SKINS Code of Conduct

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SKINS is proud to be a Foundation Stage member of the Ethical Trading Initiative (ETI), a leading alliance of companies, trade unions and NGOs that promotes respect for workers’ rights around the globe.

CODE OF CONDUCT “Whatever is my right as a man is also the right of another; and it becomes my duty to guarantee as well as to possess.” – Thomas Paine, Rights of Man SKINS has a core belief that it lives by and expects of others. It is the fundamental belief in the true spirit of competition. This belief not only extends to sport but it also extends to how we conduct ourselves in life. If we seek to compete with ourselves to do better, to be better, to treat our friends and partners better, then the collective good of that competition makes us better. SKINS has clear and unambiguous standards that it sets for itself and its partners. These standards can be called a Code of Conduct, but for SKINS these are inalienable rights expected to be implemented as a minimum by a SKINS partner for the care and protection of our valuable factory workers. EMPLOYMENT IS VOLUNTARY A SKINS partner does not use forced labour of any kind whether it be prison labour, indentured labour, bonded labour or otherwise.

EMPLOYMENT IS FOR WORKERS 16 YEARS OR OVER A factory worker is not someone who is 15 years or younger. A SKINS partner will only employ workers of 16 years or older. If the legal working age for the country is older then 16 years then this is the relevant age limit for SKINS. Workers under the age of 18 must not work with hazardous chemicals or conditions. HARASSMENT OR ABUSE Every employee shall be treated with respect and dignity. No worker shall be subject to any physical, sexual, psychological or verbal harassment or abuse. NO DISCRIMINATION AGAINST WORKERS No worker shall be subject to any discrimination in employment, hiring, salary, compensation, promotion, discipline, termination or retirement on the basis of gender, race, religion, age, pregnancy, disability, nationality, political opinion, social or ethnic origin, trade union affiliation, sexual orientation, parental status, marital status or any other status protected by the laws of the relevant country. FREEDOM OF ASSOCIATION To the extent permitted by the laws of the relevant country, workers have the right to freedom of association and collective bargaining. This includes the right to form and join trade unions and other work organisations of their own choosing without harassment, interference or retaliation. HEALTH AND SAFETY The work environment will be a safe, hygienic and healthy place to work. A SKINS partner will take all necessary steps to prevent accidents and injury to workers in the workplace. A SKINS partner must have systems in place to detect, avoid and respond to potential risks and injury to workers. COMPENSATION PAID ON TIME A worker will be paid at least the minimum wage and mandated benefits including holiday and leave allowance and severance

pay required by the laws of the relevant country. There will be no deductions for disciplinary matters. WORKING HOURS WILL NOT BE EXECESSIVE A worker will not work in excess of 60 hours per week, or the regular and overtime hours allowed by the laws of the manufacturing country, whichever is less. Overtime hours will be consensual and compensated at a premium rate. Workers will have at least 24 hours rest in any 7 day period. EMPLOYMENT IS REGULAR AND RECOGNISED Workers must perform work for the SKINS partner as part of a recognised employment relationship by the relevant country. There will be no arrangements of workers providing manufacturing services in the home. ENVIRONMENTAL IMPACTS ARE MINIMISED A SKINS partner must make progressive improvements in environmental performance of their operations by integrating principles of sustainability into business decisions, responsible use of natural recourses and adoption of reasonable measures to mitigate negative operational impacts on the environment. A SKINS partner must also protect human health and the environment by meeting applicable regulatory requirements of the relevant country including air emissions, solid/hazardous waste and water discharge. IMPORTANT: THIS CODE MUST BE FULLY IMPLEMENTED As a condition of doing business with SKINS, a SKINS partner must implement and integrate ALL of the standards set out above for the benefit of the valuable workers. The SKINS partner will allow SKINS and its agents and partners access to ALL facilities under its control or the control of related or associated parties for the purposes of inspection and verification of the implementation of the standards set out above. A SKINS partner shall post this Code, in the language(s) of its employees, throughout their workspaces and train employees on their rights and obligations as defined by this Code.


COMPLAINT PROCESS FOR BREACHES OF THE SKINS CODE OF CONDUCT SKINS is committed to ensuring that all parties in its supply chain comply with the SKINS Code of Conduct. Where there is a breach of the SKINS Code of Conduct, this document sets out how complaints can be made, how a complaint will be dealt with and the pathways to resolution. WHAT IS A COMPLAINT? A complaint can be: Made verbally to a SKINS representative; and/or In writing to a SKINS representative. A SKINS representative can be an employee of the SKINS Group or a member of the SKINS QC staff at the factory or 3rd party site. If email is also possible then complaints can be made to: complaint2015@skins.net WHO CAN COMPLAIN? Any individual or organization affected by a breach of the SKINS Code of Conduct can make a complaint. WHAT INFORMATION SHOULD BE IN A COMPLAINT? Any complaint needs to be factual and, to the extent practicable, evidenced based. This means a complaint needs as much information as possible to identify the breach of the SKINS Code of Conduct, the parties involved in the breach and identification of the seriousness of the issue. AS A GUIDE, COMPLAINTS SHOULD TRY TO SET OUT: Name of the SKINS supplier/contractor Address of the work site The alleged breach – what has happened and how does it

relate to the Code? The scale and seriousness of the problem Your name and contact details (if you want to make an anonymous complaint then this is dealt with below) If you want to claim confidentiality (this is where you want to idientify yourself to SKINS for investigation of the breach but do not want your identity disclosed to the supplier/contractor or 3rd party in the resolution process) If the complaint has been made before Any local complexities like ethnic, cultural or political issues that are relevant to the alleged breach What is the preferred solution in your eyes

DO YOU WANT TO CLAIM CONFIDENTIALITY? As a general rule, SKINS would encourage you not to make a claim of confidentiality so that you can be an active participant in the resolution process. However, if you wishe to keep your identity confidential, SKINS will respect this claim when it investigates the matter. WHAT IF THE COMPLAINT IS ANONYMOUS? If a complaint is made anonymously, SKINS will still investigate the complaint. The effectiveness of the investigation maybe reduced due to a lack of information that cannot be verified with the complainant. Ideally, SKINS would prefer the name and details of the complainant to be provided at the time of making the complaint so that it can ensure all matters are investigated efficiently. WHAT WILL HAPPEN WHEN A COMPLAINT IS MADE? When a complaint is received by SKINS, it will be provided directly to the Head of Sourcing and General Counsel. Both the Head of Sourcing and General Counsel will investigate the matter and will liaise with the local supplier/contractor, the complainant (if the identity is known) and relevant local organisations and authorities. HOW QUICKLY WILL THE COMPLAINT BE HANDLED? Each complaint will reach the Head of Sourcing and General Counsel within 48 hours of the complaint being received. The Head of Sourcing and General Counsel will commence investigation of the complaint within 48 hours of being notified of the issue. SKINS will seek to resolve all issues set out in the complaint with 3 weeks of commencing the investigation. During the investigation, SKINS will liaise with the complainant (if known).

HOW WILL SKINS RESOLVE THE ISSUES SET OUT IN THE COMPLAINT? Every complaint will be different and involve differing levels of seriousness. SKINS will endeavour to resolve all breaches of the SKINS Code of Conduct in a manner that is positive for all parties. To the extent practicable, the resolution process should not be seen as SKINS being the entity to deliver punishments. Rather, SKINS in the resolution process aims to facilitate a positive outcome by mediating and in some cases directing a supplier/contractor as to tasks and corrections that should be undertaken. It should be clear that the answer to every complaint will be different. What will remain constant in the process is the determination to achieve a resolution and the willingness of all parties to address the issues set out in the complaint in a professional and positive manner. If the seriousness of the alleged breach is such that the matter must be referred to the local authorities, SKINS will do so and remain, as appropriate, part of the process. WILL REMEDIAL ACTIONS BE CHECKED? All remedial actions will be checked by SKINS QC staff and representatives on a periodic basis and with ad hoc ‘on-thespot’ checks. On-the-spot checks will not be made with notice to the supplier/contractor or 3rd party, the subject of the complaint. WHAT HAPPENS IF THERE IS NO AGREEMENT AS TO THE REMEDIAL ACTIONS TO BE TAKEN? If an agreement cannot be reached to remediate the issue set out in the complaint within 3 weeks of the commencement of the investigation, SKINS reserves the right to take further action and make such decisions as it deems appropriate. Any decision taken by SKINS will be notified in writing to all parties. YOUR RIGHTS This complaint handling policy does not interfere or restrict your rights to make a complaint about the same or similar matters to a public authority, law enforcement or other organization that may assist you.


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