Ethical Code of Conduct

VERONA COLLECTION ETHICAL TRADING CODE OF CONDUCT


OUR COMMITMENT

The Verona Collection Ethical Trading Code of Conduct (the “Code of Conduct”) sets out standards for Verona Collection to uphold in relation to its own employees and for its supply chain partners to uphold in relation to their employees. With regards to supply chain, Verona Collection requires all those involved in its extended supply chain to agree to this code of conduct.

Verona Collection strongly believes it is important to operate a socially responsible business, promoting fair and sustainable employment practices internally as well as supporting diversity and equal opportunities in the workplace both within its own operations and across its supply chain. Verona Collection recognises that, within its supply chain, there are many different countries each with their own laws, cultures, norms and traditions, which Verona Collection acknowledges and respects. Some Associates will therefore face more complex issues than others in implementing the Policy. Verona Collection is committed to working with all relevant bodies to deliver effective action plans for change. Verona Collection believes that working closely with all Associates, Verona Collection will be able to strengthen and improve the quality of life for people who Verona Collection does works with. by working together with all Associates, Verona Collection can strengthen our business and improve the quality of life of the people who Verona Collection touch.

SCOPE OF POLICY

The Ethical Trading Code of Conduct is part of Verona Collection’s wider responsibility to safeguard the human rights of the people it works with, including but not limited to those working within its extended supply chain.

Through implementing this Code of Conduct in Verona Collection’s global supply chain, we are aware that human rights risks may be larger within groups of vulnerable workforces. Thus, tailored policies have been established to address the rights and needs of supply chain workers.

The Ethical Trading Code of Conduct exists to promote fair working conditions and the responsible management of social issues in the Verona Collection supply chain. All Associates are expected to establish and maintain a system to deliver compliance with the Verona Collection Ethical Trading Code of Conduct, which is designed to promote the protection of all workers throughout its supply chain and operations, including any workers employed by third party contractors and recruitment agencies.

DEFINITIONS

“Associates” refers to any individual, entity, business, company, partnership or any other body or group associated with Verona Collection including, without limitation, any such individual, company, entity, partnership or any other body or group supplying products, goods, raw materials, components, services, anything else, directly or indirectly, to any member of Verona Collection or otherwise working directly or indirectly with or on behalf of any member of Verona Collection.


“Verona Collection Associates” include, without limitation, the following

- finished goods vendors;
- raw material and/or component suppliers;

- persons or entities which carry out any processing on any goods directly or indirectly supplied to Verona Collection;

- construction contractors (and their construction sites);  

- consultants;

- contractors;
- all production sites of any Associate;

- wholesale customers

- service providers;

- any subcontractor of the above.

“Modern Slavery” encompasses any slavery, servitude, forced and compulsory labour and human trafficking or similar activity.

IMPLEMENTATION

∙ Associates shall enter into undertakings with Verona Collection from time to time, which include, amongst other things, terms of engagement on ethical trading, human rights and environmental issues.

∙ Verona Collection will provide assistance to the Associate in the implementation of the Ethical Trading Code of Conduct and may monitor such implementation using a variety of methods including audits and site visits to assess performance against the Ethical Trading Code of Conduct.

∙ Verona Collection is committed to working collaboratively with industry partners, government organisations, non-governmental organisations (NGOs) and trade unions to implement the Ethical Trading Code of Conduct effectively and use the most relevant techniques to assess policy adherence.

REPORTING AND REMEDY

∙ Verona Collection will report progress regularly.

∙ Verona Collection and its Associates will use reasonable means to offer workers and other stakeholders a confidential means to report any breaches of the Ethical Trading Code of Conduct.

AUDIT AND COMPLIANCE

∙ Tangible steps, such as the site inspection of Associate’s facilities, will be carried out to assess whether the standards set forth in the Ethical Trading Code of Conduct are being correctly implemented and complied with.

∙ Associates are expected to identify and correct any activities that conflict with the standard of the Ethical Trading Code of Conduct

∙ Where serious breaches of the Ethical Trading Code of Conduct persist, Verona Collection will consider termination of the business relationship with the Associate concerned.


ETHICAL TRADING CODE OF CONDUCT - STANDARD PROVISIONS

The standards below apply to all Verona Collection’s Associates and compliance is expected of every Associate.

1. EMPLOYMENT SHALL BE FREELY CHOSEN

I. Under no circumstances shall Verona Collection nor any Associate use or in any way benefit from any form of Modern Slavery including but not limited to, forced labour.

II. Workers are free to leave their employer after reasonable notice.


2. FREEDOM OF ASSOCIATION SHALL BE RESPECTED

I. Workers, without distinction, have the right to join or form trade unions of their own choice and to collectively bargain.

II. The employer adopts an open attitude towards the activities of trade unions and their activities.

III. Worker representatives are not discriminated against and have access to carry out their representative functions in the workplace.


3. WORKING CONDITIONS SHALL BE SAFE AND HYGIENIC

I. A safe and hygienic working environment shall be provided. Adequate steps shall be taken to prevent accidents and injury to health, by reducing, so far as is reasonably practical, the causes of hazards inherent in the working environment.

II. As a minimum, building, including structural, fire and electrical safety standards must be compliant with local laws and regulations.


III. Access to clean toilet facilities and to safe drinking water, and, if appropriate, clean facilities for food storage shall be provided.

IV. Accommodation, when are where provided, shall be clean, safe, and meet the basic needs of the workers..

4. CHILD LABOUR SHALL NOT BE USED

I. There shall be no child labour.

II. Young persons between 16 and 18 shall not be employed at night or in hazardous conditions.

III. Verona Collection and its Associates will always conform to relevant ILO standards.

5. LIVING WAGES SHALL BE PAID

I. Wages and benefits paid for a standard working week must meet, at a minimum, national legal standard. In any event wages should always be enough to meet basic needs and to provide some disposable income.

II. All workers shall be provided with clear, written information about their employment conditions in respect to wages before they commence their employment and about the particulars of their wages.

III. 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. All disciplinary measures should be recorded.

6. WORKING HOURS ARE NOT EXCESSIVE

I. Working hours must comply with national laws.

II. Working hours, excluding overtime, shall be defined by contract, and shall not exceed 48 hours per week.

III. All overtime must be voluntary. Overtime must be used responsibly, taking into account all the following: the extent, frequency and hours worked by individual workers and the workforce as a whole. It must not be used to replace regular employment.

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

∙ it is allowed by national law;
∙ it is allowed by a collective agreement freely negotiated with a workers’ organisation representing a significant portion of the workforce;
∙ appropriate measures are taken to protect the workers’ health and safety;
∙ the employer can demonstrate that exceptional circumstances apply e.g. unexpected production peaks, accidents or emergencies.

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

7.DISCRIMINATION SHALL NOT BE TOLERATED

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

International standards recommend the progressive reduction of normal hours of work, when appropriate, to 40 hours per week, without any reduction in workers’ wages as hours are reduced.

8. REGULAR EMPLOYMENT MUST BE PROVIDED

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


9. HARSH OR INHUMANE TREATMENT WILL NOT BE TOLERATED

I. Physical abuse as well as the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation shall be prohibited.

II. Associates will have a formal disciplinary and grievance appeal procedure with clear documented records of individual disciplinary hearings. Such procedures will support fair treatment of workers.

10. THE ENVIRONMENT SHALL BE PROTECTED

I. Associates shall carry out their activities in accordance with national laws, regulations, administrative practices and policies relating to the preservation of the environment of the countries in which they operate as well as in accordance with relevant international agreements, principles, objectives, responsibilities and standards with regard to the environment.

11. WORKERS SHALL HAVE LEGAL ENTITLEMENT TO WORK

I. Associates should only employ or use workers with a legal right to work in the country.

II. The Associate must validate, by reviewing original documents and then returning them to the workers, all workers’ and employment agency workers’ legal right to work.

III. Employment agencies can only supply workers registered with them.

12. SUB CONTRACTING AND HOME WORKING

I. Associates are not authorised to sub-contract any part of their business related to the production of goods or services they provide either directly or indirectly to Verona Collection without the prior written consent and approval of Verona Collection.

II. Similarly, sub-contractors are not authorised to sub-contract any part of their business related to the production of goods or services they provide either directly or indirectly to Verona Collection without the prior written consent and approval of Verona Collection.