Ethical Trading Initiative (ETI)

Ethical Trading Initiative (ETI) Worker’s Rights Policy

Purpose
A strong, healthy, empowered workforce is essential to the operations of The Company. Not only do good labor practices ensure quality of life and quality of business processes, they also ensure quality of the end product which we deliver to our customers.
It is important that our product represents the best possible use of the environment, natural resources, technology and human resources.
The Company has committed to excellence in all areas and in addition to complying with all applicable legal standards and regulations, The Company works diligently to follow the ethical trading initiative (ETI) base code. This code summarises the ethical trading and labour standards towards which we aim to hold ourselves and our suppliers accountable.
The provisions described within this policy are minimum and not maximum standards and The Company diligently works to comply with national and other applicable law. In the cases where the provisions of the policy and specifics of the law address the same subject The Company is committed to apply that provision which affords the greater protection.
This policy implemented in compliance with the law and regulations and in the spirit of the Ethical Trading Initiative and the UN guiding principles.

Scope
The following policy applied to all activities conducted by and on behalf of The Company. As applicable, and where possible, The Company also works to ensure that supply chain partners, immediate suppliers and co-manufacturers are in harmony with the policy standards.
Responsibility
This program is comprehensive and is implemented with full ownership and management commitment. A senior management representative has been appointed responsible for health and safety.

Continual Improvement
The Company has developed the following policy commitments, practices and behaviours in accordance with the UN Guiding Principles on Business and Human Rights (UNGPs). The Company is not only committed to the policy, but also to a proactive, continual process of

1. Identifying issues as they arise,
2. Preventing, mitigating and remedying issues as they are identified,
3. racking and communicating implementation as it is completed.

Policy Outline
The program rests on the following pillars:

1. Employment is freely chosen
2. Freedom of association and the right to collective bargaining are respected
3. Working conditions are safe and hygienic
4. Child labour is not be used
5. Living wages are paid
6. Working hours are not excessive
7. No discrimination is practiced
8. Regular employment is provided
9. No harsh or inhumane treatment is allowed

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,
The Company ensures that all of its employees, agents and contractors are entitled to their human rights as set out in the Universal Declaration of Human Rights and the Human Rights Act 1998,
The Company does not enter into any business arrangement with any person, company or organisation which fails to uphold the human rights of its workers or who breach the human rights of those affected by the organisation's activities

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 Company has adopted an open attitude towards the activities of trade unions and their organisational activities
Workers 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. Working conditions are safe and hygienic
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 are 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 causes of hazards inherent in the working environment
Workers receive regular and recorded health and safety training, and this training is repeated for new or reassigned workers
Access to clean toilet facilities and to drinkable water, and, if appropriate, sanitary facilities for food storage is provided
When provided, accommodation is clean, safe, and designed to meet the basic needs of the workers
A senior management representative has been appointed responsible for health and safety.

4. Child labour is not be used
The Company does not perform new recruitment of child labour
The Company participates in and contributes to policies and programmes which provide for the transition of any child found to be performing child labour to enable her or him to attend and remain in quality education until no longer a child; "child" and "child labour" are further defined below,
Children and young persons under 18 are not employed at night or in hazardous conditions
These policies and procedures shall conform to the provisions of the relevant ILO Standards. (International Labour Organisation)
Child: Every boy and girl under the age of 18.
The UN Convention on the Rights of the Child (1989) says: “For the purpose of this present Convention, a child means every human being below the age of 18 years unless, under the law applicable to the child, majority is attained earlier”
Young Person: Any worker over the age of a child as defined above and under the age of 18.
Adolescent: A child between the age of 10 and 17. In addition, 17-19 year olds are also referred to as ‘young adults’.
Child labour: Work which, by its nature or the circumstances in which it is carried out, is likely to harm the health, safety or morals of children.

5. Living wages are paid
Wages and benefits paid for a standard working week meet, at a minimum, national legal standards or industry benchmark standards, whichever is higher
Wages are provided that are always enough to meet basic needs and to provide some discretionary income
All workers are 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 are not made as a disciplinary measure
Deductions from wages not provided for by national law are not permitted without the expressed permission of the worker concerned.
All disciplinary measures are recorded by the HR department

6. Working hours are not excessive
6.1 Working hours comply with national laws, collective agreements, and the provisions of 6.2 to 6.6 below, whichever affords the greater protection for workers. Sub-clauses 6.2 to 6.6 are based on international labour standards.

6.2 Working hours, excluding overtime, are defined by contract, and do not exceed 48 hours per week.*

6.3 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 shall not be used to replace regular employment.
Overtime is compensated at a premium rate, which is recommended to be not less than 125% of the regular rate of pay.

6.4 The total hours worked in any seven day period shall not exceed 60 hours, except where covered by clause 6.5 below.

6.5 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 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 and safety; and
• the employer can demonstrate that exceptional circumstances apply such as unexpected production peaks, accidents or emergencies.

6.6 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.

7. No discrimination is practised
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
No worker is prevented from joining or forming a staff association or trade union, nor does any worker suffer any detriment as a result of joining, or failing to join, any such organisation

8. Regular employment is provided
To every extent possible work performed is on the basis of recognised employment relationship established through national law and practice.
Obligations to employees under labour or social security laws and regulations arising 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 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

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 shall be prohibited
No worker should be discriminated against on the basis of age, sex, race, sexual orientation, religion or beliefs, gender reassignment, marital status or pregnancy. All workers should be treated equally. Workers with the same experience and qualifications should receive equal work