DRAFT FOR DISCUSSION ONLY. Suppliers Code of Conduct

Transcription

1 Suppliers Code of Conduct

2 Preface Geox owes its development to the constant attention paid to the technological evolution of products and services, which represents the basis for achieving the highest quality standards. Innovation must be the result of a process open to all the stakeholders, achieved by exploiting the best ideas and applied through study and experimentation. Every innovation achieved directly or indirectly by Geox tends towards increasingly greater sustainability, as an essential element of corporate continuity. The innovation must be obtained exploiting the most advanced technology and seeking solutions that guarantee the excellence of Geox products and services, at the same time improving its own social and environmental characteristics. Geox pays maximum attention to ensure that its own activities feature constant Responsible Innovation, so that the solutions adopted today do not represent problems in the future. The content of this Code of Conduct can be updated by Geox according to the need of new requirements. Any update will be communicated to the suppliers and published at

3 Sommario Preface... 2 The Human Capital Humans Resources procedures Child labour and young workers Forced labour, coercition and harassement Discrimination Freedom of association Wages and working time Disciplinary practice Health and safety management system Emergencies and accidents Physical working environment... 8 Environmental Protection Local environmental impact Chemicals and hazardous substances Waste management Water management Air emissions Supply chain transparency and regulatory compliance Production and subcontractors Corruption practices and regulatory compliance Audit... 12

4 The Human Capital Geox Code of Ethics - Art. 1 [ ] 3) In their interrelations, the Addressees must base their own conduct on reciprocal cooperation and collaboration. The Addressees must act together to avoid any discriminating behaviour based on age, health, sex, religion, race, ethnic group, sexual preference, and political and cultural opinions, and adopt behaviour based on reciprocal respect and courtesy. 4. Geox bases its own success on the following values that must be shared by every Addressee of the Code: a. Enthusiasm and dynamism b. Believing in one s own ideas and innovative projects c. Conviction d. Honesty and integrity e. Sober behaviour f. Responsibility [ ] Geox Code of Ethics - Art. 4 Recognition of the value and dignity of the Person is a fundamental requisite of healthy company management. Respect and appreciation of the Person involves the protection of his/her physical and moral integrity and continual growth in technical and professional skills.it is forbidden to resort to any practice which involves humiliation or debasement of a person as such or of the role he/she covers, including bullying, exploitation or threats.every company practice must employ people in work contexts suitable to human dignity and which can adequately guarantee safety, with times and methods that do not compromise the individuals private lives or their capacity to satisfy their fundamental needs.it is necessary to safeguard workers who are in situations in which their professional activities are limited (pregnancy, maternity, inexperience, accident, disability, etc.) through the adoption of measures that can maintain physical and moral integrity, also in compliance with the laws in force.every worker has the right to a fair and regular salary, and adequate remuneration for any overtime worked. Every worker is guaranteed the freedom to belong to trade union associations.geox condemns the exploitation of child labour or of those detained against their will. The use of underage personnel is allowed only within the sphere of the correct application of the laws in force and according to the provisions of the UN Convention on the Rights of the Child. 1. Humans Resources procedures 1.1. The Geox Code of Conduct should be prominently posted and accessible to all workers both in English and in the languages known by the workers Relevant national or regional labor laws should be posted in the local language and easily accessible by the workers. Where existent, the posted laws should cover such areas as: Minimum wage, overtime rates, work hours, leave, and limits on overtime, etc All workers are hired with a written employment contract in the local language Geox suppliers shall educate illiterate workers as to the personnel policies, employment contract and wage calculation. 2. Child labour and young workers 2.1. Geox suppliers shall employ workers only according to local legal requirements for age of employment and according to ILO convention n. 138.

5 2.2. All young workers from legal age to 18 years old are prevented from working in hazardous activities, working overtime or during night shifts. All the other local legal limitations on employment of workers below 18 years old must be applied All possible young workers are easily identified through a different uniform color, or a different badge, or specific employment register, or any other suitable measure. 3. Forced labour, coercition and harassement 3.1. Geox suppliers shall not use any forced, illegal or involuntary labour Geox suppliers shall treat workers with dignity and respect and shall ban any form of corporal punishment and any threat or practice of physical violence or other abuse All Geox suppliers should have clear policies on the unacceptability of harassment and abuse on the part of supervisory staff as well as procedures for workers to report such incidents No restrictions shall be applied which interfere with the worker s right to leave the factory compound or the housing facility during their free time No security guards keep the workforce under pressure Employees are free to quit their jobs and to leave the company within the local legal framework Original documents of employees, such as ID - cards, passports or birth certificates must not be permanently held by the employer Monetary deposits are not required from the employees No prisoners are used for working 4. Discrimination 4.1. Geox suppliers shall not engage in or support any form of discrimination in terms of gender, sexual preferences, race, ethnic origin, religious beliefs, political affiliation in hiring workers, remuneration, access to training, access to factory facilities, working conditions or any other matter Migrant workers shall have exactly the same entitlement as local workers. Any commission or other fees in connection with the employment of migrant workers must be covered by the employer Pregnancy test shall not be a condition of employment. Workers shall not be forced or pressured to use contraception. Workers who take maternity leave of a duration determined

6 by local and national laws, shall not face dismissal or threat of dismissal, loss of seniority or deduction of wages, and shall be able to return to their former employment. 5. Freedom of association 5.1. Geox suppliers shall grant workers the right to form or join Trade Unions where it is permitted by local law and the right to sign Collective Bargain Agreements All workers are free to choose their Trade Union Trade union has the right to perform their work in the working time as stipulated by local law and are not subjected to any form of discrimination All workers have the right to express their opinion or suggestion by letter box, , or other channel defined by the factory. 6. Wages and working time 6.1. All workers (regular workers, probationary workers, etc) are provided with at least the minimum wage regulated by local Law or any existing collective bargaining agreement (where this affords a better minimum wage) Geox suppliers properly calculate workers wages and overtime and pay them in a timely manner according to local law and any existing collective bargaining agreement, providing for adequate audit trails. A clear wage slip is provided to all the employees Legally mandated income-security benefits are provided (workers comp, medical coverage, social security, retirement funds, etc.) and are paid to appropriate agencies in a timely manner, according to local laws. All wage deductions for voluntary savings programs, loan payments, etc., are voluntary and are deposited in full into legally defined accounts. No unfair deductions are permitted Workers shall be granted and properly compensated for any types of paid leave to which they are legally entitled, including annual leave, maternity/parental leave and sick leave Geox suppliers shall ensure that work hours including overtime do not exceed the legal daily/weekly/quarterly/monthly/annual limit permitted by the local law Workers are provided at least with 1 day off in each 7 days period Overtime shall be voluntary, and shall always be compensated at a premium rate. 7. Disciplinary practice 7.1. Geox suppliers shall not use any kind of physical violence as disciplinary practice.

7 7.2. A disciplinary procedure is documented and available to all workers in local language. The procedure is compliant to all applicable local laws or collective bargaining where this affords greater protection to workers All disciplinary actions are adopted according to the procedure. 8. Health and safety management system 8.1. Geox suppliers should have a documented procedure for identifying workplace hazards and assessing their risks. Specific emergency plans and response procedures must be defined according to the risk assessment. Geox suppliers shall assess periodically the environmental and social impact of their operations on the local community A senior management representative on Health and Safety is appointed to ensure safe and healthy workplace environment for all personnel All personnel is kept aware about occupational health and safety through regular training Geox suppliers shall provide their workers with protective equipment as required by applicable law and industry standards at no cost for the worker. Every worker is required to use the personal protective equipment during the working hours Where a specific risk for eye accidents exists, eye wash stations are adequately located in the workplace Work clothes are provided to workers as per applicable local law Employees working with electricity or other potentially dangerous infrastructure, have adequate qualification. 9. Emergencies and accidents 9.1. Emergency lights and alarms are functioning and emergency path and exits are kept free and marked adequately in local language Geox suppliers shall provide for fire fighting equipment located accordingly to fire risks. A regular check for fire extinguishers is in place and they are well maintained, easily accessible and well distributed Geox suppliers shall conduct a regular fire drill as per applicable local law with record keeping and includes all workers Emergency telephone numbers list is easily visible to all workers Appropriate first aid equipment must be available and, where legally required, a qualified doctor and/or nurse should be available during working hours.

8 9.6. Geox suppliers shall appoint a first-aid team and provide for regular training An accident/incident report must be kept up to date and reviewed for any possible corrective actions by Senior Management. 10. Physical working environment Geox suppliers shall ensure that the building and premises, where the production activity is carried out, are suitable to host productive activities, comply with applicable local law and regulations for its use and comply with the legal provisions on construction regulations A specific periodical building structural inspection is carried out by every Geox supplier Geox suppliers ensure the work environment is adequately ventilated, without dust, with adequate lighting, with a comfortable temperature, reasonable access to clean drinking water (periodically checked) Geox suppliers must conduct a periodic working environment measurement according to point 10.3 (temperature, light, noise, ventilation, dust, wind speed, etc) Geox suppliers shall ensure an adequate number of toilets compliant to applicable regulations. The doors can be locked and there are different restrooms for male and female which are kept clean Wiring, circuit box and electrical devices are properly marked and kept in good conditions Chemical containers must be properly labeled and safely stored. A material safety data sheet must be available in the local language and the instructions in it must be followed. Chemicals are used in separate rooms and all possible arrangement are taken to avoid any leakage of chemicals on the production floor or on the soil. Any flammable chemical is stored separately from the production floor Every machine is provided with a maintenance record, a valid inspection certificate (where applicable) and safety instructions in the local language. Protective devices and preventive measures are taken for dangerous machines and any out-of-order machines are properly labeled to avoid usage If a Geox supplier runs a Dormitory and /or Canteen facilities, these must comply with local law regulations and community requirements. All previous requirements (from 10.1 to 10.9) must apply also to Dormitory and / or Canteen

9 Environmental Protection Geox Code of Ethics - Art. 5 No activity or business practice must directly or indirectly involve the irreversible alteration of local natural ecosystems. In every activity, it is necessary to seek operational solutions that limit as much as possible the pollution of the air, water or soil, the accumulation of substances extracted from the subsoil or created by industrial production processes, and the waste of natural resources (water, plants, animals, minerals, etc.) and energy. The Addressees are called upon to scrupulously respect the applicable provisions regarding the safeguarding of the environment and to adopt - when possible - more stringent criteria than the provisions and, when opportune, to follow international guidelines. 1. Local environmental impact 1.1. Suppliers shall comply with all local applicable laws and regulations regarding the protection and preservation of the environment and local community Facilities should be built or converted so as to ensure their harmonious integration into the local context, whether natural or man-made, and in accordance with local laws regulations. 2. Chemicals and hazardous substances 2.1. Chemicals used must be in compliance with law and no banned chemicals are stored in the workplace Chemicals tanks are protected with barriers against accidental damage and the tanks are kept in good condition (with no signs of leaking, excessive damage, etc.) Any chemical fill points have secondary containment All Geox suppliers shall limit chemical presence in the finished goods within acceptance levels defined in the Geox Chemical Test Methods document. 3. Waste management 3.1. Any waste and in particular hazardous waste must be handled in a responsible manner and in accordance with relevant laws and regulations, whichever are stricter Geox suppliers must have the relevant environmental permits and licenses for their operations. Such permits shall be aimed at preventing soil, water and air pollution and shall be accompanied by relevant implementation procedures Geox suppliers must document a complete hazardous waste determination for all potential hazardous waste streams Employees managing hazardous waste: a) understand the hazards associated with the hazardous waste, b) work in a manner that protects themselves, others and the environment from the associated hazards

10 3.5. Every hazardous waste storage area: a) is secured b) is protected and covered c) has secondary containment d) is inspected at least weekly Geox suppliers shall provide proper documentation showing the final destination of hazardous waste and arrange appropriate disposal, recycling or treatment of hazardous waste. 4. Water management 4.1. All outgoing waste water from wet processes must be treated, before it is discharged, in accordance with local laws. Only appropriate chemicals and waste are added to waste water streams Geox suppliers shall put in place a monitoring of any waste water discharges as required for legal purposes If an on-site water treatment plant is in place, rainwater is discharged to a location other than the treatment plant or is added at a time during the process that does not negatively interfere with the treatment process If an on-site water treatment plant is in place, the personnel understand the processes, equipment and testing required to operate the on-site treatment plant correctly 5. Air emissions 5.1. All emissions must be managed in a proper and transparent manner in accordance with the relevant local laws and regulations, whichever are stricter Geox suppliers provides for a complete written inventory of air emission sources that identifies the source, type and amount of pollutants and that is accurate and reliable Air emission sources are equipped with pollution control devices that remove or filter the contaminants prior to release when needed.

11 Supply chain transparency and regulatory compliance Geox Code of Ethics - ART. 3 Compliance Relations with the Public Administration, public officials or subjects appointed to perform a public service must adhere to the strictest compliance with the provisions of law and of applicable regulations. The assumption of commitments and the management or relations with the above-mentioned subjects are reserved exclusively to the specifically appointed company departments and the authorised personnel, in respect of internal procedures that guarantee correct, honest, loyal and transparent behaviour. Within the sphere of relations with third parties, whether public or private, the Addressees must abstain from offering, even indirectly, money or other benefits to the subjects involved, their family members or persons connected to them in any way, and they must not seek or establish relations with the aim of directly or indirectly influencing choices and activities. The drafting of the financial statement and any other type of financial document shall respect the laws and regulations in force, adopting the most up to date practices and accounting standards, and representing the principle of transparency in relations with the stakeholders, faithfully presenting management events with clarity, truthfulness and accuracy. Art. 6 Supply relations The choice of suppliers must be based on principles of objectivity, competence and economy, as well as those of transparency, correctness and excellence in respect of the highest environmental and social standards. Every supply relationship is limited by the labour laws in force in one s own country and the application of the principles stated in this Code on the part of all the subjects of the supply chain. In business relations with third parties it is forbidden to offer or accept benefits (direct or indirect), gifts, or acts of courtesy or hospitality, unless they are of a nature and value that cannot influence the objectivity of judgement and cannot be interpreted as aimed at obtaining favourable treatment. 1. Production and subcontractors 1.1. Geox suppliers must communicate accurately the production forecast and any possible overproduction issue related to Geox products. Sales of Geox products are allowed only to Geox group companies In case of overproduction, Geox suppliers are expected to destroy the quantity of Geox products exceeding the purchase order, unless different instructions are issued by from Geox If requested to destroy, the Supplier shall destroy all overproduced products and be certified by an independent third party approved in advance by Geox Geox requires all its supply chain suppliers to respect this Code of Conduct and to be transparent in the information they provide on their operations Geox suppliers shall not use sub-contractors for any part of the manufacturing process of Geox products without Geox prior written consent In case of approved sub-contracting, Geox suppliers shall ensure that sub-contractors abide by this Code of Conduct and sign a copy of the Code of Conduct for acceptance In any case a sub-contracting would be necessary, the Geox suppliers must immediately notify Geox about it. 2. Corruption practices and regulatory compliance 2.1. All Geox suppliers must be in possession of a proper business license and maintain accurate financial accounting.

12 2.2. Geox suppliers shall enforce a specific anti-bribery policy according to the Geox Code of Ethics provisions. 3. Audit 3.1. The Supplier shall allow any representative of Geox and/or any independent auditor appointed by Geox (the auditor ) to unlimited access of its own premises, factories, offices, plants, equipment, documents, accounting books, records, or of any of its Affiliates or Subcontractors, without need of any prior notice, in order to check the Products, the compliance of the Supplier with all the provisions of Agreement, including the Code of Ethics, Code of Conduct and the Product Requirements, and the possession by Supplier of the Accreditation Requirements The Supplier shall provide any necessary assistance in order for the auditor to carry out its inspection The costs of the inspection shall be entirely born by Geox in case of full compliance by the Supplier, in case of non-compliance the costs shall be entirely born by the Supplier The supplier shall maintain all the relevant documentation for auditing purposes.