Code of Ethical Conduct and Social Accountability Policy
We, at C&A Marketing, Inc. (“C&A”), are committed to achieving the highest standards for ethical conduct, the safety, quality and integrity of our products and processes, and for protecting the environment. Therefore, we also carefully select our manufacturing partners and develop long-term relationships with people committed to the same goals. These standards include the working conditions under which our products are made.
We are industry leaders who have worked to enhance workplace conditions within our manufacturing partners’ factories. As a part of this commitment, we recognize this Code of Ethical Conduct and Social Accountability Policy (the “Policy”) as a vital tool in ensuring that all entities who wish to do business with us likewise adhere to basic human rights principles.
Our vendors are our partners – whether they are licensors of finished goods, factories that make C&A products for us, or white-label suppliers for our brands (collectively referred to as “Vendors”). While we understand that there are different practical concerns and legal and cultural environments in which Vendors operate throughout the world, these considerations all the more require us to set minimum requirements to maintain the integrity of our standards.
Moreover, this Policy provides the foundation for our ongoing evaluation of a Vendor’s practices that may ultimately lead to a decision of whether said relationship should be continued. As stated, this Policy is intended to convey the minimum standard for doing business with C&A, but shall not restrain us from imposing more stringent standards in selecting and partnering with our Vendors in appropriate circumstances.
Compliance with Laws
We are committed to sourcing components and materials only from Vendors that share our values regarding respect for human rights, integrity and environmental responsibility. Therefore, all Vendors must operate in full compliance with all applicable laws, rules and regulations of the countries where they manufacture, including but not limited to those related to labor, employee health and safety, and the environment. The same shall be required with respect to the production of all materials incorporated into C&A merchandise.
C&A engages in verification of suppliers to evaluate and address various risks and requires direct suppliers to certify that materials incorporated into its products comply with the laws of the countries where they are being sold, including, but not limited to, laws prohibiting slavery and human trafficking.
C&A’s merchandise shall be produced only at approved Factories. Purchase orders for Merchandise are issued for production at an agreed approved Factory and cannot be changed to a different location without written approval. All subcontractors and suppliers shall likewise be required to comply with all applicable laws.
When it comes to shipments, mandatory compliance with US Customs importation laws is required.
We abide by all applicable environmental laws and regulations, and manage our environmental footprint to minimize adverse impact on the environment. We, therefore, expect our Vendors to do the same.
Where this Policy differs from local laws, our Vendors must follow the more stringent standard. We will neither tolerate nor in any way facilitate any serious abuse of human rights.
The following are Employment Standards required to be maintained by each Vendor and/or each Factory in which C&A goods are produced.
- Forced Labor – We do not use any prison or reform labor of any kind in our operations. All of our employees may terminate their employment with our company at any time. Therefore, the use of forced labor, whether in the form of prison, indentured, bonded labor or otherwise, shall be strictly prohibited.
- Child Labor – We have a strict policy against any form of child labor. Under no circumstances would we ever hire or cause anyone to work who is under the age of 15. We not only verify the date of birth at the time of hire to ensure that this Policy is upheld, we likewise prohibit any employee to take production work at home as all work related to our business must be performed only by employees onsite whose ages have been verified.
To this end, our Vendors and Factories must ensure that no person shall be employed at an age younger than the legal age for employment in the country of manufacture. Each Vendor and Factory must also comply with restrictions in national laws on hazardous work by employees under the age of 18. No person shall knowingly be employed at an age younger than 15, or younger than the age for completing compulsory education if the age in the country of manufacture is greater than 15. No young worker shall knowingly be exposed to situations in or outside of the workplace that are likely to jeopardize their health, safety or morals.
- Harassment or Abuse – Workers shall be treated with respect and dignity. Workers shall not be subject to any physical, verbal, sexual or psychological harassment or abuse in connection with their employment.
- Health and Safety – Employers shall provide a safe and sanitary working environment in order to avoid preventable work-related accidents and injuries, such as adequate lighting and ventilation, safety training, fire extinguishers and fire evacuation escape routes. Where an employer provides dormitory or other housing for its workers, such facilities shall be operated in a safe and sanitary manner, and in compliance with applicable national laws governing such facilities.
- Nondiscrimination – Workers should be employed and compensated based on their ability to perform their job description, and not personal characteristics or beliefs.
- Prohibition of Coercion and Harassment – We treat each employee with dignity and respect. We will not use physical or bodily punishment, threats of violence or other forms of physical, sexual, psychological, or verbal harassment or abuse.
- Wages and Benefits- Employers shall pay workers for all work completed and shall pay at least the minimum wage required by law and provide legally mandated benefits.
- Overtime – In addition to compensation for regular hours of work, workers shall be compensated for overtime hours at the rate as legally required. Each Vendor and Factory shall carry out operations in ways that limit overtime to a level that ensures productive and humane working conditions.
- Work Hours – Each Vendor and Factory shall comply with national laws regarding the maximum number of hours worked per week. Overtime shall be voluntary, unless permissible under applicable law. Workers shall not be asked or required to take work home or off premises except as permissible under applicable law; and
- Freedom of Association and Collective Bargaining – Each Vendor and Factory shall comply with local laws and regulations regarding freedom of association and collective bargaining.
Evaluation and Inspection of Factories
Each Vendor and Factory shall allow C&A, and/or any of its representatives or agents, unrestricted access to its facilities and to all relevant records at all times, upon reasonable prior notice. However, independent, unannounced audits may be conducted to evaluate compliance with standards for trafficking and slavery in supply chains. We may use its sourcing personnel, overseas agents and/or third party contractors to review Vendor’s and Factory’s adherence to this Policy, and to reevaluate its existing relationships where the results of those reviews so warrant.
Remediation/Re-Evaluation of Factories
Depending on the extent of our relationship, we are willing to work with a Vendor or Factory in order to bring them into compliance where shortcomings are found. Although our only desire is for continuous improvement in factory conditions, we nevertheless reserve the right to break contractual relations for any violations of its Policy.
Communication and Training
This Policy and other appropriate guidance on our expectations shall be provided in writing to our employees and Vendors. Whenever necessary, we shall also provide training on social accountability standards to employees with direct responsibility for supply chain management, including but not limited to prohibitions against human trafficking and slavery, particularly with respect to mitigating risks within the supply chain of products, so as to achieve the highest standards of legal and ethical conduct for ourselves and our business partners.
All told, we will not knowingly do business with Vendors that undermine our standards, damage our reputation, and/or threaten our commercial success. With full consideration for the practice of individual Vendors, as well as the political and social issues in a Vendor’s country, we will nevertheless select only the Vendors who share our values. We reserve the right to break contractual relations, and will not initiate relations with Vendors who violate basic human rights.