Ethical Sourcing Policy

CODE OF CONDUCT FOR MANUFACTURERS AND SUPPLIERS OF SEAMLESS SOURCE LTD

Introduction: 

The Code of Conduct is the minimum standard that all of Seamless Source (Seamless Source) factories, suppliers, licensees, partners and agents must meet. Suppliers must ensure these standards are implemented within their own operations and throughout their supply chain as a safeguard to their workers and the environment. As such, all of Seamless Source Suppliers are strictly required to adhere to the Code.

No Forced Labour: 

Seamless Source shall not allow any form of forced or involuntary labour among their manufacturers or suppliers. Workers are not required to lodge ‘deposits’ or their identity papers in order to gain employment and are free to leave employment with reasonable notice. (Governed by Conventions 29 and 105 of the International Labour Organisation (ILO). Suppliers shall not engage in or support human trafficking.

Freedom of association and collective bargaining: 

Employees have the right to join or form trade unions of their own choosing and to bargain collectively. The Supplier will adopt an open attitude towards the activities of unions and their organisational activities. Worker representatives will not be discriminated against and will have access to carry out their representative functions in the workplace. Where the rights to such unions are restricted under law, the Supplier will not hinder the development of alternate organisations for free association and bargaining. Where the rights to Freedom of Association and Collective Bargaining are restricted under law, the appropriate channels to ensure a reasonable and independent exercise of such rights must be designed according to ILO Conventions 87,98 and 135. The Supplier shall effectively communicate this right to workers.

Safe and Hygienic working conditions: 

Manufacturers and suppliers shall provide a safe and healthy workplace to their employees, ensuring minimum conditions of light, ventilation, hygiene, fire prevention, safety measures and access to a drinking water supply. Workers shall have access to clean toilet facilities and drinking water. Where necessary, facilities for food storage shall be provided. Accommodation, where provided, shall be clean and safe. Manufacturers and suppliers shall take the required steps to prevent accidents and injuries to the health of their workers, by minimising as much as possible the risks inherent to work. 

Workers shall receive regular and recorded health and safety training, and such training shall be repeated for new or reassigned workers. The Supplier shall appoint a senior management representative to be responsible for ensuring a safe and healthy environment for all workers and for implementing the health and safety elements of this standard, and establish systems to detect avoid or respond to these

The Supplier shall provide, at its own expense, appropriate personal protective equipment to its workers and provide first aid training required by local law. Suppliers shall assist the worker in obtaining follow-up medical treatment following any work-related injury.

The Supplier shall assess all the risks to new and expectant mothers arising out of their work activity and to ensure that all reasonable steps are taken to remove or reduce any risks to their health and safety.

All Workers shall have the right to remove themselves from imminent serious danger without seeking permission from the Supplier.

Living wages are paid: 

Wages and benefits will meet the minimum national legal standards or industry benchmark standards, whichever is higher. Wages shall always be enough to meet basic needs and to provide some discretionary income. All employees will be provided with written information about their employment conditions and wages before they enter employment and about the particulars of their wages for the pay period concerned each time they are paid. Deductions from wages as a disciplinary measure are not permitted. All disciplinary measures should be recorded.

Manufacturers and suppliers shall also ensure that wages and any other allowances or benefits are paid on time and are rendered in full compliance with all applicable laws and specifically, that payments are made in the manner that best suits the workers this will be governed by ILO conventions 26 and 131.
 
 
Working hours are not excessive: 
 
Manufacturers and suppliers shall adjust the length of the working day to the provisions of the applicable laws or of the collective bargain agreement applicable for the sector in question, if the latter affords greater protection for the workers. Manufacturers and suppliers shall not require their employees to work, as a rule of thumb, in excess of 48 hours a week and workers shall be granted at least one day off for every 7-calendar day period on average. Overtime shall be voluntary, shall not exceed 12 hours per week. It shall not be demanded on a regular basis and shall always be compensated at a premium rate.
 
No Discrimination: 
 
There will be no discrimination in hiring, treatment, compensation, access to training, promotion, termination or retirement based on race, caste, national origin, social origin, religion, age, disability, gender, gender identity, marital status, sexual orientation, birth, family responsibilities, social 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.
 
 
No Child Labour: 
 
Manufacturers and suppliers shall not employ minors. Seamless Source defines minors as those persons who have not yet reached their 16th birthday. In cases where local legislation stipulates a higher minimum age, the higher limit shall apply. Persons with the ages between of 16 and 18 years will be considered young workers. Young workers shall not work during night hours or in hazardous conditions.
 
 
Regular employment: 
 
Work performed must be on a basis of a recognised working relationship established through national law. Obligations to workers 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.
 
 
Traceability of production: 
 
Manufacturers and suppliers shall not assign any work to third parties without the prior written authorisation of Seamless Source. Those who outsource any work shall be responsible for the enforcement of the Code by these third parties and their employees.
Home workers and Subcontractors: Likewise, Manufacturers and suppliers shall apply the principles of this Code to any homeworker involved in their supply chain, and shall give transparency to the location and working conditions of said homeworkers.

 

Harsh or in humane treatment is not 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.

Migrants Legally employed: 

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: 

Seamless Source condemns the practice of Modern Slavery. 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 Seamless Source immediately and comply with the remediation obligations set out Section 20.

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.

Environmental Protection: 

Seamless Source is committed to reducing our environmental impact. The Supplier should consider their environmental performance and procedures to minimise any negative impact on the environment, community and natural resources. The Supplier must operate with regard to national laws, regulations, administrative practices and policies relating to the preservation of the environment. All relevant international agreements, principles and standards in relation to the environment must be complied with. This includes, but is not limited to, the reduction and management of: greenhouse gas emissions, water consumption, waterborne effluent, chemicals, industrial waste and the use of non-renewable resources. The Supplier must provide relevant data if requested to do so by Seamless Source.

Transparency: 

Manufacturers and suppliers shall carry out their activities in an honest, upright and transparent way, keeping for these purposes an appropriate accounting records system that facilitates the traceability of their decisions, as a preventive measure versus any type of corruption, bribe and extortion that might arise. Manufacturers and suppliers shall not offer, grant, request or accept any gifts or donations to/from Seamless Source employee’s customers which might infringe the provisions of the “Seamless Source Code of Conduct and Responsible Practices”. Manufacturers and suppliers shall not manipulate or influence their workers, nor shall they forge any files or records in order to alter the verification process regarding compliance with this Code. Manufacturers and suppliers shall neither offer nor accept remuneration of any kind which seeks, or may be perceived to seek, to affect the impartial judgment or the objectivity of such parties appointed by Seamless Source to carry out inspections and compliance audits in connection with this Code.

Confidentiality of Information: 

Manufacturers and suppliers shall preserve the integrity and confidentiality of the information they may receive as a consequence of their commercial relationship with Seamless Source. The obligation of confidentiality will remain once the relation with Seamless Source is terminated and it will include the obligation to return any material related to the company held by the manufacturer or supplier.

Code of Implementation: 

Manufacturers and suppliers shall implement and maintain programmes to set in motion this Code. They shall appoint a senior member of management who shall be responsible for the implementation and enforcement of this Code. Manufacturers and suppliers shall communicate the Code to all employees and those in any way involved in the Seamless Source Supply Chain. A copy of the Code, translated into the local language, shall be displayed in accessible locations to all workers.

Reference to National Legislation, Conventions and Agreements: 

The provisions of this Code constitute only minimum standards. Should national regulations or any other applicable Law or any other commitments undertaken or applicable, including collective bargaining agreements, govern the same issue, the provision which offers greater protection for workers shall apply. Seamless Source assumes, as part of its internal norms, the content of national and international Agreements and Conventions to which it has adhered, and that they are applied in its relationship with manufacturers and suppliers, committing to their promotion and compliance.

Verification of Compliance: 

Manufacturers and suppliers shall authorize Seamless Source and/or any third parties the former might appoint, to monitor the appropriate enforcement of the Code. For these purposes, they shall provide the required means and the appropriate access to the facilities and documentation required to ensure this verification.

Remediation: 

If the Supplier becomes aware of a breach of the Code, in any part of the supply chain, the Supplier must immediately notify Seamless Source and disclose any details that are deemed necessary by Seamless Source in order to accurately assess the problem. The Supplier will co-operate with Seamless Source and implement all measures necessary in order to resolve the issue at their own expense. Seamless Source reserves the right to terminate or blacklist any Supplier in breach of this Code.

 
Whistle Blowing Channel: 
 
In order to ensure the enforcement of the Code of Conduct for Manufacturers and Suppliers, the Committee of Ethics can act at its own initiative or following a formal complaint made in good faith by a manufacturer, supplier or other interested third party that might have any direct relationship or commercial or professional interest with Seamless Source. To this end, any notices given pursuant to the provisions of this Code, either reports of any breach or enquiries regarding the Code’s interpretation or application can be addressed directly to the Committee of Ethics via:
 
 
Address: Chanodil 6, Enterprise Centre, David Lane, Nottingham, England, NG6 0JU, United Kingdom, Email: info@seamlesssource.com 
COMPANY NAME: 
Signature: 
Name: 
Title: 
Date: 
 
Seamless Source 
Signature: 
 
 

Seamless Source 

 

Signature: 

 

Name: Chathura Sudharshan 

Title: CEO 

Date: Thursday, 16th May 2019