CODE OF
CONDUCT
Ethics, consumer safety and anti-corruption policies
Kaporal requires its suppliers, subcontractors and commercial partners (hereinafter referred to as "Partners") to:
• comply with all domestic, EU and international rules governing ethics and responsible behaviour, including standards addressing human rights, environmental protection, sustainable development, corruption and child protection.• adopt, enforce and advance Kaporal's ethical standards and commitments.
Our commitment to Partners
Kaporal seeks to foster long-term relationships with its Partners and producers. It aims to create a strong working partnership and demonstrate responsible supply chain management through fair and ethical policies.Business conduct
In exercising due diligence and as part of their purchasing activity, all employees are required to notify Partners of Kaporal's commitment to upholding social, environmental and societal standards.Kaporal has robust procurement management and oversight methods in place for managing its Partner relationships.
All Partners who currently work with Kaporal, or would like to, may be audited by SGS or any other independent company for social and ethical issues.
Child labour
Kaporal does not use, and has zero tolerance for, child labour. Partners undertake to:
• Refrain from using Child Labour in the manufacture of Kaporal products,
• Refrain from employing Young Workers of school age during school hours,
• Refrain from employing Children or Young Workers during night-time hours or in dangerous
conditions.
The following definitions shall apply:
'Child' or 'Children'
Any individual aged under 15, unless local laws set a higher minimum age for work or mandatory schooling; in such cases, the higher age shall apply. If, however, local laws set the minimum age at 14 in accordance with developing-country exemptions under Convention 138 of the International Labour Organization (ILO), the lower age shall apply.'Young Worker'
Any worker aged under 18 and over the age of a Child as defined above.'Child Labour'
All work performed by a Child or Young Worker under the ages specified in the above definitions, which do not meet ILO standards, and all work that is potentially dangerous or could interfere with the education of a child or adolescent, or harm their health or physical, mental, spiritual or social development.Forced labour
Partners undertake to:
• Refrain from using, or encouraging the use of, forced or involuntary labour,
• Refrain from requiring employees to submit identity documents as a deposit as a condition for obtaining employment and ensure that employees are free to leave the company after giving reasonable notice,
• Treat employees with respect and dignity and refrain from oppressive management or any form of bullying (e.g. physical or mental bullying, sexual harassment).
Health and Safety
Partners undertake to:
• Provide a safe working environment in accordance with local health and safety legislation,
• Take all appropriate measures to prevent accidents and harm to health as a result of, or occurring in the course of, work, while keeping inherent workplace risks to a minimum,
• Facilitate employee access to first aid in case of emergency, administered by a designated individual with appropriate training, and to clearly mark emergency exits on a floor plan and conduct regular drills to prevent panic in the case of an incident.
Local community relations
Partners should ensure that the rights of the local community are respected, in particular with regard to the company's environmental and social impact in the region.
Discrimination
Partners must treat all workers equally and fairly and may not engage in any form of discrimination, in particular with regard to salary, recruitment, access to training, promotion, maternity protection or redundancy, based on sex, ethnicity, religion, age, disability, sexual orientation, political views, trade union membership, nationality, gender or social background.
Freedom of association
Partners must respect workers' freedom of association. Staff representatives must not suffer any form of discrimination or suspension of employment for exercising their rights as employees, voicing grievances, participating in trade union activities or reporting potentially illegal activity.
Salary and working hours
Salaries and working hours shall be set in line with international regulations, including ILO regulations and domestic legislation; the regulations most favourable to employees shall apply. Workers must be paid at the statutory minimum wage rate in force. Workers shall be free to work overtime as and when required. Paid leave must be granted in accordance with domestic and international law.
Environmental protection
Production sites shall comply with existing domestic environmental rules and regulations and work towards achieving ecological balance. Dangerous substances and wastewater may not be emitted without regard for environmental protection provisions. Water recycling is highly recommended. Partners must minimise their negative environmental impact and apply measures that contribute to environmental protection.Consumer safety - REACH - SVHCs
As set out in the "REACH tests" paragraph in the quality schedule, Kaporal only works with reputable partners who do not in any way compromise the safety of their workers, our workers, or our customers.
REACH (Registration, Evaluation, Authorization and Restriction of Chemicals EC 1907/2006) is the EU chemical products regulation that came into effect in June 2007. A section in these provisions relates to "Substances of Very High Concern (SVHCs)", as defined by the European Chemicals Agency.
The official list is available at http://echa.europa.eu/chem_data/candidate_list_table_en.asp.Article 33 of REACH ("Duty to communicate information on substances in articles") includes the requirement for "(a)ny supplier of an article containing a substance included on the list of SVHC products above 0.1 % weight by weight (w/w) shall provide the recipient of the article with sufficient information, available to the supplier, to allow safe use of the article including, as a minimum, the name of that substance."
Article 33 also states that "(o)n request by a consumer any supplier of an article containing an SVHC in a concentration above 0.1 % weight by weight (w/w) shall provide the consumer with sufficient information, available to the supplier, to allow safe use of the article including, as a minimum, the name of that substance. The relevant information shall be provided, free of charge, within 45 days of receipt of the request."
By virtue of this obligation to consumers under the REACH regulation, we must be notified about your REACH procedures for SVHCs contained in your products and packaging. We therefore require:
• The name of a contact person within your organisation (with telephone and email address) with responsibility for responding to REACH requests from consumers,
• Details of your REACH procedure for responding to consumers within 45 days,
Corruption
Kaporal operates its business in a transparent, honest and ethical manner. As such, it does not tolerate, nor make any allowance for, acts of corruption or misappropriation on the part of a Partner. Kaporal does not tolerate any form of irregular payments in the conduct of its business.
In particular, Kaporal prohibits the offering, giving, requesting or accepting of bribes (in cash or any other benefit) from any individual or company, in any location, regardless of whether such persons are civil servants or a public body, a private individual or a company, an agent or any other person or organisation acting on our behalf in order to obtain any unethical commercial, contractual or regulatory advantage or benefit, or for personal gain.
Orders for Kaporal-branded products may only be placed by Kaporal Collections, a company listed on the Marseille Trade and Companies Register under number 378 644 603, with a registered address at 20 Boulevard Ampère, Marseille, France. Financial transactions shall therefore only involve the aforementioned company.
We, Kaporal and its Partners, are committed to acting professionally, fairly and with integrity in all of our business relationships, wherever we do business, and use all means at our disposal to fight corruption and misappropriation of funds.
Kaporal seeks to actively minimise exposure to corruption, by ensuring that its Partners sign up to the Code of Conduct and comply with anti-corruption legislation.
By accepting an order from Kaporal, Partners agree to comply with such legislation and this Code of Conduct, and to adopt and promote an ethical and honest approach in their commercial relationship with Kaporal at all times.
Checks and audits
Partners must provide Kaporal with evidence of compliance when asked to do so. They must also notify Kaporal immediately where they become aware of a breach of their obligations in respect of the guidelines set out above.
Kaporal reserves the right to monitor compliance with these guidelines and carry out compliance audits on Partner sites. Partners must provide all necessary information and facilitate access for representatives carrying out compliance checks under this Code of Conduct. Partners undertake to improve on or rectify any shortcomings identified. Where non-compliance is found to occur, the supplier shall be notified immediately and subsequently issued a plan for improvement that must be implemented within the allotted time frame.