Swadeshi Dhaaga is strongly committed and conducting its business in a lawful and ethical manner, including engaging with suppliers that are committed to the same principles. These standards set out Swadeshi Dhaaga’s expectations for suppliers of goods and services. We require suppliers in our manufacturing supply chain and suppliers supporting Swadeshi Dhaaga’s operations to comply with the Supplier Code of Conduct* (“Supplier Code”), which is detailed below. In order to ensure these standards are cascaded throughout the supply chain, Swadeshi Dhaaga also expects our suppliers to hold their suppliers and subcontractors to the standards and practices covered by this Supplier Code. The products must be manufactured and services provided in a manner that meets or exceeds the expectations of Swadeshi Dhaaga and the customers are reflected in this Supplier Code.
Here are some of the key areas we focus on:
1) Health and safety in production areas and any living quarters
2) The right to legal wages and benefits
3) Appropriate working hours and overtime pay
4) Prevention of child labour or forced labour
5) Fair and ethical treatment, including non-discrimination
To ensure that our policies and programmes incorporate internationally recognized human rights standards, we conduct formal benchmarking with industry and multilateral groups to design, operate, and continuously improve our risk assessment and audit program. Audit and assessment results are reviewed regularly by the senior leadership of the appropriate Swadeshi Dhaaga business and corrective action plans are implemented with suppliers as needed.
Our organization partner closely with the suppliers to drive continuous improvement in worker conditions. We train the suppliers on the standards and conduct required by this Supplier Code. Where appropriate, we use independent auditors to verify compliance, including confidential worker interviews. where we use industry association audits and other mechanisms to verify information. We regularly assist suppliers to monitor continued compliance and improvement; many sites are assessed multiple times a year, including for follow-up assessments to address specific findings. Swadeshi Dhaaga may terminate its relationships with any supplier that violates this Supplier Code or does not cooperate during assessments.
Assessments may include:
1) Site inspection of all areas of the site and any living quarters;
2) Confidential worker interviews or surveys conducted without site management present
3) Review and analysis of site documents or licenses to assess workers’ age, contracts, compensation, working hours, and workplace conditions
4) Identification of past compliance issues, areas for improvement and development of a remediation plan.
5) Upon completion of an assessment, a supplier must promptly provide a detailed remediation plan for each issue identified.
6) Swadeshi Dhaaga tracks remediation closely and conducts follow-up assessments for significant issues.
7) Between assessment, Swadeshi Dhaaga employees meet with supplier managers to discuss open issues and remediation progress.
Supplier Code of Conduct
Our Guiding Principle. Suppliers’ business and labour practices must comply with all applicable laws, as well as the requirements and principles of this Supplier Code. Suppliers must comply with the standards of this Supplier Code even when this Supplier Code exceeds the requirements of applicable law.
Child Labour.
Swadeshi Dhaaga will not tolerate the use of
child labour, Suppliers must engage workers whose age is the greater of: (i) 15, (ii) the age of completion of compulsory education, or (iii) the minimum age to work in the country where work is performed. Furthermore, workers under the age of 18 must not perform hazardous work. Swadeshi Dhaaga supports the development of legitimate workplace apprenticeship programs that comply with applicable laws and this Supplier Code.
Involuntary Labour,
Human Trafficking, and Slavery. Suppliers must not use forced labour – slave, prison, indentured, bonded, or otherwise. Suppliers must not traffic workers or in any other way exploit workers by means of threat, force, pressure, abduction, or fraud. Working must be voluntary, and workers must be free to leave work and terminate their employment or other work status with reasonable notice. Workers shall not be required to pay recruitment, hiring, or other similar fees related to their employment; suppliers must bear or reimburse to their workers any such fees. All fees and expenses charged to workers must be disclosed to Swadeshi Dhaaga and communicated to workers in their native language in advance of their employment. Swadeshi Dhaaga also expects the suppliers to hold their third-party labour agents or brokers to the standards and practices covered by this
Supplier Code.
The Suppliers must not require any workers to surrender government issued identification, passports, or work permits as a condition of working, and suppliers may only temporarily hold onto such documents to the extent reasonably necessary to complete legitimate administrative and immigration processing. Workers must be given clear, understandable contracts regarding the terms and conditions of their engagement in a language understood by the worker. Suppliers must ensure that each of its staffing or recruiting agencies comply with this Supplier Code and with the more stringent of the applicable laws of the country where work is performed and the worker’s home country.
Safety and Health. Suppliers must provide workers with a safe and healthy work environment, and suppliers must, at a minimum, comply with applicable laws regarding working conditions and with the standards below.
Occupational Safety.
Suppliers must educate workers on safety procedures and also control worker exposure to potential physical safety hazards by implementing physical guards, barriers, and/or engineering and administrative controls. Workers must be informed and receive appropriate education in advance if they will be working with (or otherwise exposed to) hazardous or dangerous conditions or materials. In addition, workers must be given appropriate personal protective equipment and must be educated and trained on the proper use of such equipment. Suppliers must manage, track, and report occupational injuries and illnesses.
Physically Demanding Work. Suppliers must continually identify, evaluate, and control physically demanding tasks to ensure that worker health and safety is not jeopardised.
Emergency Preparedness and Response. Suppliers must identify and plan for emergency situations and implement and train their workers on response systems, including emergency reporting, alarm systems, worker notification and evacuation procedures, worker training and drills, first-aid supplies, fire detection and suppression equipment, and unblocked exit facilities.
Machine Safeguarding. Suppliers must implement a regular machinery maintenance program. Production and other machinery must be routinely evaluated for safety hazards.
Sanitation and Housing.
Workers must be provided with reasonable access to clean toilet facilities and potable drinking water. If suppliers provide a canteen or other food accommodations, they must include sanitary food preparation, storage, and eating accommodations. If suppliers provide residential facilities for their workers, they must provide clean and safe accommodations. In such residential facilities, workers must be provided with emergency exits, reasonable and secure personal space, entry and exit privileges, reasonable access to hot water for bathing, adequate heat and ventilation, and reasonable transportation to and from work facilities (if not reasonably accessible by walking) .
Wages and Benefits. Suppliers must pay their workers in a timely manner and provide compensation (including overtime pay and benefits) in accordance with applicable laws. Suppliers must provide to their workers the basis on which workers are being paid in a timely manner via pay stub or similar documentation. Deductions from wages as a disciplinary measure are not permitted.
Working Hours
Except in unusual or emergency situations, (i) suppliers must not require a worker to work more than 60 hours per week, including overtime, and (ii) each worker must be entitled to at least one day off for every seven-day work period. In all circumstances, working hours must not exceed the maximum amount permitted by law.
Anti-discrimination.
Conditions of working must be based on an individual’s ability to do the job, not on personal characteristics or beliefs. Suppliers must not discriminate on the basis of race, colour, national origin, gender, sexual orientation, religion, disability, age, political opinion, pregnancy, marital or family status, or similar factors in hiring and working practices such as job applications, promotions, job assignments, training, wages, benefits, and termination. Suppliers must not subject workers or applicants to medical tests that could be used in a discriminatory manner.
Fair Treatment. All workers must be treated with respect and dignity. Suppliers must not engage in or permit physical, verbal, or psychological abuse or coercion, including threats of violence, sexual harassment, or unreasonable restrictions on entering or exiting work and residential facilities. Workers must be free to voice their concerns to Swadeshi Dhaaga or its auditors, and allowed to participate in the Swadeshi Dhaaga audit process, without fear of retaliation by supplier management.
Immigration Compliance
Suppliers may only engage workers who have a legal right to work. If suppliers engage foreign or migrant workers, such workers must be engaged in full compliance with the immigration and labour laws of the host country.
Freedom of Association. Suppliers must respect the rights of workers to establish and join a legal organisation of their own selection. Workers must not be penalised or subjected to harassment or intimidation for the non-violent exercise of their right to join or refrain from joining such legal organisations.
No Bribery Suppliers must not engage in an act of bribery with anyone for any reason, whether in dealings with government officials or the private sector. This includes offering, promising, giving, or accepting anything of value to obtain or provide undue or improper advantages to anyone for any reason. Suppliers must not induce Swadeshi Dhaaga employees to violate our Code of Business Conduct and Ethics posted at: http://phx.corporate-ir.net/phoenix.zhtml?c=97664&p=irol-govConduct
Anti-Corruption. Suppliers must comply with applicable anti-corruption laws, including the United States Foreign Corrupt Practices Act and the United Kingdom Bribery Act, and never bribe a government official/ public servant on Swadeshi Dhaaga’s behalf. Suppliers must not offer, give, or promise anything of value, either directly or indirectly, to government officials/ public servants to encourage them to act improperly or to reward them for doing so. Prohibited payments can take many forms including, but not limited to, cash or cash equivalents, gifts, meals, and entertainment. Any questions regarding the applicability of this provision or exceptions to this provision must be directed to the Legal Department of Swadeshi Dhaaga.
Whistleblower Protections. Suppliers must protect worker whistleblower confidentiality and prohibit retaliation against workers who report workplace grievances. Suppliers must create a mechanism for workers to submit their grievances anonymously.
Management Systems
Suppliers must adopt a management system to ensure compliance with applicable laws and this Supplier Code and to facilitate continual improvement.
Management Accountability and Responsibility. Suppliers must have designated representatives responsible for implementing management systems and programmes that oversee compliance with applicable laws as well as this Supplier Code. Senior management must routinely review and assess the quality and efficiency of the management systems and programs. Swadeshi Dhaaga also expects the suppliers to hold their suppliers and subcontractors to the standards and practices covered by this Supplier Code.
Risk Management
Suppliers must establish a process to identify the environmental, health, safety, and ethical risks associated with their operational and labour practices. In addition, management must develop appropriate processes to control identified risks and ensure regulatory compliance.
Training. Management must maintain appropriate training programmes for managers and workers to implement the standards in this Supplier Code and to comply with applicable legal requirements.
Communication and Worker Feedback
Suppliers must clearly and accurately communicate and educate workers about Swadeshi Dhaaga policies, practices, and expectations. Swadeshi Dhaaga may require suppliers to post this Supplier Code in a location accessible to their workers (translated into the appropriate local language(s)). In addition, Swadeshi Dhaaga encourages suppliers to partner with us to implement a process to assess workers’ understanding of the standards and practices covered by this Supplier Code.
Documentation and Records
Suppliers must create, retain, and dispose of business records and/or other documents in full compliance with applicable legal requirements along with appropriate confidentiality to protect privacy.
Environment
Suppliers must comply with applicable environmental laws. Swadeshi Dhaaga encourages the suppliers to implement systems that are designed to minimise the impact on the environment by the supply chain system, the production process, and the products themselves.
Environmental Permits and Recordkeeping. Suppliers must obtain and keep current all required environmental permits, approvals, and registrations and follow applicable operational and reporting requirements.
Effective Management and Disposal of Hazardous Substances
Suppliers must effectively identify and manage the safe handling, movement, storage, and disposal of chemicals and other substances that pose a threat to the environment, including providing workers with appropriate training on the safe-handling, movement and disposal of hazardous substances. Suppliers must also monitor and control wastewater or solid waste generated from operations before disposing in accordance with applicable laws. In addition, suppliers must characterize, monitor, control, and treat regulated air emissions before discharging in accordance with applicable laws.
Continuous Improvement.
Swadeshi Dhaaga encourages the suppliers to continuously improve and reduce waste. Swadeshi Dhaaga welcomes suggestions and feedback from its suppliers to improve Swadeshi Dhaaga’s own operations and processes.
Conflict Minerals. Swadeshi Dhaaga is committed to avoiding the use of minerals that have fuelled conflict in the Democratic Republic of the Congo or an adjoining country. We expect suppliers to support our effort to identify the origin of designated minerals used in our products.
Corrective Action.
Suppliers’ compliance with this Supplier Code is subject to Swadeshi Dhaaga’s review, including third-party auditing of work and residential facilities and conducting confidential worker interviews. Suppliers must be transparent and shall ensure prompt access to their facilities, records, and workers during any assessment. We require suppliers to promptly provide a detailed remediation plan and take corrective actions for deviations from this Supplier Code, and Swadeshi Dhaaga will track suppliers’ remediation efforts. Swadeshi Dhaaga may (without liability) terminate its relationships with any supplier found to be in violation of this Supplier Code, including for denying prompt access to our auditors.