We have reviewed & updated our approach to ethical trading to align more closely with industry best practice. This has resulted in our ethical code of conduct, which is in line with the Ethical Trade Initiative (ETI) Base Code which is in turn founded on International Labour Organisation (ILO) conventions.

This code consists of nine basic principles & reflects the most relevant international standards with respect to labour practice, which are used as a basis for its global works.

Our Code of conduct is an integral part of our business culture & is made available to all employees within our business & across our supplier base.

All suppliers to us must ensure that their goods have been produced under acceptable conditions with regards to the following standards:

– Production without any exploitation of any person involved in producing Loake goods
– Produced lawfully through fair & honest dealings
– Within decent working conditions
– To acceptable quality standards
– Without damaging the environment & in a sustainable manner

At Loake Bros Ltd we are committed to achieving the best levels of visibility & transparency of our full production & supplier base, we require all our suppliers to provide us with full transparency of their business & full access to help us assist & support them in improvement of their processes & practices to help them align with us in operating to best recognised industry standards.

Achieving full visibility & transparency of any supplier chain is complex & takes time, our code of conduct is designed to be impartial, achievable & easy to manage for our suppliers.

We will work directly with our production sites & suppliers to directly help & support them to achieve identified Corrective Action Plans (CAPs). Where improvements & remediations are required these will be carried out on an agreed & reasonable timeline.

We take our responsibilities to protect the planet seriously & continue to develop our own Environmental & Sustainability policies in line with best practice & international guidelines.

We are taking steps to reduce our waste, manage our energy & resource consumption & gain higher levels of transparency & visibility of our raw material sourcing practices. This is a journey we are committed to & we look forward to sharing our progress with you along the way.

Code of Conduct

1. Legal Requirements

Suppliers & factories that produce goods for Loake Bros Ltd must fully understand & comply with all applicable laws & regulations in the country where they operate & produce, including laws relating to employment, health & safety & the environment.

2. Living Wages are Paid

Loake Bros Ltd insists that the wages & benefits paid for a standard working week, meet a minimum national legal standard or industry benchmark standard, whichever is higher. In all instances wages should always be enough to meet basic needs & to provide some discretional income.

All workers must be provided with written & understandable information about their employment conditions in respect to wages before they enter employment. Wage slips must be provided with each payment made & it must be easy to understand with regards to rate & hours of pay.

Deductions of 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 express permission of the worker concerned. All disciplinary measures should be recorded for reference & review.

3. Working Hours are Not Excessive

Working hours must comply with national laws, collective agreements & the provisions of the clause, whichever affords the greater protection for workers. The below sub-clauses are based on international labour standards & ETI Base Code.

Working hours excluding overtime, shall be defined by contract, & shall not exceed 48 hours per week*. All overtime shall be voluntary. Overtime shall be used responsibly, taking into account all the following: the extent frequency & hours worked by individual workers & the workforce as a whole. It shall not be used to replace regular employment. Overtime shall always be compensated at a premium rate, which is recommended to be not less than 125% of the regular rate of pay.

The total hours worked in any seven-day period shall not exceed 60 hours, except where covered by the below clause.

Working hours may exceed 60 hours in any seven-day period only in exceptional circumstances where all the following are met:
– This is allowed by national law
– This is allowed by collective agreement freely negotiated by a workers’ organisation representing a significant portion of the workforce
– Appropriate safeguards are taken to protect the workers’ health & safety
– The employer can demonstrate that exceptional circumstances apply such as unexpected production peaks, accidents or emergencies.
Workers shall be provided with at least one day off in every seven-day period or, where allowed by national law, two days off in every fourteen-day period.

*International standards recommend the progressive reduction of normal hours of work, when appropriate, to 40 hours per week, without any reduction in workers’ wages as hours are reduced.

4. No Employment of Children

You should not employ children, which are classed as a person younger than 15 years of age. Education related work & apprenticeships are acceptable as long as permission has been sought from the child’s parents or legal guardian, the child is not being exploited & there is deemed to be no risk to the child’s health, education & development.

Companies shall develop or participate in & contribute to policies & programmes which provide for the transition of any child found to be performing child labour to enable her or him to attend & remain in quality education until no longer a child; ‘’child’’ & ‘’child labour’’ being defined in the appendix.

All factories & production sites must have effective systems in place to check the ages of all recruited employees & must hold copies of official documentation for every worker that verifies their date of birth. If there are no official documents available, all appropriate & reliable sources must be used in order to check a child’s age. Children & young persons under 18 shall not be employed at night or in hazardous conditions .

These policies & procedures shall conform to the provision of the relevant ILO standards.

5. Forced Labour

You must not force people to work for you by threatening means.

You must not use prison labour. You must not use bonded labour- workers forced to work for you until debts have been paid off.

Workers are not required to lodge monetary deposits or their identity papers with their employer & are free to leave employment after reasonable notice.

6. Disciplinary Practices

Workers must not be threatened by physical punishment or any form of mental or verbal abuse. You must provide a workplace in which any form of harassment or intimidation is prohibited.

7. Discrimination

There must be 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.

8. Freedom of Association

Workers must have the right to join or form trade unions of their own choosing & to bargain collectively.

The employer adopts an open attitude towards activities of trade union & their organisational activities. Workers representatives are not discriminated against & have access to carry out their representative functions in the workplace. Where the right to freedom of association & collective bargaining is restricted under law, the employer facilitates & does not hinder the development or parallel means for independent & free association.

9. Health & Safety General Welfare

Workers must be provided with a safe place to work, whereby all local laws regarding to health, safety & welfare are fulfilled in the workplace, this also applies to any accommodation you may provide for your workers.

Health & safety representatives must be employed, who manage the procedures & take all reasonable precautions to prevent any accidents & injury bearing in mind the prevailing knowledge of the industry & any specific hazards. They must ensure that all workers are briefed with procedures & are aware of the systems in place. Workers shall receive regular & recorded health & safety training & such training shall be repeated for new or reassigned workers.

The environment in which they work should have acceptable lighting & ventilation & clean drinking water must be provided. Access to clean toilet facilities & to potable water must be provided, & if appropriate sanitary facilities for food storage shall be provided.

10. Entitlement to Work

Only workers with a legal right to work in the country should be employed. For both workers & agency workers, original documents should be reviewed & then returned to workers to verify right to work. To every extent possible work performed must be based on recognised employment relationships established through national law & practices. Obligation to employees under labour or social security laws & regulations arising from the regular employment relationship shall not be avoided through the use of labour-only contracting, sub-contracting, or home working agreements, 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 excessive use of fixed-term contracts of employment.

11. The Environment & Sustainability

All production sites & suppliers of materials & components must comply with all relevant laws & regulations regarding the protection & preservation of the environment. This includes obtaining & maintaining all required permits, approvals, licences & registration with regards to environmental protection. All waste that is created by suppliers must be disposed of in a way that complies with local & governmental laws & does not harm the environment or local population.

We strive constantly to find more sustainable materials & components for our product to limit & reduce its environmental impact. We require all our suppliers in every area to do the same to work with us to improve our product for the good of planet.

Appendix

Definitions

Child: A child as per our definition is any person younger than 15 years of age, unless local minimum age law stipulates a higher age for workers or mandatory schooling, in which case the higher age shall apply. If however, local minimum age law is set at 14 years of age in accordance with developing countries exceptions under ILO Convention no. 138, the lower age will apply.

Young Person: We define a young worker as any worker over the age of a child as defined above & under the age of 18.

Child Labour: Any work by a child or young person other than the age(s) specified in the above definitions, which does not comply with the provisions of the relevant ILO standards, & any work that is likely to be hazardous or to interfere with the child’s or young person’s education, or to be harmful to the child’s or young person’s health physical, mental, spiritual, moral or social development.

ETI Base Code

Listed below are the nine basic principles that reflect the most relevant international standards with respect to labour practices, which are used as a basis for its works:

– Employment is freely chosen
– Freedom of association & the right to collective bargaining is respected
– Working conditions are safe & hygienic
– Child Labour shall not be used
– Living wages are paid
– Working hours are not excessive
– No discrimination is practised
– Regular employment is provided
– No harsh or inhumane treatment is allowed

In order to achieve these goals, this needs to be a collaborative effort between us & our production sites & suppliers. Loake Bros Ltd is committed to ensure the ETI Base Code is applied to our supplier chain.

http://www.ethicaltrade.org/eti-base-code