.5. Employers shall develop a system to prevent borrowed identity documents including spot- checking the availability of the identity documents of existing Workers periodically.
5.1.6. Copies of age records shall be retained in the workplace.
5.2. Young Workers
5.2.1. Where young Workers are employed the Employer must comply with the relevant legal requirements in that region/country. These may include carrying out health and safety risk assessments for young people, restricting working hours and with the relevant contracts and permissions drafted and implemented.
5.2.2. Employment of Young Workers must be managed in accordance with Simply Brands (Asia) Ltd Child Labour, Remediation and Young Worker Policy and applicable legislation.
5.3. Preventing Children from Entering Production Areas
Children must not be permitted in production areas at any time, even if they are above the minimum age of employment. This includes the Children of Workers who live in factory accommodation and Children brought to care facilities on site.
Supplier responsibilities
5.3.1. Ensure Children cannot enter production areas;
5.3.2. All Workers and auxiliary Workers e.g. security guards, cleaners understand that Children cannot enter production areas under any circumstance;
5.3.3. Provide safe and adequate supervision of Children living in factory accommodation;
5.3.4 Provide safe and adequate supervision of Children brought to the factory whilst their parents/guardians work.
Supplier prevention systems must include:
5.3.5. Full security and monitoring of all site entrances (when facilities are open and/or accessible);
5.3.6. Clear procedures for checking, verifying and recording the identity and age of all visitors;
5.3.7. Security personnel who are fully trained on and understand procedures;
5.3.8. Enforcement of minimum age requirements within production areas.
5.4. Requirement for Children Using Factory Facilities
5.4.1. Factories with Children living in factory accommodation must:
5.4.2. During work time, ensure Children have proper adult supervision from a parent, guardian or nominated and approved adult;
5.4.3. Be accompanied by a trained care giver, their parent or guardian when walking to Child-permitted areas;
5.4.4. Have a registered guardian(s) who have the right to collect Children and take them off the production site – security personnel should retain secure copies of guardians’ photo identification at site entrances/exits;
5.4.5. Ensure facilities are safe for Children e.g. railings on staircases;
5.4.6. Keep a register of all Children living on site, next of kin and other key contacts;
5.4.7. Provide appropriate play areas (separate to the production area).
5.5. Factories with Children being cared for at on-site facilities e.g. crèches
5.5.1. Ensure Children of school age attend school. They can stay in on-site facilities after school hours and during school holidays;
5.5.2. Have a parent and/or guardian’s written consent to place Children the in facility;
5.5.3. Be accompanied by a trained care giver, their parent or guardian from site gates to Child-permitted areas;
5.5.4. Employ carers who can demonstrate sound Child care experience and have no criminal history;
5.5.5. Employ sufficient number of carers for the number of Children;
5.5.6. Provide training to carers on Child care and site policies and procedures;
5.5.7. Permit parents/guardians to visit their Children during breaks;
5.5.8. Ensure Children are collected by their registered parent/guardian within a reasonable time period;
5.5.9. Ensure Children are never left without a carer;
5.5.10. The Child-care facility is separate to any production area/building;
5.5.11. The Child-care facility is structurally safe and fit for purpose e.g. has clean running water for drinking and bathing, resting areas, toys, activities, proper ventilation and means for temperature control;
5.5.12. Provide food and drink for Children.
6. DISCRIMINATION
6.1. Discrimination in any form, based on race, colour, language, nationality, ethnic or social origin, religious belief, political opinion, gender, marital status, disability, property, birth, age, sexual orientation or Trade Union membership shall not be permitted.
6.2. The employment practices and policies of the workplace shall afford all Workers equality of treatment.
6.3. Decisions or practices which are based on unfair discriminatory grounds, rather than on merit, will not be acceptable.
6.4. No job applicant should be unfairly refused employment or offered employment on less favourable terms due to discriminatory practices.
6.5. All Workers should have equal access to jobs, training, promotion and transfer and no one should receive less favourable wages, benefits or access to facilities on grounds of discrimination. The Employer shall develop a policy on discrimination of recruiting, wages, benefits, promotion, training, transfer, termination, retirement or access to facilities.
6.6. Employers are expected to adopt and adhere to a fair disciplinary procedure. No Worker should face or be threatened with discrimination in any form and no Worker should receive disciplinary action or dismissal on grounds of discrimination. Similarly, no Worker should be unfairly selected for redundancy or lay-off based on discrimination by the Employer.
7. RESPECTFUL TREATMENT OF WORKERS
7.1. Corporal punishment, physical, mental or verbal abuse, sexual harassment or other forms of intimidation, harsh, or inhumane treatment shall not be allowed.
7.2. The Employer shall protect their Workers from bullying, verbal or physical harassment, victimisation, discrimination or physical abuse in the workplace, whether from management, from their colleagues or from members of the public.
7.3. The Employer shall develop written grievance and disciplinary procedures for the workplace and communicate these to the Workers.
7.4. A fair disciplinary and grievance procedure shall be established and adhered to in all cases of alleged Worker misconduct or unsatisfactory performance.
7.5. All disciplinary and or grievance measures must be recorded.
7.6. An appeal channel shall be developed and implemented for Workers facing disciplinary action.
7.7. Workers undergoing discipline must have the right to representation by a Trade Union or Worker representative and to a fair appeal.
7.8. Workers who raise grievances must not be penalised or intimidated.
8. HEALTH, SAFETY AND SECURITY
8.1. Management systems
8.1.1. The Employer must have adequate management systems to predict hazards and protect the health and safety of all people at their place of work and under the Employer’s control, including Homeworkers. This must include a formal and regular assessment of risks, implementation of safe systems of work, the reporting of incidents and a programme of continuous improvement in safety performance.
8.2. Working Conditions
8.2.1. Employers must provide and maintain a safe and healthy work place and working environment.
8.2.2. Workplace
• The workplace must be safe, clean and of sound structure.
• Clean drinking water must be provided and readily accessible.
• The workplace must be well ventilated and illuminated.
• Workers must be protected from extreme temperatures.
8.2.3. Toilets
• Toilets must be clean and free from foul odour and readily accessible.
• Toilets must be equipped with flushing and washing water.
• There must be at least one male room and one female room for every two floors.
• Toilets shall have doors to protect privacy and any windows shall be opaque.
8.2.4. Canteens
• Food storage and preparation areas shall be clean and hygienic.
• Cooks shall be trained in food preparation hygiene.
• If food utensils are re-used, they shall be clean and sterilised.
• Facilities should be provided for eating meals and rest during breaks.
8.3. Fire Safety and Evacuation Procedures
8.3.1. Smoking Policy
• Employers shall develop a policy on smoking and communicate it to all Workers.
• Signs shall be posted where smoking is prohibited.
8.3.2. Evacuation Procedures
• Evacuation plans, including procedure, layout and assembly points, shall be posted in prominent areas in a language that Workers understand.
• Emergency drills shall be conducted at least every 6 months in both the workplace and dormitories (if relevant).
• The procedure shall be documented and communicated to all Workers.
• Employers must develop a written evacuation procedure for emergencies such as fire, chemical spillage, natural disaster and electricity failure.
8.3.3. Walkways, Stairs and Exits
• Fire exits and escape routes shall be adequately signed, well maintained, free from obstruction and easily opened.
• Walkways shall be at least one metre (40inches) wide and pathways shall be free from obstruction and tripping hazards.
• Stairs shall have adequate and secure handrails and are clear from obstruction.
• There shall be at least two emergency exits on each floor.
• Floor and roof openings shall be covered or guarded to prevent falling.
8.3.4. Fire Training
• Where applicable, fire training shall be conducted annually to ensure Workers understand how to use firefighting measures. All training must be recorded.
8.3.5. Fire Protection Equipment
• At least one fire extinguisher with adequate extinguishing instruction shall be provided within every 75ft in distance or per 1,000ft2.
• Emergency lighting shall be provided in the direction of escape route in case of power failure.
• Fire alarms with or other means shall be provided on all floors to warn staff of evacuation.
• All electrically installed fire alarms shall have a back-up power supply.
• Fire protection equipment shall be immediately accessible and free from obstruction.
• Fire doors shall be fitted and must meet local legislation and/or industry standard specification.
• Fire extinguishers, hydrants, hose reels, sprinklers, smoke/heat detectors, emergency lights and fire alarms shall be inspected monthly for damage and obstruction.
• Fire extinguishers, hydrants, hose reels, sprinklers, smoke/heat detectors, emergency lighting and fire alarms shall be inspected and maintained by qualified personnel annually.
8.4. Medical Programmes
• The Employer shall provide adequate and appropriate first aid facilities for their Workers in case of injury or illness at work.
• To help prevent future accidents, accident procedures should be put in place covering accident reporting and logging, accident investigation and analysis, and learning from accidents to prevent them happening again.
• The workplace shall have at least one qualified first aider on each floor and in each shift, and at least one for every 50 Workers in facilities of under 100 people; for workplaces in excess of 100 Workers, a ratio of one trained first aider for every 100 people or part thereof.
• First aid supplies shall be readily available and managed by designated personnel.
• First aid supplies shall be provided free of charge.
• First aid signs shall be posted with first aid boxes.
• Young persons under eighteen years of age shall not commence employment until a thorough medical examination is conducted to show they are fit for work. Young persons under 18 years of age shall be subject to repeat medical examinations annually.
• Annual medical examinations shall be provided for Workers using respiratory protection equipment as part of their job.
• Where local legislation requires, Employers shall ensure Workers receive medical examinations.
• Annual hearing examinations shall be provided for Workers who are exposed to excessive noise for 8 hours or equivalent.
• Accident reporting channels shall be established and communicated to all Workers.
8.5. Chemical Safety
• The Employer should always aim to minimise and eliminate the risks arising from the use of chemicals at work by:
• Minimising and eliminating use of hazardous substances.
• Choosing alternatives where elimination is not possible.
• Choosing technology that eliminates or minimises the risk.
• All chemicals and hazardous substances must be identified and labelled with warning signs in accordance with their chemical properties and legislative requirements. All chemical labelling should be legible and durable, which is easily understandable to the Workers.
• Employers should keep an inventory of chemicals used at the site and make this available to Workers, including but not restricted to: identification of material; approximate volumes; flammability; toxicity; hazard potential for ground water and storage location.
• All chemicals used on site must be fully risk assessed.
• All chemicals and wastes shall be delivered, handled, stored, transported and disposed of in accordance with its properties and legislative requirements.
• Workers exposed to substances hazardous to their health must be provided with such information, instruction and training as is suitable and sufficient for them to know the health risks associated with their exposure to the substances with which they work. They should also be familiar with the precautions necessary for their protection.
• Material Safety Data Sheets (MSDS) must be held for all chemicals and should be made available to Workers at the point of use.
• If a chemical Supplier does not provide the MSDS or the chemicals are not properly labelled, then these chemicals should not be used until the information has been obtained.
• PPE shall be provided for Workers handling chemicals.
• Employers shall develop and implement an emergency plan for handling chemical spills and releases.
• Spill kits or absorbents shall be in place in chemical storage areas.
• Processes using hazardous chemicals shall be well ventilated and personal exposure monitored and kept below regulatory requirements.
• Eye washing equipment should be provided anywhere there is a risk of splashes in the eye.
8.6. Equipment / Machinery
• Employers must ensure that any equipment provided for work is suitable for its intended purpose, maintained in an efficient state, in working order and good repair. Dangerous machinery must be securely guarded.
• Equipment shall be clean and well maintained. All moving parts likely to cause injury shall be effectively guarded. A maintenance programme shall be in place for all safety devices and guarding.
• Where fitted, emergency stop buttons shall be effective and clearly labelled.
• Portable heating appliances shall be positioned safely.
• Hoists, pressure vessels, boilers and forklifts shall be regularly inspected, properly maintained and documented.
• Service lines including steam pipes, compressed air pipes and hot water pipes and tanks shall be regularly inspected and properly maintained.
• Permit-to-work programmes shall be implemented for electricity work, steam pipe work, pressurised pipe work, tank entry, fire protection equipment impairment and welding.
• Forklifts shall be inspected daily when used, findings recorded and operated by authorised personnel only.
• Gas cylinders shall be securely fixed and separated from incompatibles.
• Welding cylinders shall be equipped with flame arrestors and check valves.
• Local exhaust ventilation systems are regularly cleaned and maintained.
8.7. Electrical Safety
• Only trained staff should be allowed to work with electricity, with all electrical systems being maintained so as to prevent danger at all times. Work should not be carried out on live systems unless there is no alternative.
• All portable electrical equipment shall be tested and checked by a qualified person.
• Fixed wiring shall be tested with records available to confirm testing results.
• Qualified electricians shall maintain electrical equipment and supply.
• All portable electrical equipment shall be grounded and the power connection securely fixed with a socket.
• Electricity mains supply shall be free from obstacles, with warning signs, properly maintained and prevented from un-authorised access.
• No bare wires shall be exposed.
• Only waterproof appliances and supply shall be used outdoors.
8.8. Job Hazard Assessment
• Where risks are not adequately controlled by other means then the Employer must supply suitable Personal Protective Equipment (PPE), free of charge, to the Worker. Examples may be hearing protection, respiratory protection, eye protection and gloves. The Employer must ensure the equipment is kept clean, well maintained and used appropriately.
• Chain gloves shall be provided when using electrical cutters in the cutting process.
• Job hazards shall be assessed, identified and communicated to the Workers.
• Warning signs of hazardous areas such as high voltage, confined space, extreme temperatures and asbestos shall be posted.
• Workers shall be trained to use and maintain PPE.
• Signs shall be posted where PPE is required and use of PPE is mandatory.
• When noise level is likely to be higher than the recommended levels, the Employer shall appoint a qualified person to conduct a noise assessment.
• If Workers are exposed to higher than the recommended levels for 8 hours or equivalent, the Employer shall eliminate noise sources if possible; otherwise ear protection equipment shall be provided and hearing examinations conducted annually.
• A noise control zone shall be defined where noise exposure exceeds the recommended levels for 8 hours or equivalent.
8.9. Dormitories
• Where residential accommodation is provided for Workers it must be safe and separate to the production area (particularly with regard to fire precaution), clean and provide sufficient space for an individual to live in comfortably. Toilet and washing facilities should be provided with clean running water.
• Dormitories shall not be crowded and living space shall be adequate.
• The conditions of residential accommodation, canteens and toilets/sanitary facilities shall be monitored and recorded to ensure there are no factors which may affect Workers’ health.
• If the room exceeds more than 12 people, two fire exits shall be provided.
• Sleeping arrangements shall be adequate and provided with reasonable privacy. The building shall have fire alarms and clear signposting of emergency exits.
• Each Worker must have his/her own bed.
• Lockers shall be provided for personal belongings.
• The building shall be structurally sound and properly maintained.
• Workers can leave and enter the dormitory freely without restriction unless reasonable grounds can be demonstrated for security and safety.
• Residential facilities must be safe in the areas of security, fire protection and electrical safety.
• An evacuation plan must be posted and fire drills conducted at least every 6 months.
8.9.1. Bathrooms
• The number of bathroom cubicles for showering shall be adequate, with a minimum of one shower for 12 people.
• Hot and cold water shall be provided inside the bathroom cubicles for showering.
• Doors or curtains shall be installed in bathroom cubicles to protect privacy.
8.9.2. Toilets
• The number of toilets shall be adequate with a minimum of one toilet for 12 people.
• Toilets shall be clean and free from foul odour.
• Toilets shall be equipped with flushing and washing water.
• There must be at least one male room and one female room for every two floors.
• Toilets shall have doors to protect privacy and any windows shall be opaque.
8.9.3. Canteens
• Food storage and preparation areas shall be clean and hygienic.
• Cooks shall be trained in food preparation hygiene.
• If food utensils are re-used, they shall be clean and sterilised.
• Facilities should be provided for eating meals and adequate rest.
• Where applicable, cooks shall undergo a health check annually.
9. ENVIRONMENTAL MANAGEMENT
9.1. Suppliers must comply with all relevant laws and regulations regarding the protection and preservation of the environment. This includes obtaining and maintaining all required environmental permits (e.g. discharge monitoring), approvals and registrations.
9.2. Factories must also adhere to all applicable laws, regulations and customer requirements regarding specific substances that are restricted (or prohibited) by law or by Simply Brands (Asia) Ltd. It is the Supplier’s responsibility to ensure that any factories used by the Supplier adheres to these requirements.
9.3. In sourcing Suppliers, we will consider their environmental performance and, in particular their commitment to minimising harmful impacts of their operations on the community, environment and natural resources. Areas our Suppliers must assess and manage include:
9.3.1 Environmental Protection Standards
9.3.1.1 Waste Disposal
• Elimination or reduction of waste by practices such as modifying production, improved maintenance, materials substitution, conservation, recycling and re-use of materials.
• The Employer shall identify waste sources and develop a procedure for disposal.
• Hazardous wastes shall be labelled and disposed of properly.
• Disposal records shall also be maintained.
• Hazardous wastes shall be stored in designated and secure areas.
• The containers of hazardous waste shall be in sound condition.
• Training shall be provided for employees handling hazardous waste.
9.3.1.2 Air Emissions
• The Employer shall identify air emission sources and monitor the emission in accordance with regulatory requirements.
• Maintenance programmes and operating procedures should be developed and implemented for in-house air treatment facilities.
9.3.1.3 Industrial Waste Water Discharge
• The Employer shall identify waste water discharge sources and monitor the emission in accordance with regulatory requirements.
• Maintenance programmes and operating procedures shall be developed and implemented for in-house waste water treatment facilities.
• The local authority for waste water discharge shall grant an appropriate license or permit.
9.3.1.4 Asbestos
• The presence of any asbestos in the workplace shall be identified and steps taken to ensure its condition is monitored and that it is maintained safely. Anyone working within this environment e.g. electricians shall be made aware of the presence of asbestos.
9.3.1.5 Storage
• Secondary containment equivalent to minimum 110% of volume of the largest container shall be provided in storage areas for chemical leakage.
• No drains are allowed inside the storage area.
• Drum storage areas shall be covered to prevent rainwater from coming into contact with drums.
9.4. Wet processes
9.4.1. Seek alternative wet processes that reduces water, energy and chemical use and take responsibility for knowing where wet processes are taking place including laundries and tanneries.
9.5. Animal Welfare
9.5.1. Do not use fur, including rabbit hair (angora) or Mongolian lambs fur. Do not use any part of vulnerable, endangered, exotic or wild caught species. Do not use feather and down, shell, horn or bones in Simply Brands (Asia) Ltd’ own-label products. Do not test any products or ingredients on animals. Only source certain types of leather, wool and other animal hair from Suppliers with a good track record of animal welfare.
Approval For This Statement
This Supplier’s Ethical Code was approved by the board of directors.
Signed off by: Ollie Page (CEO)
Signature: O. Page