OUR ETHICAL TRADE CODE OF CONDUCT

This code of conduct states the minimum standards that Sabry Marouf expect of all its supply chain partners with regards to social issues and the working conditions of all workers in our supply chain. Our manufacturing business partners are required to read and sign the declaration of understanding which commits them to comply with this code and confirm that they share our values. 

However we will not continue to cooperate with suppliers at any level of the supply chain who do not commit to make improvements in cases where our standards have not been met. In those cases we will do our best to work towards a positive resolution, but we will not hesitate to terminate those business relationships if it becomes clear that our values are not shared. We will make every effort to support the fair treatment of workers who may be impacted through these decisions. 

Our suppliers are required to align with and support our values as defined in our ethical trade code of conduct. We believe that through mutual transparency of business models, cost base, work practices and goals we can create a better way of working that inherently delivers governance of and best practice in the key areas of ethical trading, environmental protection and business ethics. 

These standards are based on the 9 provisions of the ethical trade initiative (ETI) base code which is widely recognised and used as the minimum standard across most industry. Please note that in paragraphs 1 – 9 the sections in italics are not written into the eti base code but are updated additions to it. Sections 10 – 16 are further additions that are widely included in code of conduct issued by responsible businesses. These standards are consistent with the united nations universal declaration of human rights and the fundamental conventions of the international labour organisation (ILO).

01 EMPLOYMENT IS FREELY CHOSEN

1. There is no forced, bonded or involuntary prison labour. 
2. Workers are not required to lodge "deposits" or their identity papers with their employer and are free to leave their employer after reasonable notice.



02 FREEDOM OF ASSOCIATION AND THE RIGHT TO COLLECTIVE BARGAINING ARE RESPECTED

1.  Workers, without distinction, have the right to join or form trade unions of their own choosing and to bargain collectively. 
2. The employer adopts an open attitude towards the activities of trade unions and their organisational activities. 
3. Workers representatives are not discriminated against and have access to carry out their representative functions in the workplace. 
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.

03 WORKING CONDITIONS ARE SAFE AND HYGIENIC

1. A safe and hygienic working environment shall be provided, bearing in mind the prevailing knowledge of the industry and of any specific hazards. Building strength and stability is a priority and emergency exits must be unlocked and unblocked at all times. Emergency evacuation procedures must be trained and practised at least twice a year.  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.
2. Workers shall receive regular and recorded health and safety training, and such training shall be repeated for new or reassigned workers. 
3. Access to clean toilet facilities and to potable water, and, if appropriate, sanitary facilities for food storage shall be provided. 
4. Accommodation, where provided, shall be clean, safe, and meet the basic needs of the workers. 
5. The company observing the code shall assign responsibility for health and safety to a senior management representative.
6. Workers must be allowed freedom of movement in the workplace, outside of the workplace after working hours, and in and around the dormitory or accommodation if provided

04 CHILD LABOUR SHALL NOT BE USED

1. Child labour shall not be used and there shall be no new recruitment of child labour. 
2. Suppliers 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. 
3. Children and young persons under 18 shall not be employed at night or in hazardous conditions. 
4. These policies and procedures shall conform to the provisions of the relevant ILO standards. In accordance with ILO standards on Child Labour the minimum age for admission to employment or work is 15 years.

05 LIVING WAGES ARE PAID

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. 
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. Wages must be paid regularly and on time. 
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.

06 WORKING HOURS ARE NOT EXCESSIVE

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. Sub-clauses 6.2 to 6.6 are based on international labour standards. 
2. Working hours, excluding overtime, shall be defined by contract, and shall not exceed 48 hours per week.* 
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. 
4. The total hours worked in any seven day period shall not exceed 60 hours, except where covered by clause 6.5 below. 
5. 6.6 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 14 day period. 
6. Working hours may exceed 60 hours in any seven 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; 
• The employer can demonstrate that exceptional circumstances apply such as unexpected production peaks, accidents or emergencies. 
  

07 NO DISCRIMINATION IS PRACTISED

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.

08 REGULAR EMPLOYMENT IS PROVIDED

1. To every extent possible work performed must be on the basis of recognised employment relationship established through national law and practice. 
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.

09 REGULAR EMPLOYMENT IS PROVIDED



1. Physical abuse of discipline, the threat of physics abuse, sexual or other harassment and verbal abase or other forms on intimidation shall not be prohibited. 
2. supplies must have both a written disciplinary procedure and a written grievance procedure that are understandable to the workers and which re operated in a fair and transparent manner

10 REGULAR EMPLOYMENT IS PROVIDED

1. Supplies must be able to show, without retaining original documents, that all workers have a legal right to work in their country of operations.

11 AGENCY WORKERS, HOME-WORKING, AND SUB-CONTRACTING

1. Suppliers must have processes that ensures agency workers have equal rights and/or rights according to the local labour law relating to agency workers.
2. Suppliers must notify Sabry Marouf of any planned home-working and obtain approval in advance of the start of work.
3. Suppliers must notify Sabry Marouf of any planned subcontracting and obtain approval in advance of the start of production.
   

12 ENVIRONMENT

1. As a minimum all suppliers will comply with the laws and regulations that apply in their country and best practice and norms across their industry.
2. Suppliers will comply with industry standards of material compliance and chemical use as per reach requirements of use of certain chemicals. However these are seen as minimum standards and suppliers are encouraged to engage in an ems programme that will drive continuous improvement and result in the reduction of the use of potentially harmful chemicals in their supply chain. Please refer to our separate chemicals and hazardous substances policy and restricted substances list
3. Suppliers must ensure their operations have no negative impact on the local environment or community where they operate, this includes issues such as water and air emissions, noise, and waste disposal. Every effort should be made to actively reduce impacts and the use of resources over time.

13 RAW MATERIALS

1. All suppliers must be able to provide details of the source, supplier, country of origin, and country of processing of all raw materials. in the case of animal origin materials the supplier should also provide details of the species of all and any animal origin products. 
2. It is the responsibility of the supplier to ensure they work with responsible suppliers of raw materials who can assure animal welfare within their supply chains, as a minimum this should include;
3. Compliance with any legislation in the country of origin concerning animal welfare
4. Humane treatment of animals during their lifetime and in transit and at time of slaughter.
5. No live skinning or plucking or other inhumane methods of obtaining materials during the lifetime of the animal are tolerated.
6. Animal based raw materials must at all times be a by-product of the food industry. 

14 LEATHER

1. Leather must not be sourced from the amazon biome where cattle ranching is known to be impacting on deforestation. 
2. Leather shall be sourced from local tanneries where possible

15 BRIBERY AND CORRUPTION



As part of our belief in doing business to the highest ethical standards we have zero tolerance towards bribery and corruption. 

1. Suppliers must not offer, pay, solicit or accept any kind of bribe which could influence business activity.
2. Suppliers must be aware that employees of sabry marouf must not accept or offer any gift, entertainment or service that could be construed as a bribe. Employees are expected to report any gifts or hospitality that is deemed disproportionate to normal business relations. In addition employees must report any bribery, corruption or facilitation payments that they may be aware of.

16 MODERN SLAVERY

He term modern slavery covers all offences covered by the UK modern slavery act 2015 which includes slavery, servitude, and forced or compulsory labour and human trafficking. Modern slavery is a crime and a violation of fundamental human rights. Suppliers to sabry marouf should be aware of the policy and confirm their understanding and acceptance of it:

1. 16.1 suppliers must ensure that they are constantly vigilant about the risks of forced, bonded and trafficked labour in their own business and in any part of their supply chain.
2. 16.2 suppliers are expected to maintain high levels of awareness and governance in situations where risks can be high such as foreign contract workers and migrant labour populations. This should include measures such as; suppliers must ensure they do not withhold identification documents, they do not have a system of recruitment fees, and they do not prevent workers from leaving employment or re-patriating at the time of their choosing. Suppliers must facilitate the unhindered freedom of movement of their workers. 
3. 16.3 suppliers should be aware that factory audits and worker interviews will look for signs of the risk of modern slavery and also that sabry marouf employees are expected to report any concerns they may have about such risks.