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Brompton’s Ethical Code of Conduct

 

Brompton is committed to operating a responsible business that respects suppliers, workers and the environment. This Code of Conduct strives to keep workers safe and free from exploitation and reduce the environmental impacts associated with our supply chain operations.

We partner with suppliers who share our values and therefore require all suppliers, regardless of size or manufacturing process, to comply with these minimum standards. This Code of Conduct is based on the fundamental conventions of the International Labour Organisation (ILO) and is aligned with other industry social standards, including the World Federation of Sporting Goods Industries (WFSGI) Code of Conduct.

 

Our Minimum Standards

 

Employment is fair

Employment is voluntary

No under-age workers

Pay is fair and legal

Freedom of Association and collective bargaining is supported

Working hours are not excessive

No discrimination

No harassment or abuse

Migrant, temporary and agency workers are covered by this code

 

Facilities are safe

Provide a safe and healthy workplace

Protect against fire and relevant risks

Provide training for employees

 

Operations are sustainable

Environmental impacts are identified and reduced

Packaging is kept minimal and sustainable

Suppliers are open and transparent

 

Employment is fair

 

FORCED LABOUR & MODERN SLAVERY

  • Suppliers shall not use forced labour, including prison labour, indentured labour,
    bonded labour and other forms of forced labour or modern slavery.
  • Workers shall have free access to all their identity documents, such as passports.
  • Workers shall not be required to make monetary deposits for finding
    employment or required to pay recruitment fees to their employer, recruitment
    agencies or any other intermediaries.
  • Workers are free to leave their employer after reasonable notice. 

 

WAGES AND BENEFITS

  • Suppliers shall pay and guarantee all workers a wage that meets or exceeds
    the national legal minimum wage or the minimum wage set by the collective
    bargaining agreements, whichever applies in a given country. 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.
  • Suppliers shall provide workers with benefits as required by law or contract, including holidays, sick and maternity leave and statutory severance.
  • Only legally mandated deductions are allowed, and suppliers shall not make
    deductions from workers’ wages for disciplinary purposes.

 

FREEDOM OF ASSOCIATION & COLLECTIVE BARGAINING

  • 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.

 

HOURS OF WORK

Employees shall not be required, except in extraordinary business circumstances,
to work in excess of 60 hours (including overtime) per week, or the local legal
requirement, whichever is less. Overtime work must be voluntary. Employees shall be
allowed to at least twenty-four (24) consecutive hours rest within
every seven-day period.

 

 

NON-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. Foreign or domestic migrant labour shall be treated on an equal basis with local employees. 

 

MIGRANT, TEMPORARY AND AGENCY WORKERS

  • This Code of Conduct applies equally to migrant workers (cross country and internal migrants), temporary workers and agency workers as it does to regional workers, permanent workers and local nationals.
  • Suppliers are responsible for ensuring any intermediary employers or recruitment agencies understand and comply with the contents and spirit of this Code of Conduct.

 

CHILD LABOUR

  • Supplier shall not employ (or otherwise permit anyone to work) who is under the age of 15, under the local minimum school leave age or under the local minimum employment age, whichever is higher.
  • Suppliers shall have adequate age verification policies and procedures in place to ensure children are not engaged in work.
  • Physically demanding and hazardous labour is prohibited for anyone below the age of 18 years.

 

REGULAR EMPLOYMENT

  • All workers shall have a written contract in compliance with the country law and practice.
  • Suppliers shall not avoid the obligation to provide workers with labour and social benefits for example, by using extensive probation periods or through an excessive use of subcontractors, temporary workers, agency workers and apprentices.

 

HARRASMENT OR ABUSE

  • Suppliers shall treat all staff and workers with dignity and respect. No one shall be subject to physical, verbal, sexual or psychological intimidation, harassment, violence or abuse.
  • Monetary fines or wage withholdings shall not be used as a means to maintain labour discipline.

 

 

 

 

 

Facilities are safe

 

HEALTH & SAFETY

  • Suppliers shall ensure that all personnel are appropriately protected from hazards in the workplace.
  • Suppliers shall conduct risk assessments to determine all relevant risks, including but not limited to, the exposure to chemicals and physical hazards.
  • Supplier shall act to mitigate such risks through proper design, engineering and administrative controls, preventative maintenance, training and safe work procedures.
  • Suppliers shall provide personnel using machinery with protection through an appropriate design of machine, training, preventative maintenance and protective personal protection items.
  • Workers shall receive regular and recorded health and safety training.
  • Access to clean toilet facilities and safe to drink 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.
  • Responsibility for health and safety shall be assigned to a senior management representative at the site.

 

Operations are sustainable

 

ENVIRONMENT

  • Suppliers shall use all reasonable endeavours to minimize the environmental impact of its activities, products and services during the whole product life cycle: production, transport, use, disposal or recycling.
  • Where possible, suppliers should not install any new coal fired boilers and instead should seek alternative options.
  • Suppliers shall use all reasonable endeavours to reduce the amount of packaging that is associated with Brompton products.
  • Where possible supplier should seek to utilise on-site renewable energy generations or access renewable energy contracts.

 

EXPECTATIONS

  • Suppliers are expected to communicate the contents of this Code of Conduct to all their personnel and subcontractors, in their local language(s).
  • Brompton require all suppliers, regardless of size or manufacturing process, to fully comply with these minimum standards.
  • Supplier shall provide Brompton with complete access to social and environmental factory assessments including but not limited to facilities, relevant documentation and worker interviews.
  • Brompton reserves the right to review suppliers ‘compliance with this Code of Conduct at any time. In exceptional cases, where full compliance is not immediately possible, Brompton will work with suppliers on the development and implementation of corrective actions plans, to which suppliers must show commitment and continuous improvement.

 

If you have any questions, or if you are concerned about non-compliance, please contact us at sustainability@brompton.co.uk