LOWA SPORTSCHUHE GMBH. LOWA Code of Conduct
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1 LOWA SPORTSCHUHE GMBH LOWA Code of Conduct Version 3_
2 Code of Conduct Version 3_ LOWA Sportschuhe GmbH Table of Contents I. LOWA STANDARDS... 2 (1) ENVIRONMENTAL PROTECTION... 2 (2) CHILD LABOUR... 2 (3) WORKING HOURS... 2 (4) WAGES, OVERTIME & BENEFITS... 3 (5) FORCED LABOUR & DISCIPLINARY MEASURES... 3 (6) WORKPLACE HEALTH & SAFETY... 3 (7) DISCRIMINATION... 4 (8) FREEDOM OF ASSOCIATION & COLLECTIVE BARGAINING... 4 (9) BRIBERY, CORRUPTION & GIFTS... 4 (10) COMPLIANCE AND AUDITS... 4 (11) SANCTIONS FOR NON-COMPLIANCE... 5 (12) CODE COMMUNICATION... 5 (13) SUPPLIER RELATIONSHIPS... 5 (14) ADMINISTRATIVE SYSTEM... 5 (15) REPORTING AND GRIEVANCE PROCEDURES... 5 Declaration of commitment to this Code of Conduct... 6 between... 6 Page 1
3 I. LOWA Standards LOWA s Code of Conduct is based on international standards. Referenced in particular is the UN Declaration of Human Rights, as well as the principles of the UN Global Compact, the ILO Convention, and the OECD standards for multinational corporations. Fundamentally all general legal requirements (e.g., environmental regulations) are to be adhered to and are guided by the strictest standards. All suppliers and business partners of LOWA Sportschuhe GmbH, including all of their employees 1, are subject to these Standards. LOWA approves only those as business partners who agree to uphold the environmental and social standards outlined herein. This Code of Conduct does not make any claim to address each and every situation that may arise, but is to be understood as an expression of minimum requirements. (1) Environmental Protection Every business partner must comply with established environmental laws and regulations. In addition, it is vital that all engage in responsible use of natural resources and avoid environmental pollution. The disposal of and other obligations involved with the use of hazardous materials (e.g. chemicals) must adhere to all minimum legal requirements. (2) Child Labour Child labour is prohibited by the provisions of the United Nations and the ILO. Any and all forms of child labour are not permitted. All workers must meet the minimum age of school age or the age of 15 years (in some areas, the minimum permitted working age may be older). Young persons may never be used on night shifts nor be asked to work more than 8 hours a day. The rights of children are to be protected at all times. ILO conventions 138, 142, 182 and recommendation shall apply. (3) Working Hours Working hours are to follow valid legal provisions or standards (the stricter thereof shall be applied). Normal working time may not be more than 42 hours a week and a maximum of 8 hours of overtime per week. Overtime hours are to be voluntary and may not occur regularly. Employees have the right to at least one day off per week. ILO conventions 1, 14 3 shall apply. 1 For the sake of simplicity the additional use of the feminine form will not be used; however, it is to be understood and advised that the exclusive use of he masculine form is to be explicitly understood here as gender neutral. 2 ILO conventions herein refer to youth night shifts (79), minimum age ( ), human resource development (142) and the worst forms of child labour (182). (See: 3 ILO conventions herein refer to business work hours (1) and the weekly mandated day off (14). Page 2
4 (4) Wages, Overtime & Benefits Employees shall be paid the minimum legal wage or a minimum wage that is consistent with industry standards (the highest thereof shall apply). Business partners should attempt to pay wages that cover the cost of living with a portion still available for discretionary spending if the legally mandated minimum wage is not enough. Workers shall be paid regularly and promptly. Overtime hours are to include a bonus based on legal provisions or industry standards (the higher thereof shall apply). In addition each employee has the right to all benefits required by law (e.g. sick time, paid vacation, parenthood allowance), as well as the issuance of regular salary statements (with easily comprehensible information with a breakdown of renumeration such as deductions and bonuses). Wage deductions as disciplinary measures are prohibited. ILO conventions 26, 102, shall apply. (5) Forced Labour & Disciplinary Measures Any employees shall engage in work on a voluntary basis. Any form of forced, indentured, bonded or prison labour is strictly forbidden in the production of LOWA products and is in no way part of company philosophy. Employees shall be treated with respect and dignity. The use of physical, psychological, sexual or verbal harassment or any other form of intimidation is prohibited. Employees who report non-compliance with the Code of Conduct and/or with valid international standards may not be disciplined in any form or manner. ILO conventions 29, shall apply. (6) Workplace Health & Safety Protective measures at the worksite are to be regularly monitored and ensured. The worksite may also never endanger the health of individual employees. Potential risks at the workplace are to be avoided (including via fire protection systems, emergency exits and routes, and first aid measures), and employees must be educated by the employer about any health and safety risks (e.g. in special training). All hazardous materials shall be properly labeled and safely stored. A Material Safety Data Sheet must be available at all times at the worksite for employees free access. The Data Sheet must also include information about emergency procedures. Workers must also have access to sanitary toilets and shall have access to sufficient water at all times. If dormitories are required, they must be clean and secure. ILO convention 155 and recommendation shall apply. 4 ILO conventions herein refer to minimum wage (26+131) and social security (102). 5 ILO conventions herein refer to forced labour (29+105). 6 ILO conventions herein refer to occupational safety (155) and an ILO recommendation for health protection (164). Page 3
5 (7) Discrimination Discrimination of any kind will not be tolerated at LOWA. Any differentiation in treatment, hiring, termination or advancement on the basis of gender, age, religion, political opinion, nationality, sexual orientation, social origin or any other personal differences is strictly prohibited. ILO conventions 100, 111, 143, 158, shall apply. (8) Freedom of Association & Collective Bargaining Employees have the freedom to establish associations or organisations that serve and protect workers. If the freedom of association is limited due to local regulations, employees will be allowed to elect a colleague to represent them and their interests. At minimum, alternative forms of assembly to further joint negotiations shall be supported by suppliers. ILO conventions 87, 98, 135, 154 and recommendation shall apply. (9) Bribery, Corruption & Gifts Accepting gifts and other personal favours is not permitted, unless of a nominal value or written consent is obtained from superiors. All favours over and above those mentioned are prohibited and are to be declined. The offer of any such favours is to be immediately reported to LOWA Sportschuhe GmbH. (10) Compliance and Audits LOWA expects that all business partners follow established legal regulations and standards. Therefore, LOWA retains the right to conduct random audits and/or inspections of suppliers/product at any time. Audits of suppliers may occur independently based on an audit plan as agreed upon with LOWA and, at minimum, occur biannually. LOWA will be allowed access by the business partner to production facilities for inspections at any time. In addition, the transfer of all relevant accounting records is obligatory. A supplier that was inspected has the right to a discussion of the results of the process. Any offences are to be recorded in a Corrective Action Plan and are to be remedied within a reasonable timeframe. The supplier will be assisted by LOWA in this action. 7 ILO conventions herein refer to renumeration (100), discrimination (111), migrant labourers, (143), termination of a business relationship (158) and the vocational rehabilitation and employment of the disabled (159). 8 ILO conventions herein refer to freedom of association (87), migrant labourers (98+143), worker representives (135) and collective bargaining (154). Page 4
6 (11) Sanctions for Non-compliance LOWA has the right to end a business relationship in the case of serious offences (e.g. human rights offences) that are not rectified according to the Corrective Action Plan. If a supplier later remedies an offence/offences, the opportunity to again engage in a working relationship may occur. (12) Code Communication The Code of Conduct shall be communicated to all employees (with translation of the code into the native language of each country). The code s contents shall be communicated in the form of notices and, as appropriate, in trainings. An employee has the right to receive a written copy of the code. (13) Supplier Relationships LOWA Sportschuhe GmbH strives to produce its footwear in Europe (currently, 98%) and thus to foster direct and long-term relationships with suppliers. (14) Administrative System The Code of Conduct will be introduced, implemented and executed by the business partners using an administrative system (e.g. for clarification of responsibilities and documentation). Within a reasonable period and by a deadline set by LOWA, suppliers will provide substantiation regarding the successful establishment of the administrative system, assuming one does not currently exist. LOWA will gladly assist business partners in this process. Business partners who contract with other parties (i.e. LOWA sub-contractors) shall ensure and be responsible for ascertaining compliance by said suppliers. (15) Reporting and Grievance Procedures To obtain further information regarding offences of the general legal provisions and/or in general about the Code of Conduct, please contact LOWA at any time: No disciplinary measures may be taken against employees who file non-compliance grievances. Page 5
7 Declaration of commitment to this Code of Conduct between LOWA Sportschuhe GmbH Hauptstraße 19 D Jetzendorf Signature, Managing Director (LOWA) and Business Name: Business Address: Place, Date Signature, Managing Director Page 6
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