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Ethical Policy / Modern Slavery / Equal Opps

Overview

Our purpose for this ethics policy is to establish a culture of openness, trust and integrity in the business practices we use. We are committed to being a socially responsible organisation, taking into consideration the environmental, social and economic footprint of our business on the local communities where we operate and aiming to maximise the benefits and minimise any negative impact of our operations where possible. This includes abiding by written laws and legislation for the relevant countries we are working within.

Scope

This policy applies to employees, contractors, consultants, temporaries, and other workers at our company, including all personnel affiliated with third parties and contractors. Such individuals or parties will be expected to familiarise themselves with the principles of this policy. It will remain the responsibility of our suppliers to ensure that their employees and subcontractors are informed about and comply with this policy and it will be clearly recognised when setting up new contracts, that a company will be abiding by this statement.

Legal Responsibility

We expects all of our operations, suppliers and their subcontractors to obey national as well as regional statutory requirements of the countries in which they are operating for all their activities. We recognise that different countries have different legislation that must be adhered to and we will ensure that our contractors, where possible are committed to these laws. However, we understand these laws as a minimum standard and expects its suppliers and employees to operate with the highest moral standards.

Local Communities & The Environment

We are fully committed to supporting and assisting the communities in which we operate by conducting our business with respect and consideration for the wellbeing of local communities. All operating facilities will be discreet within the local neighbourhood and will work to give back to the community where possible.

We are further committed to the preservation and improvement of the environment it operates in. We expect all companies to comply with environmental, safety and health laws and regulations, and to the extent practical, put into action programs that exceed national governmental requirements. All companies must do whatever they can to minimise their operations’ impact on the environment. We will recycle where possible any materials it can during its supply chain process. Recycling facilities are in place and employee’s are encouraged to use them and reducing the impact of the business on the environment is a high priority.

Human Rights

We believe in the philosophy of the United Nations Universal Declaration of Human Rights and we are committed to maintaining this in our working practices. Respect for human rights continues to remain the cornerstone of our decision making.

We will endeavour to co-operate with business partners to ensure they conduct their operations in a manner that meets these standards and our own.

We will continuously take steps to ensure that the operations of our employees and suppliers do not counter internationally accepted human rights conventions and where possible will only source products from countries that have legislation that meets the standard of the United Nations Universal Declaration of Human Rights.

Child Labour

A child in this context is a person younger than 15 years of age, or 14 years of age in accordance with the exceptions for developing countries as set out in Article 2.4 in the ILO Convention No.138 on Minimum Age.

We base our child labour code on the UN Convention on the Rights of the Child, article 32.1. We recognise that children have the right to be protected from exploitation economically and from partaking in any work that is likely to be hazardous or to interfere with their education, or to be harmful to their health and detrimental to their physical, mental, spiritual, moral or social development.

We will not co-operate with any company that is involved in child labour and will seek to ensure that all suppliers have the ethical conduct and procedures in place that support this. All companies that deal with our company are expected to respect children’s rights and to wherever possible help children develop themselves in fields such as education, sports and to develop into good members of society.

Unethical Behaviour

  • We will avoid the intent and appearance of unethical or compromising practice in relationships, actions and communications.
  • We will not tolerate harassment or discrimination.
  • We will not permit impropriety at any time and we will act ethically and responsibly in accordance with laws.

Enforcement

Any employee found to have violated this policy may be subject to disciplinary action, up to and including termination of employment.

 

Modern Slavery Statement

Introduction

Promotional Gods is a socially responsible business headquartered and based solely in the UK. Promotional Gods published its initial Modern Slavery Statement in response to Modern Slavery Act of 2015. This document provided a brief overview of business in the UK and the steps we took to manage the risks associated with modern slavery in the supply chain. This 2021 statement will show what we have learned and expand upon our aims for enabling continued transparency and vigilance in our employment and procurement practices.

We recognise that modern slavery, forced labour and child labour are real issues of global concern. We understand the affect this has on individuals and communities and are aware that being a European organisation does not insulate us from the effects of unethical practice directly, or indirectly through third parties in our supply chain.

Our Business and Supply Chains

Being a micro business, we consider ourselves to be low risk but we are committed to working in partnership with our clients to ensure our supply chain vendors meet the high standards of social responsibility demanded by us as a business and by the end users of our products.

Our supply chain is complex and may consist of different tiers between our direct suppliers and the producers of raw materials. We source our requirements from highly regarded global suppliers who enable us to rely on the integrity of their supply chain, particularly in relation to suppliers of paper, inks and other constituent materials required for the manufacture of printed products.

Our Controls and Procedures

We have discovered that the areas of high risk are not large corporate suppliers, but more local and less publicly transparent service providers. We identified that seasonal peaks and troughs in product demand means that our supply chain uses contingent labour, which is a widely accepted area of risk prone to potential abuse.

In addition to areas of risk exposed within our business through internal audit, we continue to issue modern slavery compliance questionnaires to our suppliers, asking a range of questions including whether or not they are aware of the practice of modern slavery, do they have any company standards, policies or other statements relating to human slavery and trafficking, do they audit their own supply chain in relation to these issues, and have or do they intend to provide training for their workforce.

Thus far we have received a positive response from the majority of our suppliers and were able to identify, through lack of response, the areas of highest risk. This enabled us to focus on improving awareness within our business, providing a safe avenue for whistle blowing should any of our contingent workers be the victims of such practices or know of anyone affected.

Organisations helping us

Some of the associations within our industry that monitor modern slavery and social responsibility and help with the transparency of supply chains:

Fair Labor Association

From coffee and electronics to apparel and footwear, most of the products we enjoy and use every day are made by men and women in factories and on farms around the world. These workers harvest the cotton used to make our shirts, sew buttons and zippers onto our jackets, grow the cocoa our children drink, and make high-tech soles for our running shoes. Unfortunately, many of them work in deplorable conditions.

FLA's Multi-Stakeholder Approach to Improving Workers' Lives

The products we buy should not come at the cost of workers' rights. The Fair Labor Association believes that all goods should be produced fairly and ethically, and brings together three key constituencies - universities, civil society organizations (CSOs) and companies - to find sustainable solutions to systemic labor issues. Since 1999, FLA has helped improve workers' lives by:

  • Holding affiliated companies accountable for implementing FLA’s Code of Conduct across their supply chains.
  • Conducting external assessments so that consumers can be assured of the integrity of the products they buy.
  • Creating a space for CSOs to engage with companies and other stakeholders to find viable solutions to labor concerns.

 

Worldwide Responsible Apparel Production

Worldwide Responsible Accredited Production (WRAP) is an independent, global non-profit organization dedicated to the certification of facilities engaged in lawful, humane and ethical production. Headquartered in Arlington, Virginia, WRAP has offices in Hong Kong and Bangladesh with representation in India.

Based on reports of improper working conditions in sewing factories in developing countries, a task force composed of members from the American Apparel Manufacturers Association, consultants, NGOs and other stakeholders began an exhaustive, three-year study of the labor and environmental conditions in sewing factories around the world in late 1996.  Based hundreds of meetings across the world with numerous governments, trade associations, retailers, brand manufacturers, suppliers, trade unions and NGOs, WRAP was established in January 2000 and is today the world’s largest labor and environmental certification program for labor-intensive consumer products manufacturing and processing.  WRAP enjoys the support of 25 international trade associations including the International Apparel Federation which represents 36 national associations and over 150,000 individual companies.

WRAP is a standards-setting and certification body.  It has no members nor does it rely on government funding or foundation grants.

The WRAP Certification Program is based on 12 Principles focusing on local law and workplace regulations, generally accepted international workplace standards, and the environment. WRAP also includes evaluation of a facility’s customs compliance and security standards in line with the Customs - Trade Partnership Against Terrorism (C-TPAT) Foreign Manufacturers Security Criteria of the U.S. Department of Homeland Security for facilities exporting to the US.  Facilities that demonstrate proper adoption, deployment and monitoring of all 12 Principles receive certification for six months to two years. The certificate applies to the individual facility, not a parent company or brand.

As stated above, WRAP focuses on compliance with local law.  It is an apolitical organization and does not lobby nor advocate for issues such as freedom of association outside of local law, nor the concept of a living wage, which has not been defined. WRAP understands and respects the unique culture of each country. Therefore it is the policy that WRAP has not and will not get involved in any political issue with any country.

Facilities benefit from WRAP certification by demonstrating compliance with buyer Corporate Social Responsibility (CSR) requirements.  This certification clearly opens doors and creates business opportunities in today’s highly competitive global export markets. WRAP is well recognized and has been accepted by many international retailers, brand manufacturers and licensors. Manufacturers in many developing countries have treated WRAP as an “International Passport for Entry into Western Countries”.

WRAP has incorporated a significant number of “best practices” to assist facilities in becoming more efficient, productive and profitable. Finally, the overall benefits are clear: better working conditions for employees, an environmental program designed to protect the environment, and a sustainable platform to provide for future generations.

Fairwear Association

Fair Wear Foundation (FWF) is an independent, non-profit organisation that works with companies and factories to improve labour conditions for garment workers.

FWF’s 80 member companies represent over 120 brands, and are based in seven European countries; member products are sold in over 20,000 retail outlets in more than 80 countries around the world. FWF is active in 15 production countries in Asia, Europe and Africa.

FWF keeps track of the improvements made by the companies it works with. And through sharing expertise, social dialogue and strengthening industrial relations, FWF increases the effectiveness of the efforts made by companies.

Change requires a major joint effort. We therefore invite companies to join FWF and make a difference. If you're interested in how we can help you, send us an e-mail

Companies that produce and distribute products of which the main manufacturing process is sewing can join FWF and, depending on the direct influence they have with garment factories, become an FWF affiliate or FWF ambassador. Both affiliates and ambassadors of FWF work towards improving the labour conditions in factories and workshops where the ‘cut-make-trim’ stage takes place, all over the world. The basis of the collaboration between FWF and a member is the Code of Labour Practices. Eight labour standards form the core of the Code of Labour Practices. Members of FWF must comply with this Code of Labour Practices.


Principles

Supply chain responsibility = realising that the Code can only be fulfilled when sourcing companies, as well as factory management, actively pursue practices that support good working conditions.
Labour standards derived from ILO Conventions and the UN’s Declaration on Human Rights = basing FWF’s Code on internationally-recognised standards which have been set through tri-partite negotiation.
Multi-stakeholder verification = verification processes developed through multi-stakeholder negotiation, and involving experts from diverse disciplines and perspectives in FWF verification teams.
A process approach to implementation = paying special attention to the means (i.e. building functioning industrial relations systems over time) in order to achieve the end (i.e. sustainable workplace improvements).
Involvement of stakeholders in production countries = engaging local partners in shaping FWF’s approach in a given region or country.
Transparency = keeping relevant stakeholders informed of FWF policies, activities, and results; publicly reporting on member company efforts to fulfil FWF requirements.

FWF is governed by the following organisations:

  • Modint (the trade association for fashion, interior design, carpets and textiles)
  • CBW-MITEX (business association for retailers of interior design, fashion, shoes and sportswear)
  • FGHS (business association for sporting goods suppliers)
  • FNV Bondgenoten (federation of trade unions - service industry)
  • CNV dienstenbond (Christian trade union - service industry)
  • Clean Clothes Campaign (The Netherlands)
  • Brot für alle (Switzerland)

 

Future

We are continually trying to improve our modern slavery processes and we are working towards modern slavery awareness in our business inductions & refreshers for all employees. A modern slavery section is now included in most of our tender documents.

We will continue to perform due diligence exercises when on boarding new suppliers and work to place similar contractual obligations in our contracts.

What is clear is that the purpose of the Act is to introduce a culture of transparency that can enable socially responsible businesses such as ours and those of our suppliers to continue to develop awareness, raise standards and deliver an excellent service from a position of ethical best practice, thus ensuring a viable and satisfactory experience for all stakeholders.

 

Equal Opportunities Policy
Reasons for having an Equal Opportunities Policy
An effectively implemented Equal Opportunities Policy will help us to:
 Provide a pleasant environment promoting fair and equal opportunities to all staff
 Ensure fair treatment for all job applicants and existing members of staff
 Ensure fair treatment for all others with whom we have contact e.g. suppliers and
customers
 Maintain good staff morale
 Attract, develop and retain the good quality staff who are essential for achievement of our
business objectives
 Avoid unlawful or unfair discrimination
APPS believes that it is in everyone’s best interests to ensure that the experience, talents and
skills available throughout this organisation are considered when employment or development
opportunities arise.
Employer & Employee rights and obligations
Equal opportunities impose rights and responsibilities for every member of staff. Everyone has a
right to fair and dignified treatment. This means that no-one will be discriminated against nor
harassed. Every member of staff has an obligation to ensure fair and dignified treatment. The
contribution of everyone will be valued and everyone will be treated purely on their merits.
Everyone must act fairly, within APPS policy and the law. Failure to do so may lead to
disciplinary action.
The APPS Equal Opportunities Policy is issued to all members of staff and job applicants.
Policy statement
APPS is an equal opportunities employer. Our aim is to be fair to everybody and to ensure that
no job applicant or employee receives more or less favourable opportunities or treatment on the
grounds of, for example:
 Age
 Race
 Sexual orientation
 Marital status
 Disability
 Religion or religious affiliation

Definitions
Discrimination
Discrimination is unequal treatment of an individual because of their membership of a particular
class or group, such as gender, race or religion.
Discrimination may be subtle and unconscious. It may not be easy to identify. For example,
discrimination sometimes results from general assumptions about the capabilities,
characteristics and interests of particular groups or individuals, which are allowed to influence
the treatment of staff or job applicants.
Sexual harassment
Sexual harassment may involve unwelcome sexual comments or innuendo, looks and gestures,
displays of pin-ups or physical contact by one individual aimed at another, and which is only
directed at that other person because of their sex.
Sexual harassment cannot be dismissed as a 'bit of harmless fun'. It can lead to an
uncomfortable and alienating working environment.
Racial harassment
Racial harassment is offensive or hostile behaviour, which has the purpose or effect of creating
discomfort, distress, exclusion or isolation and is based upon someone’s race (colour,
nationality or ethnic origins) or is directed at them because of their race. If the comment or
behaviour is offensive to the individual, it will amount to racial harassment.
Harassment/bullying
As with sexual or racial harassment, any form of harassment or bullying will have the effect of
causing undue stress on individuals and of de-motivating them. Harassment of any kind will not
be tolerated and serves to undermine the good team spirit which APPS wishes to encourage.
Disability harassment
Offensive or hostile behaviour or comments aimed at an individual because he or she is
disabled, will also be harassment.
Resolving problems
Everyone must be sensitive to the effects their words and actions have on their colleagues and
need to ensure that their attitudes towards others carry no trace of discrimination which can
affect working relationships, behaviour or judgement.
In the first instance, staff are encouraged to calmly make clear to their colleagues if conduct or
comments are offensive to them so that the perpetrator(s) are made aware of the problem and
have an opportunity to alter their behaviour before a problem escalates.
If the behaviour continues, staff who are experiencing or are concerned about discrimination or
harassment should discuss the problem with the management who must take appropriate action
to try to resolve it, if possible.
Management should be aware of any problem developing at an early stage and take corrective
action to ensure that the situation is resolved in a conciliatory and effective manner and that
staff do not feel excluded.

Complaints procedure
If you wish to make any complaint of discrimination or harassment, you should approach your
manager in the first instance who must act firmly, fairly and without delay. If there is a reason
why you do not feel able to speak to your manager initially, you may elect a representative,
relative or friend to speak on your behalf.
Where appropriate, an enquiry will be conducted into the complaint and if it is considered that
the behaviour of an individual is unlawful, unfair or unacceptable, disciplinary action will be
taken by APPS against that individual.
All staff are subject to the disciplinary rules and should remember that unfounded allegations of
unfair treatment can themselves be distressing to the recipients of such complaints. Such
unfounded allegations may lead to disciplinary proceedings.
Further information and relevant legislation
Over and above the provisions set out in its own policy and procedures, APPS is also bound by
certain legal responsibilities in the field of equal opportunities.
Useful resources:
Equal Pay Act 1970:
http://www.womenandequalityunit.gov.uk/legislation/equal_pay_act.htm
Sex Discrimination Act 1975:
http://www.womenandequalityunit.gov.uk/legislation/equal_pay_act.htm
Race Relations Act 1976, Race Relations (Amendment) Act 2000, Race Relations Act 1976
(Amendment) Regulations 2003:
http://www.cre.gov.uk/legal/rra.html
Disability Discrimination Act 1995:
http://www.drc-gb.org/thelaw/thedda.asp
Employment Rights Act 1996:
http://www.opsi.gov.uk/acts/acts1996/1996018.htm
Employment Act 2002:
http://www.dti.gov.uk/employment/employment-legislation/employment-act-2002/index.html
Religion or Belief Regulations 2003, Sexual Orientation Regulations 2003, Age
Discrimination Regulations 2006:
http://www.dti.gov.uk/employment/discrimination/index.html

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