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Club Green Ethical Trading Policy

Introduction

Club Green are committed to this policy and will conduct business in an ethical, legal and socially responsible manner. This commitment extends to suppliers and other associated external resources with which we chose to do business. We recognise the responsibility that we share with our suppliers to source products in an ethical manner. We want our customers to be confident that people are treated fairly, are not exploited and are not exposed to unsafe working conditions. Our Ethical Trading Policy requires all our suppliers to comply with our ethical code which is based on the International Labour Organisation (ILO) and national and international laws.

Commitment to Ethical Trading

We recognise the need to communicate our commitment to key stakeholders including suppliers and the people who work with our suppliers. We seek to develop long term relationships with our suppliers who share our ethical standards. These relationships are based on the principle of fair, open and honest dealings at all times. Only suppliers that share our standards and can demonstrate compliance will be considered appropriate to trade with.
Improvement

We encourage and support continuous improvement in supplier standards and we regularly measure supplier improvement. We recognise our suppliers may need time and support to ensure compliance, however, all our suppliers must demonstrate that any breach of our ETC is addressed in appropriate timescales. Where we are alerted to breaches of our ETC we will take action considered appropriate. We will work with suppliers to resolve ethical trading issues. If suppliers are unable or unwilling to address critical issues associated with any breach of our ETC within the required timescales, we reserve the right to terminate the relationship in accordance with our contractual rights.

Transparency

We will strive to be open and honest when we work with others and ensure reporting is fair and transparent.

Specific Supplier Requirements

The requirements outlines are in addition to applicable legislation. These requirements are in addition to our standard requirements for products supplied to be safe, legal and good quality.
All suppliers are required to comply in all respects with our code which is referenced in our supplier standard terms & conditions of purchase

Ethical Trading Code

Suppliers shall at all times comply with this code and with the applicable national and international laws, regulations, codes and standards, both in the country in which the supplier works and in the country in which the product and/or services are sourced/provided. Suppliers shall ensure, as far as is reasonably practicable, that their suppliers, agent(s), subcontractors and consultants, who are directly or indirectly involved in the provision of goods and/or services to Club Green Limited comply with the code.

Suppliers Shall Ensure:

Employment is freely chosen

There is no forced, bonded or involuntary prison labour.
Workers are not required to lodge monetary deposits or their identity papers with their employer and are free to leave their employment after reasonable notice.

Freedom of association and the right to collective bargaining respected

Workers have the right to join or form trade unions of their own choosing and to bargain collectively.
The employer adopts an open attitude towards the activities of trade unions and their organisational activities.
Workers’ representatives are not discriminated against and have access to carry out their representative functions in the work place.
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.

Working conditions are safe and hygienic

A safe and hygienic working environment shall be provided, bearing in mind the prevailing knowledge of 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 reasonably practicable the causes of hazards inherent in the working environments.
Workers shall receive regular recorded health and safety training.
Workers are provided with access to clean toilet facilities and to safe drinking 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.
A senior management representative shall be responsible for Health and Safety.

Child labour shall not be used

There shall be no use of child labour.

In the event of any child found to be performing child labour, they shall be removed from the workplace immediately. The supplier shall then participate and contribute to the provision for the transition of the child to enable her or him to attend quality education until no longer a child.

Young persons under 18 shall not be employed at night or in hazardous conditions.
These policies and procedures relating to Child Labour shall conform to the provisions of the relevant International Labour Organisation (ILO) Standards.

Remuneration

Wages and benefits paid for a standard working week meet, at a minimum, national legal or industry benchmark standards, whichever is higher. In any event wages shall always be enough to meet basic needs and to provide some discretionary income.

All workers shall be provided with written and understandable information about their employment conditions including information with respect to wages before they enter employment, and about the particulars of their wages for the pay period concerned each time they are paid.

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.

Working hours are not excessive

Working hours must comply with national laws, collective agreements, and the provisions defined in the clauses below, whichever affords the greater protection for workers. Working hours, excluding overtime, shall be defined by contract, and shall not exceed 48 hours per week.

All overtime shall be voluntary.

Overtime shall be used responsibly, taking into account all the following: the extent, the frequency and hours worked by individual workers and the workforce as a whole. It shall be used to replace regular employment.
Overtime shall always be compensated at a premium rate, which is recommended to be not less than 125% of the regular pay rate.

The total hours worked in any 7 day period shall not exceed 60 hours, except where covered by the clause below.

Working hours may exceed 60 hours in any 7 day period only in exceptional circumstances where all the following are met:

• This is allowed by national law
• This is allowed by a collective agreement freely negotiated with a workers’ organisation representing a significant portion of the workforce
• Appropriate safeguards are taken to protect the workers' health and safety, and the employer can demonstrate that exceptional circumstances apply such as unexpected production peaks, accidents and emergencies.

Workers shall be provided at least one day off every 7 day period or, where allowed by national law, 2 days off in every 14 day period.

No discrimination is practised

There is no discrimination in hiring, compensation, access to training, promotion, termination or retirement based on race, national origin, religion, age disability, gender, marital status, sexual orientation, union membership, or political affiliation.

Regular employment is provided

To every extent possible work performed must be on the basis of recognised employment relationships established through national law and practice.

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 and 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.

No harsh or inhumane treatment is allowed

Suppliers provide a workplace in which any form of harassment is unacceptable. Examples include physical abuse or discipline, the threat of physical abuse or sexual or other harassment and verbal abuse or other forms of intimidations.

Entitlement to work

Only workers with a legal right to work in the country should be employed.
For both workers and agency workers, original documents should be reviewed and then returned to workers to verify the right to work.

Labour Providers
Labour providers should only supply workers registered with them.

Relationships with labour providers should be covered by a Service Level Agreement which meets all national legal requirements.

Labour providers should be independently audited on a regular basis to ensure compliance with national requirements/legislation.
Club Green Modern Slavery Policy

Policy Statement

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain. We have a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implement and enforce effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or our supply chain.
We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chain. We expect the same high standards from all of our contractors, suppliers and other business partners. As part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude and we expect that our suppliers will hold their own suppliers to the same high standards.
This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, agents, contractors, external consultants, third-party representatives, suppliers and business partners. This policy does not form part of any employee’s contract of employment and we may amend it at any time.

Responsibility for the Policy

The Procurement Department has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
The Group Purchasing Director has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.
Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given any required training.

Compliance with the Policy

You must ensure that you read, understand and comply with this policy.
The prevention, detection and reporting of modern slavery in any part of our business or supply chain is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.
You must notify your manager OR the Procurement Department as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future.
You are encouraged to raise concerns about any issue of suspicion of modern slavery in any parts of our business or the supply chains of any supplier tier at the earliest possible stage.
If you believe or suspect a breach of this policy has occurred or that it may occur you must notify your manager or report it in accordance with our Whistleblowing Policy as soon as possible
If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chain constitutes any of the various forms of modern slavery, raise it with your manager or the Procurement Department.
We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any part of our supply chain. If you believe that you have suffered any such treatment, you should inform your manager immediately.

Communication and Awareness of Policy

Training on this policy, and on the risk our business faces from modern slavery in its supply chain will be given where needed.
Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

Breaches of this Policy

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
We may terminate our relationship with other individuals, suppliers and organisations working on our behalf if they breach this policy.