Mothercare Group Responsible Sourcing Code of Practice & Implementation Policy The Responsible Sourcing Code of Practice: The Mothercare group Responsible Sourcing Code sets out the standards we expect in all factories used to manufacture Mothercare/ELC branded product. The Code is based upon the Ethical Trading Initiative Base Code, which stems from international labour and human rights law. At Mothercare we believe that everyone should be treated with respect and work in a safe environment. Our suppliers must share our values and be committed to working towards full compliance with our Code which is set out below: 1. EMPLOYMENT IS FREELY CHOSEN 1.1 There is no forced, bonded or involuntary prison labour. 1.2 Workers are not required to lodge "deposits" or their identity papers with their employer and are free to leave their employer after reasonable notice. 2. FREEDOM OF ASSOCIATION AND THE RIGHT TO COLLECTIVE BARGAINING ARE RESPECTED 2.1 Workers, without distinction, have the right to join or form trade unions of their own choosing and to bargain collectively. 2.2 The employer adopts an open attitude towards the activities of trade unions and their organisational activities. 2.3 Workers representatives are not discriminated against and have access to carry out their representative functions in the workplace. 2.4 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. 3. WORKING CONDITIONS ARE SAFE AND HYGIENIC 3.1 A safe and hygienic working environment shall be provided, bearing in mind the prevailing knowledge of the industry and of any specific hazards. 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. 3.2 Workers shall receive regular and recorded health and safety training, and such training shall be repeated for new or reassigned workers. 3.3 Access to clean toilet facilities and to potable water, and, if appropriate, sanitary facilities for food storage shall be provided. 3.4 Accommodation, where provided, shall be clean, safe, and meet the basic needs of the workers. 3.5 The company observing the code shall assign responsibility for health and
safety to a senior management representative. 4. CHILD LABOUR SHALL NOT BE USED 4.1 There shall be no new recruitment of child labour. 4.2 Companies 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. 4.3 Children and young persons under 18 shall not be employed at night or in hazardous conditions. 4.4 These policies and procedures shall conform to the provisions of the relevant ILO standards. 5. LIVING WAGES ARE PAID 5.1 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. 5.2 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. 5.3 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. 6. WORKING HOURS ARE NOT EXCESSIVE 6.1 Working hours comply with national laws and benchmark industry standards, whichever affords greater protection. 6.2 In any event, workers shall not on a regular basis be required to work in excess of 48 hours per week and shall be provided with at least one day off for every 7 day period on average. Overtime shall be voluntary, shall not exceed 12 hours per week, shall not be demanded on a regular basis and shall always be compensated at a premium rate. 7. NO DISCRIMINATION IS PRACTISED 7.1 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. 8. REGULAR EMPLOYMENT IS PROVIDED 8.1 To every extent possible work performed must be on the basis of recognised employment relationship established through national law and practice. 8.2 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. 9. NO HARSH OR INHUMANE TREATMENT IS ALLOWED 9.1 Physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation shall be prohibited. 10. ENVIRONMENTAL IMPACT IS KEPT TO A MINIMUM 10.1 Every reasonable effort must be made to reduce the environmental impact of business activities. In addition to complying with local laws, steps should be taken to optimise the use of energy and natural resources and dispose of waste in a way that is not detrimental to the local community. Branded and Licensed Products: Any branded or licensed products, including Mini Club, Disney, Mattel and any other branded goods which are supplied Direct to Retail for Mothercare or ELC, are subject to other Codes of Practice and ethical trade requirements. Any such suppliers must engage with Mothercare and the Responsible Sourcing team to ensure that they and their sites comply with the requirements of other brands. The Responsible Sourcing Implementation Policy: P Both the Responsible Sourcing Implementation Policy and the Code of Practice apply to all Mothercare Group suppliers. Additional requirements may be required for suppliers of Licensed product or Mini Club. We expect all of our suppliers to continuously improve standards in the supply chain and work towards full compliance with our Responsible Sourcing Code and any associated policies. The board of directors of Mothercare Group plc will only support trading with suppliers who can demonstrate that they are working in a way that is consistent with the requirements defined in our Implementation Policy: Suppliers are expected to declare all factories used for the manufacture of Mothercare/ELC Branded product. We accept that in certain circumstances the use of sub-suppliers, subcontractors and homeworkers are a necessary part of our supply chain. We expect all subcontracted and sub-supplier work to be carried out in an ethical manner and for any worker operating within our supply chain to be treated and rewarded appropriately. Suppliers should take note of the requirements laid out in the Group Homeworking Policy and the Group Sub-Contracting Policy. A copy of our Code of Practice must be displayed (in the local language) at each factory used for the manufacture of Mothercare/ELC Branded product. Each factory must undertake regular third party audits and is expected to make continuous improvement and remediate non-compliances identified in an audit within reasonable time frames. Suppliers will bear the cost of initial third party audits and any follow up audits deemed necessary. Suppliers and each factory used for the manufacture of Mothercare/ELC
Branded product are expected to become a member of SEDEX. Suppliers will ensure that all audit related information is uploaded onto the SEDEX database and use SEDEX as a tool to demonstrate improvements/compliance to Mothercare/ELC. We expect transparency from all of our suppliers and sites. Suppliers must ensure that all Mothercare Group employees and / or third party audit companies are given unrestricted access to premises, workers and documentation. Double books, fake or inaccurate records will not be accepted as proof of compliance on issues such as working hours and wages. Issues can be complex and we realise that it can take time to bring about genuine improvements. Our approach to compliance is based on continuous improvement. However there are certain issues deemed No Tolerance issues which we will not accept in our supply base. If a No Tolerance issue is identified in a factory, no new orders will be placed until the issue has been remediated. Any existing orders will be put on hold until an improvement plan is agreed. No Tolerance issues are defined as: Child Labour* Forced/Bonded or Illegally Trafficked labour Non-payment of wages Unsafe premises that pose a direct risk to life Extreme working hours Pollution of local water or air courses by hazardous waste * Suppliers should take note of the Group Child Labour Policy. Suppliers must notify the Responsible Sourcing Team immediately if a No Tolerance issue is identified. Mothercare maintains the right to visit any factory used for the production of Mothercare/ELC Branded products, at any time. These visits will be undertaken by a member of Mothercare staff or a nominated 3 rd party. If access is denied or attempts are made to deceive these parties, orders will be put on hold and no further payments will be made to the supplier. The Mothercare Responsible Sourcing Team or any nominated 3 rd party will visit factories to provide advice and guidance on dealing with non-compliances, carry out validation audits or to engage in capacity building activities. The Responsible Sourcing Team may engage key strategic suppliers in project work aimed at understanding the root causes of non-compliances and identifying and implementing improvement strategies. The Responsible Sourcing Team will provide advice and guidance to suppliers through printed materials, supplier workshops and conferences Bribery of any form is against Mothercare Policy and is illegal within the provisions of the Bribery Act 2010. Any employee or third party working on behalf of Mothercare who is found to have accepted a bribe will be dismissed from employment. If any supplier or site is found to have offered or accepted a bribe (or is in breach of the terms of the Bribery Act 2010), no new orders will be placed until transparency has been achieved and written commitments not to engage in such activity in the future. Any existing orders will be put on hold until such actions are taken. Any repeat of the same or other bribery-like practices will
result in a complete review of the supplier s position to Mothercare. The supplier is expected to understand and apply the provisions and principles of the UK Bribery Act in all its behaviours and dealings. Mothercare will maintain membership of the Ethical Trading Initiative and where possible engage our supply base in ETI activities. Supplier Responsible Sourcing Commitment: We, as a supplier of product to Mothercare, are committed to sincerely abiding by the terms and conditions outlined in Responsible Sourcing Implementation Policy, based on Mothercare s Responsible Sourcing Code of Practice. Date: Signature: Name: Company Name: Company stamp: Designation: