CEWE Limited (“CEWE”) is committed to sourcing and supplying quality products and developing partnerships with customers and suppliers who share common principles of fair and honest trading.
We are committed to ensuring that the products and services we source are obtained only from suppliers who strive to maintain satisfactory working conditions, comply fully with all legal requirements and the labour, health and safety standards of those countries in which they operate.
We are committed to a continuous improvement approach regarding the environment and social sustainability. We aim to meet the needs of our customers without compromising the ability of future generations to meet their own needs.
We seek to uphold the following standards in dealings with suppliers:
We will only trade with suppliers who are open and transparent to assessment and who are working towards compliance with our Code. Suppliers must maintain proper and accurate employment, payroll and working time records for the assessment when required. We maintain the right to end the business relationship and cancel outstanding orders if any supplier fails to do so.
We do however recognise that in the event of non-compliance, withdrawal of our business may cause severe hardship to those employed and will therefore attempt to work with our suppliers to move them towards compliance.
Fabian Sparer, Managing Director, CEWE Limited
Our principles draw upon international standards, including the Ethical Trading Initiative Base Code and the International Labour Organisation (ILO) conventions and recommendations, which in turn are based on the United Nations (UN) Universal Declaration of Human Rights and Convention on Rights of the Child.
CEWE is committed to applying and implementing all elements of this policy and its Guiding Principles. Certain elements of non-compliance will not be tolerated under any circumstances – those that protect workers’ fundamental human rights such as the use of forced, bonded or involuntary prison labour, physical abuse or discipline and extreme forms of intimidation. Other elements of the policy are aspirational and it is understood that remediation will not always be able to be achieved immediately. In these circumstances we will work with our suppliers to create change towards the standards described.
1. Terms and Conditions of Employment
There must be no forced, bonded or involuntary labour. No worker shall be required to lodge a deposit, passport or identity papers with their employer. Where identity cards, etc. are required for registration / age validation purposes, employers should retain a copy for their records and return the original to the worker. Any worker shall be free to leave their employer after giving their contractual notice in writing and shall normally be entitled to their contractual or statutory notice (whichever is the highest) in the event of termination of their employment. Disciplinary processes must comply with local law as a minimum and must be clearly defined, documented and communicated to all workers. All disciplinary action taken must be recorded. Grievance procedures must allow for all workers to raise concerns with their employer about their employment conditions or about other employees, without fear of reprisal. These processes must be clearly defined, documented and communicated to all workers. Subject to local law:
All workers must be entitled to join a trade union of their own choosing. All workers shall be entitled to bargain collectively. Employers must demonstrate an open attitude towards trade unions and their organisational activities. Workers’ representatives must be allowed access to the workplace to carry out their functions and must not be discriminated against. Where local law restricts workers’ rights to join a trade union of their choosing and to bargain collectively, employers must facilitate other means of independent, free association and bargaining. Prior to employment, workers must be provided with written and understandable information about their conditions of employment, including rates of pay. Workers shall not be placed under duress to sign their agreement to terms and conditions (or changes to terms and conditions). Working hours shall not exceed local legal requirements or local norms for the industry. All workers must be allowed at least one day off in seven. To every extent possible, work performed must be on the basis of a recognised employment relationship established through national law and practice. Part time, temporary, fixed-term contracts or homeworking arrangements shall not be used to avoid compliance with the principles of this policy or to avoid obligations to employees under local labour law and practice. This includes workers supplied through agencies. Worker participation in overtime shall be entirely voluntary, and will be paid in accordance with local legal requirements. There must be no discrimination during recruitment or employment on the basis of (but not limited to) race, skin colour, ethnic origin, national origin, religion, gender, sexual orientation, disability, age, marital status, union membership, or political affiliation.
2. Wages and Benefits
Wages and benefits for basic hours must (as a minimum) meet local legal minimum wage criteria or local norms for the industry. All workers shall be provided with written, understandable information (pay-slip) relating to their wages for each pay period. All deductions shall be clearly indicated on workers’ pay-slips. Where a charge or deduction is made for accommodation, transport, meals or other similar benefit which is provided, this deduction shall not be excessive. After all deductions, wages must be in accordance with local norms for the industry. 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 express permission of the worker concerned. Where accommodation is provided, this must be safe, hygienic and not compromise the dignity of workers.
In line with ILO conventions on child labour, children under the age of 15 shall not be recruited or employed, unless the local minimum age for work or mandatory schooling specifies a higher age or if ILO developing country exemptions apply. The education, health, physical, mental, spiritual, moral or social development of a young person must not be adversely impacted by the work he or she performs, the number of hours worked or the conditions in which he or she works. Children and young people under 18 shall not be expected to work at night or carry out potentially hazardous activities or activities which are likely to be damaging to their health and development. If underage workers are found working, the supplier involved will be expected to stop the practice and take remedial action. This should include support for the child to attend and remain in education until the national minimum working age, or 15, or mandatory schooling age whichever is oldest. Suppliers shall clearly document and communicate their policies for dealing with underage children, even if there are no known children employed.
4. Health and Safety
Responsibility for the implementation of Health and Safety shall be assigned to a senior manager. Working conditions for all employees shall be safe and hygienic. Risk assessment (and risk management) shall be used as part of a proactive approach to accident prevention. A review of all risks shall be carried out on a regular (and appropriate) basis. Adequate steps shall be taken to minimise the causes of hazards in the working environment. Emergency procedures must be in place and their efficacy evaluated at an appropriate frequency. Workers shall receive health and safety training. This shall be recorded and refreshed at an appropriate frequency. Workers shall not be assigned to any task for which they have not received the appropriate training. Clean toilet facilities must be accessible to all workers.
5. Sustainable Development and Environmental Protection:
CEWE is committed to improving the sustainability of its products and services. This can be achieved by working with our suppliers to continually improve our products by adopting a balanced approach to reducing the social, economic and environmental impacts throughout the supply chain. All suppliers have a role to play in helping achieve this ambition. The nature and extent of involvement will depend on a range of factors including product sector, geographical location and stage of supplier development.
A fundamental requirement is that all suppliers must comply with local environmental legislation. Suppliers should identify and understand the range and importance of the social and environmental impacts most relevant to their operations. The suppliers approach to reducing these impacts must be documented in a written environmental policy statement. Responsibility for implementation of the policy must be assigned to a senior manager.
We expect our suppliers to engage with us to reduce the sustainability impacts of the products they produce for CEWE. For example, this can be by reducing the use of non-renewable resources, sourcing materials from accredited origins, or by reducing energy, water or packaging use. We encourage suppliers to identify any new opportunities to improve the sustainability of products supplied to CEWE.
6. Modern Slavery and Human Trafficking
It is a key priority for CEWE to ensure we trade ethically, source responsibly and work to prevent modern slavery and human rights issues throughout our organisation and in our supply chain.
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 and suppliers. CEWE strictly prohibits the use of modern slavery and human trafficking in our operations and supply chain.
We are committed to implementing controls and awareness aimed at ensuring that modern slavery is not taking place within our organisation or in our supply chains. We expect that our suppliers will hold their own suppliers to the same high standards.
Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking. Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited. Modern slavery is a crime and a violation of fundamental human rights.
The prevention, detection and reporting of modern slavery in any part of our organisation or supply chain is the responsibility of all those working for us or on our behalf. Workers must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy.
If we find that other individuals or organisations working on our behalf have breached this policy we will ensure that we take appropriate action. This may range from considering the possibility of breaches being remediated and whether that might represent the best outcome for those individuals impacted by the breach to terminating such relationships
Monitoring and Verification
We will take reasonable and practical steps, including on-site assessments to ensure that the required standards are adopted by our suppliers and in turn by their suppliers at all times.
Development of the Policy
We are committed to reviewing this Policy to ensure it reflects practical experience and changing circumstances over time. We will continue to develop and share best practice with stakeholders so that we can all make real progress together.