CODE OF CONDUCT
CODE OF CONDUCT
- This Code of Conduct (Code) is based on the Ethical Trading Initiative’s (ETI) Base Code. We believe all workers must be treated with dignity, respect and fairness and that the environment must not be harmed in the manufacture of our products.
- Our customers expect working conditions in our supply chain to conform to international labour standards. Where this is not the case, our company faces reputational risks which can also affect our suppliers. It is therefore in the interests of our suppliers to uphold the standards set out in this Code.
- We believe the Code can only be implemented by working in partnership with our suppliers. This partnership must be based on trust, transparency and co-operation. Suppliers must be open with us about labour and environmental conditions in order that we can jointly resolve any areas that do not meet the standards in our Code.
- We recognise that in some cases it may not be possible to immediately comply with the Code because of complex and multiple barriers. Where this is the case, suppliers must commit to making continuous improvements towards the Code over a reasonable timeframe and implement a corrective action plan to remedy any non-compliance issues. This must be agreed with our staff or representatives.
- Our staff or representatives may visit supplier manufacturing sites from time to time to ensure that working conditions meet the standards of the Code. Suppliers will be advised of these visits in advance but we reserve the right to make unannounced visits too. Suppliers must provide our staff or representatives unrestricted access to all facilities, including dormitories, and must provide full access to all relevant documents and records.
- Each supplier must nominate a member of senior management to be their point of contact on any matters that may arise regarding compliance with our Code. Suppliers must communicate the Code to all their workers and ensure their suppliers meet the standards of the Code.
- The provisions of this Code constitute minimum and not maximum standards, and this Code should not be used to prevent suppliers from exceeding these standards. Suppliers are expected to comply with national and other applicable laws and, where the provisions of law and Karen Millen’s Code address the same subject, to apply that provision which affords the greater protection to workers.
This Code of Conduct applies to all workers; including agency, migrant, temporary and permanent workers.
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 you and are free to leave after reasonable notice.
- Neither you nor any entity supplying you with labour shall engage in or support human trafficking.
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.
- You must adopt 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, you facilitate, and do not hinder, the development of parallel means for independent and free association and bargaining.
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 shall be 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.
- Workers shall receive regular and recorded health and safety training, and such training shall be repeated for new or reassigned workers.
- Access to clean toilet facilities and to potable 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.
- You shall assign responsibility for health and safety to a senior management representative.
Child labour shall not be used
- There shall be no new recruitment of child labour.
- You must develop or participate in programs that enable children to remain in quality education until no longer a child. All policies and procedures relating to child labour shall confirm to the provisions of the relevant ILO standards. Young workers shall not be employed at night or in hazardous conditions.
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. 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.
Working hours are not excessive
- Working hours must comply with national laws, collective agreements, and benchmark industry standards, whichever affords the greater protection for workers.
- The working hours must not prohibit the worker from enjoying their private and family life.
- In any event, workers shall not be required to work in excess of 48 hours per week and will be provided with at least one day off for every 7 day period.
- Overtime is voluntary, shall not exceed 12 hours per week or be demanded on a regular basis and shall be compensated at a premium rate.
No discrimination is practiced
- 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.
- The Supplier shall not allow any behaviour that is threatening, abusive, exploitative, or sexually coercive including gestures, language, and physical contact, in the workplace and where applicable, in residences and other facilities provided by the company for use by personnel. The Supplier shall not subject workers to pregnancy or virginity tests under any circumstances.
Regular employment is provided
- To every extent possible work performed must be on the basis of recognised employment relationship established through national law and practice.
- Obligations to workers 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, 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.
No harsh or inhumane treatment is allowed
- There will be no exploitation of workers. This includes employing workers through dishonesty, the treatment of the worker whilst employed and the right to be free from oppressive treatment once the employment has been terminated. Physical, sexual, mental or verbal abuse is prohibited. As is the threat of any kind of abuse or other forms of intimidation.
Ensure Migrants are employed legally
- Migrant workers must be employed in accordance with the immigration and labour laws of the country of manufacture. The supplier must have effective systems in place to verify the worker’s entitlement to work and their status in the country of manufacture. The Supplier must hold copies of documentation which verifies that the migrant worker can be legally employed.
- The migrant workers’ right to freedom of movement and communications must not be interfered with and all original documentation necessary to exercise these rights must be left in the possession of the migrant worker.
Modern Slavery is prohibited
- The practice of Modern Slavery is condemned. The term Modern Savery is used here to encapsulate all offences under the Modern Slavery Act 2015, including slavery, servitude and forced or compulsory labour, and human trafficking. The supplier is required to ensure that all reasonable efforts are employed to eliminate Modern Slavery and deceptive practices in the recruitment of workers in their operations, in their subcontractors and within their supply chains including raw material producers. If the supplier becomes aware of slavery within their supply chain it must notify Karen Millen immediately.
- The supplier should make provisions to accommodate for individuals who are particularly vulnerable to these practices. This includes, but is not limited to; women, migrants and minorities.
- Suppliers must manage all resources and waste in accordance with local laws or in such a way as to avoid harm to the local population.