EP01- Ethical Sourcing Policy
Version 4 - March 2025
Introduction
Eurosonic Group Ltd. is committed to legal compliance and ethical business practices in all operations and will only do business with suppliers who obey the laws of the country in which they operate, and the principles expressed in this Code of Practice.
The Group expects all those involved in the supply chain of our products to respect the rights and wellbeing of their employees, and implement systems and controls aimed at minimising the risk of modern slavery taking place within the organisation, or in any of our supply chains. We expect our suppliers, contractors and business partners to adhere to the principles in this Sourcing Policy, in order to promote high standards of welfare.
Factory Requirements
Eurosonic Group product can only be placed in factories that have a 3rd party ethical audit. Acceptable audit types are BSCI, SMETA, SA8000 and Better Works. Audits must be renewed at least every 12 months, and it is the supplier’s responsibility to ensure that audits are booked in a timely fashion to ensure there is no lapse.
Eurosonic Group do not accept Fully Announced audits. Audits must be booked on a Semi-Announced or Unannounced basis.
As well as an ethical audit, all manufacturing sites must provide a valid building and fire certificate to demonstrate that the buildings are in a safe structural condition and comply with local law in relation to fire safety.
Factories that work with The Group should understand that the ethical audit process is an ongoing procedure and show continual commitment to improve. All factories are expected to work towards remediation of any non-compliances that are found on an audit. Factories should be aware that ethical audits may be graded differently by different customers and licensors, and should be willing to undergo any corrective actions that may be issued. The Group will work together with all factories on remediation of any non-compliances and expects full cooperation in this matter.
Suppliers may not place Eurosonic Group product in a factory that has not been previously declared to The Group, and suppliers are expected to do their own due diligence to ensure that any factories proposed are suitable for the goods, meet the ethical audit requirements and adhere to the below code of practise.
New factories proposed for Eurosonic Group product will undergo assessment by an internal team before orders are placed – The Group will not retrospectively approve factories.
Certain Licensors and customers reserve the right to visit and/or audit any factories that have been declared to them, and we expect full co-operation from our suppliers in this matter. All factories must be willing to allow reasonable access to our customers or their representatives, and any costs associated with these audits will be at the factory’s expense unless covered by the customer themselves.
The Group reserves the right to withdraw production from a factory at any time if it does not meet our, or our licensors, ethical requirements, or is not showing commitment to improve on reoccurring issues.
Code of Practise
1: Employment is freely chosen
1.1 There is no forced, bonded, prison, slave, trafficked or unwilling or unpaid labour in any form, this includes forced overtime. All work MUST BE carried out voluntarily.
1.2 Workers are not required to lodge "deposits" or their identity papers, passports, identity cards with their employer and are free to leave their employer after reasonable notice period in accordance with local law.
2: Freedom of association and the right to collective bargaining are respected
2.1 Workers, without distinction, have the right to join or form trade unions of their own choosing and to bargain collectively.
2.2 The employer adopts an open attitude towards the activities of trade unions and their organisational activities.
2.3 Workers representatives are not discriminated against and have access to carry out their representative functions in the workplace.
2.4 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.
2.5 Workers shall be able to file grievances to their employers, in doing so workers shall not suffer retaliation or victimisation for grievances raised.
3: Working conditions are safe and hygienic
3.1 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 arising out of, associated with, or occurring in the course of work, by minimising, so far as is reasonably practicable, the causes of hazards inherent in the working environment.
3.2 Workers shall receive regular and recorded health and safety training, and such training shall be repeated for new or reassigned workers.
3.3 Access to clean toilet facilities and to potable water, and, if appropriate, sanitary facilities for food storage shall be provided.
3.4 Accommodation, where provided, shall be clean, safe, and meet the basic needs of the workers.
3.5 The company observing the code shall assign responsibility for health and safety to a senior management representative.
4: Child labour shall not be used
4.1 There shall be no recruitment of child labour. Nobody shall be employed under the minimum age (as set by local law).
4.2 Companies shall develop or participate in and contribute to policies and programmes which provide for the transition of any child found to be performing child labour to enable her or him to attend and remain in quality education until no longer a child; "child" and "child labour" being defined in the appendices.
4.3 Young persons under 18 shall not be employed at night or in hazardous conditions. Safeguards are to be in place to ensure safe working conditions.
4.4 These policies and procedures shall conform to the provisions of the relevant ILO standards.
5: Living wages are paid
5.1 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.
5.2 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.
5.3 Deductions from 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 expressed permission of the worker concerned. All disciplinary measures should be recorded.
6: Working hours are not excessive
6.1 Working hours must comply with national laws, collective agreements, and the provisions of 6.2 to 6.6 below, whichever affords the greater protection for workers. 6.2 to 6.6 are based on international labour standards.
6.2 Working hours, excluding overtime, shall be defined by contract, and shall not exceed 48 hours per week*
6.3 All overtime shall be voluntary. Overtime shall be used responsibly, taking into account all the following: the extent, frequency and hours worked by individual workers and 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.
6.4 The total hours worked in any 7 day period shall not exceed 60 hours, except where covered by clause 6.5 below.
6.5 Working hours may exceed 60 hours in any 7 day period only in exceptional circumstances where all of the following are met:
this is allowed by national law;
this is allowed by a collective agreement freely negotiated with a workers’ organisation representing a significant portion of the workforce;
appropriate safeguards are taken to protect the workers’ health and safety; and
the employer can demonstrate that exceptional circumstances apply such as unexpected production peaks, accidents or emergencies.
6.6 Workers shall be provided with at least one day off in every 7 day period or, where allowed by national law, 2 days off in every 14 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
7: No discrimination is practiced
7.1 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.
8: Regular employment is provided
8.1 To every extent possible work performed must be on the basis of recognised employment relationship established through national law and practice.
8.2 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.
9: No harsh or inhumane treatment is allowed
9.1 Physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation shall be prohibited.
10. Environment
10.1 Suppliers will ensure their activities, and those of their suppliers are conducted with due regard for the environment and comply with applicable environmental, safety and health regulations.
