ETHICAL SOURCING POLICY - Updated January 2014
The following document is to be read and adhered to by senior management at Gray-Nicolls Sports, who are involved in purchasing as well as all Gray-Nicolls Sports suppliers.
Gray-Nicolls Sports aims to provide its customers with high quality and high performance sporting equipment which are fair value for money; in today’s global market, this means sourcing products from both national and international locations.
Society’s concern over the welfare of workers and their working environment has seen companies implement social policies for the production facilities from which they source their products.
Gray-Nicolls Sports is addressing these concerns with the following Ethical Sourcing Policy. This policy aims to ensure that:
- Products are sourced in a responsible manner.
- Suppliers are clearly informed about the proper social and environmental practices they are required to implement.
Gray-Nicolls Sports is committed to upholding human rights, no child labour, fair working conditions and environmental protection. We operate responsibly within the community and expect the same from our suppliers.
We are dedicated to working with our suppliers to help improve their labour and environmental practices.
We expect our suppliers to support and comply with the ethical standards set out in this Policy; no matter where they operate in the world. We understand that full compliance with these criteria may take some time and are committed to working with our suppliers to help them improve and achieve compliance.
Our suppliers must commit to complying with the following requirements, many of which are drawn from the Ethical Trading Initiative (ETI) and International Labour Organisation (ILO) Conventions.
1. Legal Requirements
• All local laws and regulations regarding labour, health, safety and the environment must be observed by suppliers. Suppliers must comply with the legal requirements of the countries in which they operate in addition to all elements of this Ethical Sourcing Policy.
2. Bribery and Corruption
- Suppliers shall not engage in acts of bribery and corruption and shall not falsify documents and records.
- Suppliers are not permitted to offer any employee of Gray-Nicolls Sports any benefit (money, commission, travel or gift, directly or indirectly).
3. Labour Rights
- Employment is freely chosen. There is no forced, bonded or involuntary prison labour. Workers are free to leave employment after appropriate notice has been given to the employer. Workers are not required to lodge deposits or identity papers with suppliers.
4. Child Labour
- Suppliers shall not use child labour. A child is defined as an individual who is younger than the local legal age for completion of compulsory education. Or if any doubt under 18 years of age.
- Child Labour refers to work that is mentally, physically or morally harmful to children. This means depriving them of the opportunity to attend school; obliging them to leave school prematurely or requiring them to attempt to combine school attendance with excessively long and heavy work. In short, child labour is work that deprives children of their childhood, the opportunity to attend school and is harmful to their physical and mental development.
5. Working Conditions
- A safe and hygienic working environment shall be provided, keeping in mind the prevailing knowledge of the industry and of any specific hazards. Adequate steps shall be taken to prevent accidents and injury, and risks to long term health in the working environment. This includes putting in place procedures to minimise the long term effects of noise, chemicals (fumes and contact with skin) and smoke inhalation to employees.
- Workers shall receive adequate, regular and recorded health and safety training which shall be repeated for new or reassigned workers.
- Access to clean toilet facilities and to clean and drinkable water and if appropriate, sanitary facilities for food storage shall be provided.
- Accommodation, where provided, shall be clean, safe, and meet the basic needs of the workers.
- Suppliers will ensure that personal protective equipment is available and workers receive adequate training in its use. Safeguards on machinery must meet or exceed local laws.
- Suppliers shall assign responsibility for health and safety to a senior management representative.
- Suppliers must design the place of manufacturing so that there are two fire exits (that are clear of obstruction) on each floor in the suppliers premises, multiple fire extinguishers that are kept up to safety codes (i.e. ensure they have not expired).
- There will be a fire evacuation procedure that all employees are educated about, including the dangers of smoke inhalation.
6. Living Wages
- Wages and benefits paid for a standard working week must meet the minimum national legal standards or industry benchmark standards, whichever is higher.
- All workers must be provided with written and understandable information about their employment conditions in respect to wages and other benefit both before they begin their employment as well as during their employment, and about the particulars of their wages for the pay period concerned each time that they are paid.
- Deductions from wages as a disciplinary measure or any deductions from wages not provided for by law shall not occur without the expressed permission of the worker concerned. All disciplinary measures should be recorded.
7. Working Hours
- Working hours comply with any law and benchmark industry standards, whichever affords greater protection.
- Overtime shall be voluntary, shall not be excessive and shall always be compensated at a premium rate.
- In cases of casual employment (including those receiving piece wage), paid leave is not provided, but the wage given shall be higher than hourly wage full or part time workers to compensate.
- There will be no discrimination in hiring, compensation, access to training, promotion, termination or retirement based on race, caste, national origin, colour, descent, religion, age, physical or mental disability, gender/gender identity, marital status, parental status, physical characteristics or appearance, genetic information, sexual orientation, union membership, political affiliation, HIV/AIDs or any other category protected by relevant local law.
9. Harsh or Inhumane Treatment
- Physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation shall be prohibited.
- There shall be no sub-contracting of work or labour unless previously agreed with Gray-Nicolls Sports.
- Suppliers must have adequate processes in place for properly managing sub-contracting to ensure sub-contractors do not abuse, exploit or provide unsafe working conditions for their employees. Sub-contractors and suppliers providing materials or labour in the manufacture of goods for Gray-Nicolls must adhere to the Gray-Nicolls Ethical Sourcing Policy.
11. Environment Compliance
- The facility shall comply with national and local environmental laws and regulations.
- The facility shall dispose of its production waste in accordance with local environmental laws and regulations.
- The facility must have identified and documented its key environmental impacts and implemented controls to minimise its impact on the environment with respect to solid waste disposal, hazardous chemicals storage and management, air and water emissions.
- Suppliers will follow Gray-Nicolls Sports requests when an environmental issue is raised with regard to production waste.
12. Entitlement to Work and Immigration
- Only workers with a legal right to work shall be employed or used by the supplier.
- Goods should only be manufactured within the supplier’s own premises, unless transparently and previously agreed by Gray-Nicolls. Details of addresses to be provided.
14. Supplier agreements
- It is expected that larger suppliers will have separate contracts with Gray-Nicolls.