Ethical Policy

Introduction
Schottlander has created an Ethical Policy in order to ensure that both its organisation and its suppliers conduct their business in accordance with Industry and internationally approved Standards of good ethical, employment and environmental practice. This includes adherence to the Ten Principles of the Global Compact and the occupational health and safety requirements of the International Labour Organisation’s (ILO) Code of Practice, and compliance with the Modern Slavery Act 2015. The Ethical Policy is designed to ensure that Schottlander, its partners and its suppliers operate within the principles and guidelines as laid down in the Policy.

The procedures contained in this document ensure that Schottlander operates best practice in the application of the Policy and ensures that Schottlander abides by its core principles.


Schottlander Code of Ethical Conduct
Schottlander is committed to the manufacture and supply of safe, legal products that meet or exceed statutory and customer requirements and that it conducts its business according to the standards of good ethical, employment and environmental practice contained in this policy. Schottlander expects its suppliers and partners to operate on the same principles. Specifically, Schottlander expects its suppliers (and their sub contractors) to observe best practice and continuing improvement in the fields set out below, and in any other areas notified by Schottlander from time to time.


Scope of Application
This code is to be applied within Schottlander and to direct suppliers, who in turn will be required to supervise their suppliers and sub contractors in the same terms. Schottlander accepts that it may be difficult to exert control or influence over small volume or short term suppliers but will take all reasonable steps to ensure compliance within this part of the supply base.

Where Schottlander deals with large company suppliers (over which it cannot reasonably exert control or influence) which operate their own Social Codes of Conduct, Schottlander will expect those companies to demonstrate the conformance of their supply base to the company’s code. Schottlander does not expect companies’ codes to apply outside their  own scope of reasonable control and influence.


Compliance to the Modern Slavery Act 2015
Schottlander requires that its suppliers confirm their full compliance to its Modern Slavery Statement and Modern Slavery Policy, as well as their full compliance to the Modern Slavery Act 2015. In line with these requirements, they agree to confirm this compliance in writing, to regular risk assessments and information exchanges on issues of modern slavery and human trafficking, and to cooperate with on-site inspections and third party audits as such as Schottlander deems necessary to confirm this compliance.


1. Employment of Appropriate Workers
a) Schottlander requires that no forced, bonded or involuntary prison labour be used to produce goods, wholly or in part.
b) No worker shall be employed under the minimum age established by local law or the age at which compulsory schooling ends in the country, whichever is the greater. In any event, children under fifteen, or the minimum working age according to International Labour Organisation (ILO) exemptions (under Convention 138), shall not be recruited or employed.


2. General Employment Practices 
Schottlander requires that:
a) There is compliance with local legislation regulating employment and working conditions.
b) Employee working hours comply with local legislation and standards. In addition overtime shall always be voluntary and shall not be demanded on a regular basis. Each employee is allowed regular rest periods.
c) Part-time or temporary employment complies with local legislation.
d) Employees are paid in accordance with local legislation, specifically including any minimum wage, allowances and benefits. All overtime worked shall be paid at premium rates.
e) Employees are paid in accordance with local legislation, specifically including any minimum wage, allowances and benefits. All overtime worked shall be paid at premium rates.
f) All local legislation for sick leave, child care, emergency leave, pregnancy leave, holiday leave and statutory holidays and any similar issues are observed.

3. Working Environment
Schottlander believes that products should be manufactured in a safe, hygienic working environment. It therefore requires that the working conditions in places of work comply with the following standards:
a) All national and local health & safety laws and all of the relevant requirements of ILO convention 155. Where the organisation subscribes to other codes of practice or standards on Health & Safety, these shall also be met.
b) Assigning of a senior management representative to be responsible for health and safety issues.
c) Establishment of a Health and Safety Committee on which local management, workers and/or their organisations must be represented.
d) Written health and safety policies shall apply to all work places.
e) No employees shall be subjected to unhealthy or unsafe working conditions and all necessary safety equipment (including personal protective equipment) should be provided free of charge. Fire exits shall be adequate and well identified.
f) Young people under 18 shall not be expected to work at night or under potentially hazardous conditions.
g) No one shall be employed in potentially hazardous conditions without receiving adequate safety training and supervision. First aid training should be provided to nominated First Aiders. A First Aider should be available at all times.
h) Provision for all personnel of clean bathrooms, access to potable water, and, if appropriate, sanitary food storage facilities.
i) Where appropriate, employees’ living quarters, and food and clothing allowance should be of a standard comparable to that provided by employers locally.


4. Respect for the Individual Worker
Schottlander requires compliance with management practices which recognise the dignity of the individual and the right to a workplace free of harassment, abuse and corporal punishment. The company shall not allow behaviour including gestures, language and physical contact that is sexually coercive, threatening or exploitative.

Disciplinary practices shall be clearly set out and communicated to workers. They shall not involve the use of corporal punishment, mental or physical coercion and verbal abuse. Workers shall have the right of appeal and representation at disciplinary hearings.


5. Environmental Standards
a) Compliance with all relevant environmental standards and legislation requirements.
b) Schottlander is committed to sound environmental practices: it will therefore select suppliers dedicated to making continuous efforts to reduce the impact of their operations on the environment.


6. Ethical Standards
Schottlander requires all its suppliers and partners to conduct their businesses in an ethical manner. All suppliers & partners must provide Safe, Legal goods or services that fulfil statutory requirements. No contract will be entered into with any supplier or partner engaged in bribery, kickbacks or the provision of gifts, favours or services to gain a competitive advantage with Schottlander or any third party.


7. Equal Opportunities
Schottlander operates an equal opportunities policy. All suppliers must confirm that they do not discriminate in hiring, salary, benefits, advancement, provision of training, termination or retirement (or otherwise interfere with the rights of individuals to observe tenets or practices, or to meet their needs) on the basis of gender, race, religion, caste, age, sexual orientation, disability, union membership, political affiliation, or national or ethnic origin.


8. Breach of these conditions
a) All suppliers and sub contractors are expected to achieve compliance with this code within a reasonable timeframe as agreed by Schottlander.
b) It is recognised that observance of some provisions of the code may not be immediately realisable in some cases. Some suppliers may not be able to meet all requirements within a short time and in some cases they may be constrained by national law. Reasonable timeframes and the existence of any constraints not controllable by the supplier may be taken into account by Schottlander when evaluating compliance. Failure to apply rapid corrective action with respect to certain standards (such as, but not necessarily limited to, the use of forced, bonded or involuntary prison labour, the use of physical abuse or discipline and intimidation) will result in immediate termination of the contract.
c) Where compliance is not achieved, Schottlander will no longer continue to place business with this supplier.


9 . Responsibility Documentation and Inspection
a) All suppliers are expected to maintain on file such documentation as may be needed to demonstrate compliance with the requirements of this Code of Conduct.
b) Schottlander may conduct audits regularly at all facilities used to produce its components, including the facilities of sub-contractors, to determine whether the requirements set out above have been met.
c) A named Senior Manager (a member of the board or equivalent) shall be given responsibility for ensuring that these requirements are understood and complied with.


Supplier Compliance to Schottlander Ethical Policy
If Schottlander determines that at any time that a supplier has failed to comply with any of the supplier requirements within Schottlander’s Ethical Policy, Schottlander reserves the right to cease purchasing products and services from that supplier without liability or obligation of any sort.


Brian Schottlander, Managing Director.
Revised: 8th September 2024