CODE OF PRACTICE - 2 Sisters Food Group

CODE OF PRACTICE - 2 Sisters Food Group

Ethical Management Standard Ethical Trading & Human Rights April 2016 Document uncontrolled if printed The information contained in this document i...

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Ethical Management Standard Ethical Trading & Human Rights

April 2016

Document uncontrolled if printed

The information contained in this document is the property of the Company. The contents of this document cannot be reproduced or disclosed wholly or in part or used for the purposes other than that which it is supplied without prior written permission of the Company.

Contents Page No.

      



Foreword .................................................................................................. 2 Summary .................................................................................................. 2 Definitions ................................................................................................ 3 Policy Statement ...................................................................................... 4 Scope of Policy ........................................................................................ 4 Responsibility ........................................................................................... 4 2SFG Standards ...................................................................................... 4  4.1 Employment is Freely Chosen ............................................................. 4  4.2 Freedom of Association and Collective Bargaining .............................. 5  4.3 Safe & Hygienic Working Conditions ................................................... 5  4.4 Child Labour ........................................................................................ 5  4.5 Wages ................................................................................................. 5  4.6 Working Hours ..................................................................................... 5  4.7 Discrimination ...................................................................................... 6  4.8 Regular Employment ........................................................................... 6  4.7 No Harsh or Inhumane Treatment ....................................................... 6 Policy Revisions ....................................................................................... 6

Ref 2SFG ETH001

Issue No

Enquiries To

Authorised By

Date of Issue

Page No

V6.0

Gavin Dring

Chris Gilbert Wood

April 2016

Page 1 of 6

Foreword Robust ethical management is a fundamental of good business practices within the food industry. Growing legal, customer and societal expectations, reducing resources and increasing commodity costs are some of the challenges we face. In order to be a trusted supplier to retailers the Group must ensure it is effective in managing ethical impacts.

This Ethical Standard is intended to inform 2 Sisters Food Group (2SFG) sites of the minimum expectations placed on them for Ethical Trading and Human Rights based around the company’s objective to comply with the ETI Base Code. The Standard sets out a number of roles, which are not necessarily new or standalone duties, requiring decisions and actions from the site senior management.

The scope of this Ethical Standard does not currently include 2SFG sites based in Holland or Poland but should they wish to implement the Standard full support will be provided to help them to do so.

Summary The policy is not best practice or optional, but is a Standard to which all sites must comply.

Responsibility for implementing this policy lies with the senior person on a site, such as the Site Director or General Manager. The HR Lead provides support in key requirements.

The site is required to implement management systems which ensure compliance with the requirements across all parts of the operation ensuring compliance with the ETI Base Code.

Ref 2SFG ETH001

Issue No

Enquiries To

Authorised By

Date of Issue

Page No

V6.0

Gavin Dring

Chris Gilbert Wood

April 2016

Page 2 of 6

Definitions Wording

Definition

Divisional HR Leads

The senior HR person for a Division of 2 Sisters, which may be a HR Director, Head of HR or a Head of Learning and Development.

Young Worker

A person under 18 years of age.

Child

A child is anyone who has not yet reached the official minimum school leaving age (MSLA). Pupils will reach the MSLA in the school year in which they turn 16.

Child Labour

Work that harms, abuses and exploits a child or deprives a child of an education. It refers to working children below the age of completing compulsory education in the country of manufacture.

Ref 2SFG ETH001

Issue No

Enquiries To

Authorised By

Date of Issue

Page No

V6.0

Gavin Dring

Chris Gilbert Wood

April 2016

Page 3 of 6

1.0

Policy Statement

1.1

2 Sisters Food Group have adopted the Ethical Trading Initiative (ETI) Base Code to guide this Standard and create the confidence that the business is doing all it can to ensure that colleagues have fair and decent treatment with their human rights respected.

1.2

Where any potential impact is identified in relation to human rights the Company will investigate the issue and implement appropriate action to prevent it from becoming an actual issue. In these matters the Group Ethical Manager will be notified and through consultation with the relevant HR Director and/or Head of HR will agree a corrective action plan to negate the issue.

2.0

Scope of Policy

2.1

This Standard applies to all sites and offices within 2 Sisters Food Group and in particular to all staff that have a managerial or supervisory responsibility for staff and colleagues.

2.2

All our suppliers, agricultural partners and labour providers are required to work to this Standard via the 2SFG Supplier Sustainability Code of Practice and are expected to subscribe to SEDEX.

3.0

Responsibility

3.1

Implementation of this policy is the responsibility for Site Directors or General Managers with control of the operations on a single site.

3.2

Divisional HR Leads are responsible for ensuring that the policy is clearly communicated to the colleagues’ line management, local HR teams, trade union representatives and agency labour providers.

3.3

The Group Ethical Manager is responsible for supporting our production sites to comply with the Standard.

3.4

The Group Sustainability Manager is responsible for supporting our suppliers and agricultural partners comply with the Policy.

4.0

Our Standards

4.1

Employment is Freely Chosen We do not use and will not recruit child labour, prison or bonded labour or forced labour of any description. Employees are free to leave the company of their own accord at any time with the requisite contractual notice.

Ref 2SFG ETH001

Issue No

Enquiries To

Authorised By

Date of Issue

Page No

V6.0

Gavin Dring

Chris Gilbert Wood

April 2016

Page 4 of 6

4.2

Freedom of Association and Collective Bargaining All workers have the right to Freedom of Association and to join a trade union or other worker body for the purpose of consultation, negotiation, collective bargaining and representation. All workers will have access to raise concerns and get resolutions by either following the Company’s Grievance Procedure, using employee representatives or by using ‘Speak Up’, the Company confidential multilingual reporting line.

4.3

Safe and Hygienic Conditions All workers will have unrestricted access to decent standards of equipment and facilities whilst at work and their working conditions will be safe and hygienic. Workers will receive regular and appropriate health and safety training, both as part of their induction program and on an on-going basis to meet the standards set by the Health& Safety Leadership Team.

4.4

Child Labour We do not use and will not recruit child labour, prison or bonded labour or forced labour of any description. Young workers will be supported in the business and we will be compliant with all national legislation in relation to their employment. Young persons under 18 years of age are not allowed to work at night or in hazardous conditions. We expect our supply chain partners to adopt the same standards.

4.5

Wages We ensure equal access to jobs and equal pay for work of equal value. Pay for the standard contractual week at least meets the National Minimum Wage. The company will not levy any charge on an employee whether financial or otherwise for employment with the company and will not retain employee’s original documents. Overtime that is worked in excess of the base contractual week will be paid at a premium rate and will not be less than 1.25 per hour for hourly paid colleagues. All workers shall be provided with clear written information about their employment conditions in respect to wages before they join the business. All workers will receive written clear information about their wages for the pay period concerned each time that they are paid.

4.6

Working Hours Working hours will not be excessive; the maximum working week will be 60 hours. Overtime is voluntary and workers will not be required to regularly work in excess of 48 hours per week and will be provided with at least one day off for every 7 day period on average.

Ref 2SFG ETH001

Issue No

Enquiries To

Authorised By

Date of Issue

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V6.0

Gavin Dring

Chris Gilbert Wood

April 2016

Page 5 of 6

4.7

Discrimination We will ensure that our recruitment practices protect workers and give fair, consistent and equal treatment so that there is no discrimination in recruitment, pay or promotion decisions based on race, caste, national origin, religion, age, disability, gender, marital status, sexual orientation, union membership or political affiliation.

4.8

Regular Employment We will promote permanent employment wherever possible and work with our customers so that we can adopt a planned approach to the use of agency workers.

4.9

Harsh or Inhumane Treatment No harsh or inhumane treatment is allowed. Actual or threatened physical abuse or discipline, sexual or other harassment, or verbal abuse or any other form of intimidation or bullying are expressly prohibited and regarded as gross misconduct under the Company’s Disciplinary Policy.

5.0

Policy Revisions

Version Details

Date

1

09.03.2014

Version 1 Original Policy issued Contents and Index page reformatted.

2

08.04.2014 Section 4 Our Standards - paragraphs re-numbered Policy Title changed, Section 1 Policy Statement amended to include Human Rights, Section 3. Responsibility amended to include Group Sustainability Manager, Section 4.2 amended, Section 4.4 amended, Section 4.6 amended Policy Statement amended Issued signed by Chief Executive Officer Review of all content and reformatting.

3 4 5 6

Ref 2SFG ETH001

19.12.2014 19.12.2014 23.02.2015 March 2016

Issue No

Enquiries To

Authorised By

Date of Issue

Page No

V6.0

Gavin Dring

Chris Gilbert Wood

April 2016

Page 6 of 6