Ethical Policy

Environment
Ethical Sourcing
Employment Standards for Suppliers

Environment

Clerk & Teller consider environmental issues to be an influential factor in our drive for world-class standards and sustainable development.

We recognise that our business activities affect the natural environment in a number of ways. We aim, through continuing improvement, to minimise the adverse effects on the environment and the earth's natural resources, whilst safeguarding the health & safety of our employees and the public.

We will strive to:

• Comply with or exceed relevant legislative requirements. Where these are inadequate we will set our own standards that comply with our environmental & ethical criteria.
• Develop and implement a set of procedures to monitor, control and review our significant environmental impacts (an Environmental Management System or EMS) and update it as necessary.
• Encourage manufacturing suppliers to recognise their environmental responsibilities, offering support, training and advice to help them implement sound environmental health & safety policies and practices.
• Provide safe working conditions for our employees, encouraging them to identify possible improvements and providing training wherever necessary.
• Design and manufacture our products with consideration of the environment, moving towards greater use of suitable materials and processes.
• Reduce progressively the environmental impact caused by our products and activities.
• Communicate our policy and achievements widely and, where appropriate freely share and disseminate the techniques used to improve environmental performance.
• Make efforts to inform the end users of our products how to use and dispose of them and their packaging responsibly.
• Protect local and wider communities from environmental damage or nuisance resulting from our activities, offering support to community ventures in the localities in which we operate.

Ethical Sourcing

At Clerk & Teller we believe that business should be conducted honestly, fairly and with respect for people, their dignity and their rights.

We are working with our suppliers to ensure the provision of fair wages and working hours, safe and hygienic working conditions, regular employment and no discrimination or harsh or inhumane treatment of employees.

Our Suppliers

Since we started out, we have been working with our suppliers to improve standards.

Our policy is only to do business with suppliers that adopt and implement our standards or have their own policies that reflect the same values.

There are some difficult issues within our supply chain and our strategy is to understand why they come about. This usually involves some research, so before we do any work with our suppliers we meet with local organisations and institutions to establish the local standards and level of implementation. With our suppliers, we then try to address problems through an appropriate programme.

We have learnt a lot about what works and what does not work. We have established some principles which underlie our methodology.

The Relationship

Principle 1 - The strength of the trading relationship

Our ability to work with our suppliers depends on a strong business relationship. If this relationship is not strong, it is unlikely that the owners of the factory will listen in the first place or do anything in the second. Some suppliers might make cosmetic changes to the way that they do things but these are rarely sustainable.

If the relationship is a long term one then the management can begin to build in the changes to their development plan, knowing that the business is likely to continue.

Most factory owners and managers are proud of their factories and have a long term interest in developing their workforce and the production.

Principle 2 - Trust and respect

Our reviews are done with the factory's management team. Our business relationship is based on trust and respect and our reviews are too. We put a lot of effort into our reviews and it is only fair that management are part of the process. If they play a full role in the reviews they are much more likely to follow through with the recommendations.

Local legal compliance is part of our trading contract with suppliers.

We do not employ a third party to do our reviews. This is neither a "tick box" exercise, pass or fail, nor a policing one. We have an in-house team of people to conduct the reviews, which are done with representatives from our brand or operating companies.

In our experience it is not sufficient, or useful, just to inform factories of poor practices; often they need help and encouragement to identify best practice. There are no substitutes for human resource departments, staff handbooks, comprehensive and clear records, grievance procedures etc.

Follow up is essential to the whole process.

The Process

Principle 3 - Working with local institutions

Poor standards in factories are based in a number of factors, not least that the institutions that are supposed to set and monitor standards are often underdeveloped and/or under-resourced. We therefore try to engage with local institutions for the reviews. In the best cases we are able to have a local health and safety expert with us to advise the factory on standards and resources. Sometimes the relationship continues after the review and this is a good result.

Principle 4 - Worker representation

If there is an active health and safety committee and/or a workers' representative committee then the review can be much more productive. A programme of improvement is more effective if these committees are consulted and included in the process. In many factories these committees are absent or ineffective it is then necessary to ascertain workers' views. This work is usually done by a local non-governmental organisation or people from a local social research institution. They have experience in talking to workers/women, speak the local language and know how to gain the interviewees' confidence. They speak to workers individually and in groups and often use a questionnaire to reach more workers.

We do not, unless it is part of a wider project, talk to workers without the knowledge of management. We accept that off-site interviews might yield more information but it could affect our relationship with management and therefore compromise our ability to find sustainable solutions.

Principle 5 - Disengagement

We have sometimes disengaged with factories because of poor business standards. However the reason is almost always poor management attitude to the overall business relationship and little concern for workers' welfare.

Our Partners

Principle 6 - Building capacity

Rarely does a factory have poor standards in isolation. It is usually symptomatic of conditions in that sector in a region or country. We have therefore worked with local institutions to develop a number of resources to enable factories to make progress:

• Working in Vietnam with the Vietnamese Chamber of Commerce and Industry to develop best practice manuals, liaising with government departments to improve implementation of standards.
• Working with our suppliers in Portugal, India and Pakistan to improve working conditions of homeworkers.
• Working with our suppliers in Pakistan and India on a community programme for children who have dropped out of school prematurely.
• Our Hazardous Substances in Factories booklet is available in English and Chinese and parts have been translated into Portuguese, Vietnamese and Indonesian.
• A good practice manual is available in a bi-lingual (English and Chinese) edition.
• We developed in Vietnam and China a mould for a glue pot which minimises solvent vapour emissions.
• Modules to help factories establish systems to manage their factories better.
• Working with the Red Cross in several countries to train first aiders.
• Working with factories to find ways to improve internal communications and consultation.

Employment Standards For Suppliers

Code of Employment Standards for Suppliers

This Code provides minimum standards that should be exceeded where possible. In applying it, suppliers must comply with national and other applicable laws and, where the provisions of the law and this Code address the same subject, apply the provision that gives workers the greater protection.

Living wages are paid

• The wages and benefits paid for a standard working week are at or above national minimum legal levels or industry benchmark levels, whichever are higher. In any event, wages are always sufficient to meet basic needs and to provide some discretionary income.
• All workers, before entering employment, are provided with written and understandable information about the basis and calculation of their wages and any deductions to be made from them. Then, each time they are paid, workers are given written particulars of their wages for the pay period concerned.
• No deductions are made from wages as a disciplinary measure, nor are any other deductions made without the express written permission of the worker concerned, unless required by law.

Working hours are not excessive

• Working hours comply with national laws or benchmark industry standards, whichever afford greater protection. Workers are not, in any event, required to work more than forty-eight hours per week on a regular basis.
• Overtime is voluntary, does not exceed twelve hours per week, is not demanded on a regular basis and is always paid at a premium rate.
• Workers are allowed at least one day off on average per week.

Working conditions are safe and hygienic

• A safe and hygienic working environment is provided, subject to any specific hazards intrinsic to the job. Adequate steps are taken to prevent accidents and damage 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 in the working environment.
• Workers receive health and safety training on recruitment and, subsequently, at regular intervals. Additional training is given to workers who change to jobs that are exposed to different risks.
• Workers are provided with access to clean toilet facilities and potable water. Hygienic facilities for food storage are provided, if appropriate.
• If accommodation is provided, it is clean and safe and meets the basic needs of the workers.
• Responsibility for health and safety is assigned to a senior manager.

Child labour is not used

• There is no recruitment of child labour.
• If any incidence of child labour is identified in the supplier's industry and region, the supplier shall initiate, or participate in, a programme to transfer any children involved in child labour into quality education until they are no longer children.
• No one under eighteen years old is employed at night or in hazardous work or conditions.
• In this Code, "child" means anyone under fifteen years of age, unless national or local law stipulates a higher mandatory school leaving or minimum working age, in which case the higher age shall apply; and "child labour" means any work by a child or young person, unless it is considered acceptable under the ILO Minimum Age Convention 1973 (C138).

Employment is freely chosen

• There is no use of forced, bonded or involuntary prison labour.
• Workers are not required to lodge deposits, identity papers or any other security with their employer and are free to leave their employment after reasonable notice.

No discrimination is practised

• There is no discrimination in recruitment, wages, access to training, promotion, termination or retirement, based on race, caste, national origin, religion, age, disability, sex, marital status, union membership, political affiliation or on any other basis unrelated to the ability to do the job.

There is no harsh or inhumane treatment

• Physical abuse or discipline, verbal abuse, the threat of physical abuse, sexual or other harassment and other forms of intimidation are not permitted and not practised.

Freedom of association and the right to collective bargaining are respected

• All workers have the right to join or form trade unions of their own choosing and to bargain collectively They also have the right to choose not to join a trade union.
• The supplier adopts an open attitude towards the activities of trade unions and their recruitment of members.
• Workers' representatives are not discriminated against and are allowed access to the workplace to carry out their representative functions.
• If rights to freedom of association and collective bargaining are restricted by law, the employer supports the development of parallel means for workers' free and independent association and bargaining.

Regular employment is provided

• As far as possible, work is performed on the basis of the regular employment relationship established through national law and practice.
• The supplier does not attempt to avoid the normal obligations of employer to employees under labour or social security laws and regulations by replacing the regular employment relationship with arrangements such as: labour-only contracting, sub-contracting, home-working, apprenticeship schemes with no real intent to impart skills or provide regular employment, or excessive use of fixed term contracts of employment.