Ethical Sourcing Policy

V1.0  (01/07/2020)

Introduction
In recent years, concerns over poor working conditions and environmental degradation in developing countries and emerging markets have seen companies implement specific social and environmental criteria for the production facilities from which they source products.

In order to address these concerns, Lacess Ltd. is implementing its Ethical Sourcing Policy to ensure it is:

  • sourcing its products in a responsible manner; and
  • committing its suppliers to improve their social and environmental practices.

Our Commitment
Lacess Ltd is committed to upholding human rights, fair working conditions and environmental protection.

In accordance with the expectations of our customers, the community, and the requirements of the Law, we endeavour to always operate responsibly within the community, and we expect the same from our suppliers.

Maintaining a reputation for the highest legal, moral and ethical standards in our dealings with our customers and other key stakeholders is critical for our ongoing success. The Policy has been developed to complement our core values of integrity, trust and acting responsibly.

We are committed to working with our suppliers to help improve their labour and environmental practices.

Expectations
We expect our suppliers to fully comply with the ethical standards set out in this Policy with regard to workplace safety, environment, and fair pay and employment conditions.

The Policy sets out the standards that we expect all of our suppliers to comply with when producing and supplying products for Lacess Ltd, no matter where they operate in the world.

Our suppliers must commit to complying with the following requirements, many of which are drawn from the Ethical Trading Initiative (ETI) and International Labour Organisation (ILO) Conventions. These requirements represent minimum standards based on the principles of the United Nations Universal Declaration of Human Rights.

  1. Bribery and Corruption

- Suppliers shall not engage in acts of bribery and corruption and shall not falsify documents and records.

  1. Labour Rights

- 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. 

  1. 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 employer adopts 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.

  1. Working Conditions

- 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 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 clean and drinkable 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.

- Suppliers will ensure that personal protective equipment is available, and workers are trained in its use.

- Safeguards on machinery must meet or exceed local laws.

  1. Child Labour

Lacess Ltd. supports ILO Convention 138 with regard to the appropriate age of workers and will not work with suppliers who use child labour.

Child labour refers to work that:

- Is mentally, physically, or morally harmful to children;

- Can negatively affect their mental, physical, or social development, and

- Interferes with their schooling:

  • by depriving them of the opportunity to attend school;
  • by obliging them to leave school prematurely; or
  • by requiring them to attempt to combine school attendance with excessively long and heavy work. 

In short: child labour is work that deprives children of their childhood, their potential and their dignity, and is harmful to their physical and mental development.

  1. Living Wages

- 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 or any deductions from wages not provided for by Law shall not occur without the expressed permission of the worker concerned. All disciplinary measures should be recorded.

  1. Working Hours

- Working hours comply with any Law and benchmark industry standards, whichever affords greater protection.

- In any event, workers shall not on a regular basis be required to work in excess of 48 hours per week and shall be provided with at least one day off for every 7 day period on average. Overtime shall be voluntary, shall not exceed 12 hours per week, shall not be demanded on a regular basis and shall always be compensated at a premium rate.

  1. Discrimination

- 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.

  1. Regular Employment

- To every extent possible work performed must be 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, 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.

  1. Harsh or Inhumane Treatment

- Physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation shall be prohibited.

  1. Entitlement to Work and Immigration

- Only workers with a legal right to work shall be employed or used by the supplier.

- All workers, including employment agency staff must be validated by the supplier for their legal right to work by reviewing original documentation.

- The supplier shall implement processes to enable adequate control over agencies with regards to the above points and related legislation.

  1. Production & Sub-Contracting

- No sub-contract is allowed without the express approval of Lacess Ltd in writing.

- Where approved, it is the sole responsibility of Suppliers to ensure that any sub-contractors fully observe and comply with this Policy.

- Suppliers must have adequate processes in place for properly managing sub-contractors to ensure sub-contractors do not abuse, exploit or provide unsafe working conditions for their employees.

  1. Environment Compliance

- The facility shall comply with national and local environmental laws and regulations.

- The facility shall dispose of its production waste in accordance with local environmental laws and regulations.

- The facility must have identified and documented its key environmental impacts and implemented controls to minimise its impact on the environment with respect to solid waste disposal, hazardous chemicals storage and management, air and water emissions.

Compliance with the Policy

Lacess  Ltd. expects its suppliers to comply with all aspects of this Policy, and will seek up-to-date proof of compliance as they see fit, which may include 3rd party audits or in-person verifications.