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Ethical Trading Policy

ETHICAL CODE OF PRACTICE
OF
RELIANCE WORLDWIDE CORPORATION (UK) LTD

RELIANCE WORLDWIDE CORPORATION (UK) LTD is part of RELIANCE WORLDWIDE CORPORATION(RWC) comprising all those companies wholly or partially owned by GSA Industries (AUST.) Pty Ltd. CORPORATION (UK) LTD (“the Company”).  RWC is committed to instilling a strong anti-corruption culture and to upholding all laws relevant to countering bribery and corruption, including, but not limited to, the Bribery Act 2010.

It is the policy of RWC to protect and promote the Health, Safety and Welfare of all personnel involved in producing our products worldwide.

This document is prepared to give guidance and instruction on the minimum standards acceptable to RWC in the manufacture of components and raw materials supplied to the Group’s companies and of finished products. The principles of this Code apply to all suppliers of the Group, but within Australia, compliance will be defined as adherence to local legislative minimum standards. This Code of Practice is written specifically as a guide for supplying companies and factories based outside of Australia.

The Code of Practice forms part of the standards by which RWC will select new supplier factories and / or sub-contractors. Factories supplying to RWC are expected to comply with this code and may be audited against these principles. Any factory failing significantly or consistently to adhere to these standards and making no substantial efforts to improve against this Code may not be considered an acceptable supplier to RWC.

Process

RWC recognises that not all factories and worksites will be able to achieve all of the standards immediately; but RWC will not purchase from factories or worksites where management practices indicate an absence of commitment to improvement. As a condition of supply, all factories must meet the Critical Failure Points (identified below in bold) and site management will be requested to demonstrate commitment in progressing towards the standards detailed within this Code of Practice.

Age of Workers

  • Factories and production sites must only employ workers who are of or over the local legal minimum age relative to the worked being conducted. Where the local minimum age is not set, or is set at less than 15 years of age, no worker should knowledgeably be less than 15 years old. Exceptions include young workers receiving work experience or as otherwise allowed by local law.
  • Young people (under 18) should not work at night (i.e. between the hours of 10 pm and 6 am) or in hazardous conditions, unless they are adequately trained in the work being conducted and their well-being is effectively monitored or adequately supervised and they’re well-being monitored.

Forced Labour

RWC does not condone, and WILL NOT be a party to, any form of forced or involuntary labour.

  • Factories or worksites must not use forced, bonded or involuntary labour.
  • Workers are not forced to lodge unreasonable deposits or their identity papers with their employers. In countries where deposits are prohibited by law, no deposits are allowed.
  • Worker are not subject to physical abuse, the threat of physical abuse, verbal abuse or any other forms or intimidation.

Disciplinary Procedures

  • Any disciplinary rules are written and communicated to workers in a language that they understand.
  • All employees must be treated with respect and dignity.
  • Deductions from pay must not be made as a tool of discipline. It is NOT acceptable to discipline employees by withholding wages or payment.

Terms of Employment

Hours of Work:

  • Standard working hours must comply with the limits set by local law.
  • Overtime hours comply with the limit and regulations set by local law.
  • Overtime is voluntary or complies with regulations set by local law or, as agreeable between employer and worker.
  • Workers have at least one day off in every seven days as an average throughout the year.
  • Workers take suitable and sufficient breaks during the working day.

Wages:

  • Wages and benefits comply with local law.
  • Any overtime paid is paid at an additional rate.
  • Any deductions from wages must be clearly communicated to workers and be reasonable in the context of the total wage.
  • Wages are paid regularly (at least monthly) and on time.
  • Sites keep accurate records of the ages of all workers.
  • Sites keep accurate records showing wages earned and hours worked by each worker (both for standard working hours & if worked for overtime hours).
  • All workers receive payslips (or other media) that clearly shows how wages are calculated and all deductions from wages.
  • Any loan or credit schemes operated by factories or worksites for their workers should be transparent and clearly explained to workers and fully documented.
  • Payment must be made in currency. Payment in kind is not acceptable and must not be undertaken.

Discrimination

  • There is no discrimination in hiring, promotion or employment conditions on any grounds.

Contract of Employment

  • All workers have signed a written contract that sets out the terms and conditions of their employment in a language they understand and have been given a copy of it. Terms and conditions of employment have been clearly communicated in a language understood by workers.

Representation

  • Workers have the right and freedom of choice to belong, or not belong to a trade union of their choosing, without pressure or influence from the business. Where the above right is restricted by law, management facilitates the development of alternative means for workers’ representation as permitted by the legal framework.
  • Workers’ representatives are not discriminated against.

Health and Safety

RWC will give preference to suppliers whose Health and Safety standards show a commitment beyond that which is the legal minimum.

  • There must be an adequate number of safe, unblocked fire exits, escape routes and fire fighting equipment accessible to workers from each floor or area of the factory or production site and, if provided, accommodation.
  • The factory or worksite is a safe and hygienic place to work.

Where Health and Safety standards do not match the guidelines below there must be acceptance by the supplier of the need to improve Health and Safety standards demonstrated either by a plan of activity or evidence of ongoing actions to improve Health and Safety standards.

  • Fixed guards should be used whenever possible on moving parts that could cause injury. The guards should be properly fastened in place with screws or nuts and bolts which need tools to remove them.
  • The factory or worksite takes adequate and appropriate steps to prevent avoidable health and safety hazards.
  • The use of hazardous substances / activities is kept to a minimum.
  • The risk of harm from hazardous substances / activities is minimised through the provision of safety equipment, signage, training and a safe factory infrastructure.
  • Adequate provision is made for evacuation and fire-fighting in all areas of the factory or worksite.

Personal Protective Equipment (PPE)

  • PPE is made available without charge to any employee where there is a risk to their health and safety that cannot be controlled by an alternative method. This includes gloves. coveralls, safety footwear, safety spectacles, hearing protection and respirators protection where applicable.

Use of Dust / Fume Extraction

  • Extraction of dust fumes or harmful vapours must be used to ensure that adequate fresh air is provided.

Lighting Levels

  • Adequate lighting levels must be provided including for manufacturing during normal hours of darkness.

Noise Levels

  • Nose should be kept at a reasonable level or hearing protection worn in areas where that is not possible.

First Aid on Site

  • Each factory should have at least one first aid kit and one trained first-aider to administer the necessary treatment.

Training

  • All employees should receive health and safety training when they first join and at regular intervals thereafter.
  • All employees that operate machinery should receive training on how to use and maintain their machinery safely. They should be aware of:
    • How to use the machine.
    • How to stop the machine in an emergency.
    • How to ensure that all guards are in the correct position.
    • How to ensure that all protective devices are working.

Hygiene

  • The factory or worksite provides a clean and hygienic place of work and rest consistent with local standards and the nature of the industry.
  • Workers have access to clean and safe drinking water at all times.
  • Workers have access to sufficient clean and hygienic toilets and washing facilities.
  • Canteens, kitchens and any food preparation and storage facilities provided for workers are clean and hygienic.

Accommodation

RWC does not encourage the use of dormitory factories as a principle. But, where factories provide dormitory accommodation:

  • Accommodation is safe, hygienic and segregated from the factory or production area and from material storage areas.
  • Employees should be able to lock their door if they wish, but they are not to be locked in by someone else excepting for security or safety issues.
  • Accommodation is clean and provides individual privacy.
  • Adequate provision is made for evacuation and fire fighting in accommodation areas. An evacuation plan that exists is displayed in the accommodation.

Environment

  • The factory or production site does not knowingly contravene local and national environmental legislation without being able to demonstrate a plan of action to improve.

 

Edwin De Wolf

CEO – EMEA

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