The SPRHRA Supplier Workplace Code of Conduct (“Code”) establishes standards for fair, safe and healthy working conditions and environmental responsibility throughout our supply chain. It provides the foundation to our Social and Environmental Responsibility Code.
This code was written to comply with the Fair Labor Association (FLA) standards to meet or exceed those. Our code is also based on the International Labor Organization (ILO) standards and internationally accepted good labor practices.
At SPRHRA, all suppliers must commit to adhering to our Code of Conduct and detailed Compliance Benchmark standards. Requirements in this Code pertain to the entire supply chain. Our supply chain includes, sub-suppliers, sub-contractors and farms. Standards equally apply to permanent, temporary, and agency workers, as well as piece-rate, salaried, hourly paid, legal young workers (minors), part-time, night, and migrant workers.
We look for suppliers who are committed to continuous improvement and who are moving in a forward direction towards their sustainability journey, along basic to leadership practices. All suppliers must agree to announced and unannounced assessments by SPRHRA and the FLA. SPRHRA expects all suppliers to make improvements when any of these Code standards are not met. SPRHRA expects suppliers to develop sustainable management, reporting and tracking systems within the factory, to ensure ongoing compliance. Timelines for achieving compliance shall be reasonable and defined. Providing proof of correction to SPRHRA for each non-compliance is also required.
SPRHRA pledges to help our suppliers improve labor, health and safety, and environmental conditions in the workplace, and to help our suppliers understand how to move from basic to leadership sustainability practices. We recognize that this effort requires listening to our suppliers and employers’ needs, and requires a collaborative approach using capacity building tools, such as root-cause analysis, training, and management-system development to drive intentional and impactful change.
SPRHRA’s mission is to give the “freedom to perform”, which includes building the best quality products, while doing our best to protect the earth we play on. SPRHRA seeks to exercise the best possible practices for the respectful and ethical treatment of workers and promote sustainable conditions in which workers earn fair wages in safe and healthy workplaces.
Supplier Workplace Code of Conduct
LAW AND CODE COMPLIANCE
Our suppliers are expected to comply with and will be monitored to: (1) all relevant and applicable laws and regulations of the country in which workers are employed including those at the federal, state/provincial and local community levels, (2) our Supplier Workplace Code of Conduct, (3) detailed Compliance Benchmark document, and (4) where applicable, Collective Bargaining Agreements. The Compliance Benchmarks identify specific requirements for meeting each Code standard. When differences or conflicts in standards arise, suppliers are expected to comply with the highest standard that is the most in favor of the employees.
No person shall be employed under the age of 15 or under the age for completion of compulsory education, whichever is higher. Juvenile workers (ages 15-17) shall not perform work which, by its nature or the circumstances in which it is carried out, is likely to compromise their health, safety or morals. (ILO Convention 138 and 182).
There shall be no use of forced labor, including prison, indentured, bonded, slave or other forms of forced labor. Acts of human trafficking are also prohibited. Suppliers are required to monitor any third party entity which assists them in recruiting or hiring employees, to ensure that people seeking employment at their facility are not compelled to work through force, deception, intimidation, coercion or as a punishment for holding or expressing political views. (ILO Conventions 29, 105, 182)
HARASSMENT, ABUSE AND DISCIPLINARY PRACTICES
Every employee shall be treated with respect and dignity. No employee shall be subject to any physical, sexual, psychological or verbal harassment or abuse or to monetary fines or embarrassing acts as a disciplinary measure.
No person shall be subject to any discrimination in any aspect of the employment, relationship including recruitment, hiring, compensation, benefits, work assignments, access to training, advancement, discipline, termination or retirement, on the basis of race, religious belief, color, gender, pregnancy, childbirth or related medical conditions, age, national origin, ancestry, sexual orientation, gender identification, physical or mental disability, medical condition, illness, genetic characteristics, family care, marital status, status as a veteran or qualified disabled veteran (in the USA only), caste, socio-economic situation, political opinion, union affiliation, ethnic group, illness any other classification protected under applicable law. All employment decisions must be made based on the principle of equal employment opportunity, and shall include effective mechanisms to protect migrant, temporary or seasonal workers against any form of discrimination. (ILO Conventions 100 and 111). *Gender-specific codes of conduct are outlined in the Women’s Rights section.*
FREEDOM OF ASSOCIATION AND COLLECTIVE BARGAINING
Workers must be free to join organizations of their own choice. Suppliers shall recognize and respect the right of employees to freedom of association and collective bargaining. All suppliers must develop and fully implement effective grievance mechanisms which resolve internal industrial disputes, employee complaints, and ensure effective, respectful and transparent communication between employees, their representatives and management. (ILO Conventions 87, 98 and 135)
Employers shall adopt and adhere to rules and conditions of employment that respect workers and, at a minimum, safeguard their rights under national and international labor and social security laws and regulations.
WAGES AND BENEFITS
We seek and favor suppliers who progressively raise employee living standards through improved wage systems, benefits, welfare programs and other services, which exceed legal requirements and enhance quality of life. Every worker has a right to compensation for a regular work week that is sufficient to meet the worker’s and their family’s basic needs and provide some discretionary income. Employers shall pay wages which equal or exceed minimum wage or the appropriate prevailing wage, whichever is higher, comply with all legal requirements on wages, and provide any fringe benefits required by law and/or contract. Where compensation does not meet workers’ basic needs and provide some discretionary income, each employer shall work with SPRHRA and the Fair Labor Association (FLA) to take appropriate actions that seek to progressively realize a level of compensation that does. (ILO Conventions 26 and 131)
In addition to compensation for regular working hours, employees must be compensated for overtime hours at the rate legally required in the country of manufacture or, in those countries where such laws do not exist, at a rate exceeding the regular hourly compensation rate by at least 125%. (ILO Convention 1 and 30)
HOURS OF WORK
Suppliers shall not require workers to work more than the regular and overtime hours allowed by the law of the country where the workers are employed. The regular work week shall not exceed 48 hours or the maximum allowed by the law of the country of manufacture, whichever is less. Employers shall allow workers at least 24 consecutive hours of rest in every seven-day period. All overtime work shall be consensual. Employers shall not request overtime hours on a regular basis. The sum of regular and overtime hours in a week shall not exceed 60 hours or the maximum allowed by the law of the county of manufacture, whichever is less. (ILO Convention 1)
HEALTH AND SAFETY
Suppliers shall provide a safe and healthy workplace to prevent accidents and injury to health arising out of, linked with, or occurring in the course of work or as a result of the operation of employers’ facilities. The employer shall take a proactive approach to health and safety by implementing policies, systems and training designed to prevent accidents, injuries and protect worker health. (ILO Convention 155)
Suppliers shall maintain written environmental policies and standards and must comply with all applicable environmental laws, our Code and Benchmarks, and agree to be monitored separately for environmental responsibility. Factories shall continuously monitor, and disclose to SPRHRA, their energy and natural resource usage, emissions, discharges, carbon footprint and disposal of wastes and take a progressive approach to minimize negative impacts on the environment.
SPRHRA encourages all suppliers and their employees to get involved in local social and environmental community charity efforts by volunteering time and/or providing other types of support. We seek long-term partnerships with suppliers that share these same philanthropic values.
SPRHRA does not permit subcontracting without our prior written approval. All salesman-sample and bulk production orders must be placed within facilities that have been pre-approved by SPRHRA, without exception. Direct suppliers are required to continuously monitor approved subcontractors and sub-suppliers for social and environmental responsibility using standards that meet or exceed our Code and Benchmarks.
Suppliers must respect animal welfare and work progressively towards adopting healthy and humane practices towards animals based on best available technology and standards.
SPRHRA and our suppliers are jointly responsible for ensuring social and environmental responsibility and the integrity of our product content claims from the farm through the finished goods factory level. The only way to work towards this goal is to have transparency and traceability into all levels of our supply chain. SPRHRA requires suppliers to map and continuously track and monitor all locations in all levels of their supply chain and upon request provide transparency information into the owned and/or subcontracted farms, mills, plants, factories and other sites that are involved in the production of our products.
All suppliers are required to: (1) post the SPRHRA Code standards and separate SPRHRA grievance phone number document in a conspicuous place frequented by all employees in the local languages spoken by employees, supervisors and managers; (2) undertake annual, documented training efforts to educate current and new employees about the SPRHRA Code standards and use of the SPRHRA grievance phone number.
DISCRIMINATION: Women and men workers shall be protected against discrimination on the basis of marital status. Pregnancy tests or the use of contraception shall not be used as a condition of hiring or continued employment.Women workers shall be protected against threats of dismissal or any other employment decision that negatively affects their employment status in order to prevent them from getting married or becoming pregnant. Equal opportunities for women and men shall be provided in all aspects of training and personal and professional development. Workers with family responsibilities shall be protected against discrimination with regard to dismissal (see ILO Convention No. 156).
WAGES AND BENEFITS: Fair and comparable wages, hours, and benefits are guaranteed to all workers for comparable work. Every worker, male or female, has a right to compensation for a regular workweek that is sufficient to meet the worker’s basic needs (such as food, water, housing, healthcare, education, transport, and clothing) and provides some discretionary income for the workers and their families. Women employees are entitled to maternity protection (leave and benefits as well as protection against discrimination) in accordance with the requirements of national laws and regulations or ILO Conventions Nos. 183, 103, and 3), whichever is higher. Childcare benefits and special leave or working time arrangements for workers with family responsibilities shall apply to both men and women.
FORCED LABOR: Migrant workers shall have exactly the same entitlements as local employees. Any commissions and other fees in connection with employment of migrant workers must be covered by the employer. The employer must not require the employee to submit his/her identification documents. Deposits are not allowed. Workers employed through an agent or contractor are the responsibility of the supplier and other business partners, and are thus covered by this Code. Practices that restrict workers’ freedom of movement or ability to terminate his or her employment are prohibited. Workers, both men and women, shall not be required to make deposits and/ or financial guarantees and their identity documents (such as passports, identity cards, etc.) shall not be retained.
WORKING HOURS: Policies for the calculation of basic wages, overtime, bonuses, and payroll deductions are the same for both men and women workers, and measures are taken to ensure that all personnel understand these policies. Piece-rate work shall not be exempted from the right to overtime compensation. The imposition of overtime where women or men workers are unable to leave the work premises or are in any way forced to accept it (through abuse, threats of dismissal, or other) is not allowed.
HARASSMENT AND ABUSE: All forms of violence and harassment in the workplace, including verbal, physical, sexual, or psychological abuse, are prohibited. Sexual harassment, including unwelcome sexual advances, unwanted hugs and touches, suggestive or lewd remarks, requests for sexual favors, or the display of indecent, derogatory, or pornographic pictures, posters, drawings, or videos, is prohibited. Sexual harassment in any form is not acceptable in the workplace or in any facilities related to the workplace, including transportation and dormitories. All workers are protected from retaliation for complaining about harassment. Security staff, doctors, nurses, managers, and other key personnel (where relevant) are regularly trained to recognize signs of gender-based violence and understand laws and organization policies on human trafficking and sexual exploitation.
HEALTH AND SAFETY: Access to basic healthcare services shall be ensured to workers in accordance with national law and international norms (including UDHR and CEDAW), recognizing gender differences and specifically facilitating services for migrants and their dependents who may face language or other social barriers to care. Reasonable actions should be taken (e.g., providing on-site clinics, a strong referral system, and external health providers) to ensure that workers have access to health services and insurance that serve the distinctive concerns and needs of women and men. On-the-job attention and accommodations shall be given to ensure that the reproductive rights of women—and men—workers are respected, which includes ensuring access to family planning products and services and care relating to pregnancy, maternity leave, and childcare. Feminine hygiene products also shall be available to women workers. Men and women workers engaged in working with hazardous materials will be informed of the potential risks to their reproductive health. To prevent unsafe exposure to hazardous chemicals and hazardous substances, appropriate accommodations shall be made for pregnant women. The number of toilets within a reasonable distance of the workplace required under applicable laws shall be provided. The number of toilets shall also take into consideration the number of workers, privacy for each individual and gender, accessibility, and hygiene. Undue restrictions shall not be imposed on the time and frequency of toilet use. Workplace policies and practices shall be established to ensure that women— and men—have the agency to take rest and water breaks and to take leave to see non emergency services from on-site or off-site health service providers when needed. Where doctors, nurses, or other health professionals are required on site, they shall be qualified not just to provide curative care for injuries, but also to address the broader health needs of men and women workers, including providing referrals to accessible, affordable, quality services off site. Flexible working arrangements and on-site facilities shall be offered to women who are pregnant or nursing. Women and men workers shall have access to childcare services.
CONTACT US: If suppliers are violating any of these Code elements, we would like to know about it. Please bring these issues to our attention by contacting us at the free phone number posted next to this Code or you can email us at firstname.lastname@example.org. Please feel free to write in your local language. All information we receive will be kept in strict confidence and your identity protected.
This code of conduct must be posted within the factory in a conspicuous, freely accessible area in the local language(s) of the employee.