SKINS Complaint Policy 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?
WHAT IF THE COMPLAINT IS ANONYMOUS?
A complaint can be:
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.
• 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 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.
SKINS Complaint Policy 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-the-spot’ 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 organisation that may assist you.