Code of Conduct
At Actona Group we have a very clear position on environment, ethics and product safety, which also are the key areas in our Code of Conduct.
If it is noted and documented that our criteria for cooperation are deliberately violated, Actona Group will take immediate action. If no solution can be agreed upon and implemented within a reasonable period, withdrawal of orders and a future ban of the supplier in question are potential consequences.
Actona Group is furthermore a member of the Business Social Compliance Initiative (BSCI). Briefly, this means that we align with BSCI's Code of Conduct, which aims to attain compliance with certain social and environmental standards.
The BSCI Code of Conduct refers to international conventions:
- Universal Declaration of Human Rights
- Children’s Rights and Business Principles
- UN Guiding Principles on Business and Human Rights
- OECD Guidelines
- UN Global Compact
- ILO Conventions
The Rights of Freedom of Association and Collective Bargaining
- Respect the right of workers to form unions in a free and democratic way
- Not discriminate against workers because of trade union membership
- Respect workers’ right to bargain collectively
Suppliers shall furthermore not prevent workers’ representatives from having access to workers in the workplace or from interacting with them.
When operating in countries where trade union activity is unlawful or where free and democratic trade union activity is not allowed, suppliers shall respect this principle by allowing workers to freely elect their own representatives with whom the company can enter into dialogue about workplace issues.
Suppliers shall not discriminate, exclude, or have a certain preference for people based on gender, age, religion, race, caste, birth, social background, disability, ethnic and national origin, nationality, membership in unions or other legitimate organizations, political affiliation or opinions, sexual orientation, family responsibilities, marital status, diseases or any other condition that could give rise to discrimination. In particular, workers shall not be harassed or disciplined on any of the abovementioned grounds.
Suppliers observe this principle when respecting the rights of the workers to receive fair remuneration sufficient to provide them with a decent living for themselves and their families, as well as the social benefits legally granted, without prejudice to the specific expectations set out hereunder.
Suppliers shall as a minimum comply with wages mandated by governments’ minimum wage legislation or industry standards approved on the basis of collective bargaining, whichever is higher.
Wages are to be paid in a timely manner, regularly, and fully in legal tender. Partial payment in the form of allowance “in kind” is accepted in line with ILO specifications. The level of wages is to reflect the skills and education of workers and shall refer to regular working hours.
Deductions will be permitted only under the conditions and to the extent prescribed by law or fixed by collective agreement.
Decent Working Hours
Suppliers observe this principle when they ensure that workers are not required to work more than 48 regular hours per week, without prejudice to the specific expectations set out hereunder. However, the BSCI recognizes the exceptions specified by the ILO.
Applicable national laws, industry benchmark standards, or collective agreements are to be interpreted within the international framework set out by the ILO.
In exceptional cases defined by the ILO, the limit of working hours prescribed above may be exceeded, in which case overtime is permitted.
The use of overtime is meant to be exceptional, voluntary, paid at a premium rate of no less than one and one-quarter times the regular rate and shall not represent a significantly higher likelihood of occupational hazards. Furthermore, suppliers shall grant their workers with the right to resting breaks every working day and the right to have minimum one day off every seven days, unless exceptions defined by collective agreements apply.
Occupational Health and Safety
Suppliers observe this principle when they respect the right to healthy working and living conditions of workers and local communities, without prejudice to the specific expectations set out hereunder. Vulnerable individuals such as - but not limited to - young workers, new and expecting mothers and people with disabilities, shall receive special protection.
Suppliers shall comply with occupational health and safety regulations or with international standards where domestic legislation is weak or poorly enforced.
The active co-operation between management and workers, and/or their representatives is essential in order to develop and implement systems towards ensuring a safe and healthy work environment. This may be achieved through the establishment of Occupational Health and Safety Committees.
Suppliers shall ensure that there are systems in place to detect, assess, avoid, and respond to potential threats to the health and safety of workers. They shall take effective measures to prevent workers from having accidents, injuries, or illnesses arising from, associated with, or occurring during work. These measures should so far reasonable aim at minimizing the causes of hazards inherent within the workplace.
Suppliers shall seek improving workers protection in case of an accident, including through compulsory insurance schemes.
Suppliers shall take all appropriate measures within their sphere of influence to ensure the stability and safety of the equipment and buildings they use. This includes residential facilities to workers, when these are provided by the employer as well as to protect against any foreseeable emergency.
Suppliers shall respect the workers’ right to exit the premises from imminent danger without seeking permission.
Suppliers shall ensure adequate occupational medical assistance and related facilities.
Suppliers shall ensure access to drinking water, safe and clean eating and resting areas, as well as clean and safe cooking and food storage areas. Furthermore, suppliers shall always provide effective Personal Protective Equipment (PPE) to all workers free of charge.
No Child Labour
Suppliers observe this principle when they do not employ, directly or indirectly, children below the minimum age of completion of compulsory schooling as defined by law, which shall not be less than 15 years, unless the exceptions recognized by the ILO apply.
Suppliers must establish dependable age-verification mechanisms as part of the recruitment process, which may not be in any way degrading or disrespectful to the worker. This principle aims to protect children from any form of exploitation. Special care is to be taken on the occasion of the dismissal of children, as they can move into more hazardous employment such as prostitution or drug trafficking. In removing children from the workplace, suppliers should in a proactive manner identify measures to ensure the protection of affected children. When appropriate, they shall pursue the possibility to provide decent work for adult household members of the affected children’s family.
Special Protection for Young Workers
Suppliers observe this principle when they ensure that young people do not work at night and that they are protected against conditions of work which is prejudicial to their health, safety, morals, and development, without prejudice to the specific expectations set out in this principle.
Where young workers are employed, suppliers should ensure that (a) the kind of work is not likely to be harmful to their health or development; (b) their working hours do not prejudice their school attendance, their participation in vocational orientation approved by the competent authority, or their capacity to benefit from training or instruction programs.
Suppliers shall establish the necessary mechanisms to prevent, identify, and mitigate harm to young workers with special attention to the access young workers shall have to effective grievance mechanisms and to Occupational Health and Safety training schemes and programs.
No Precarious Employment
Suppliers observe this principle when, without prejudice to the specific expectations set out in this chapter, (a) they ensure that their employment relationships do not cause insecurity and social or economic vulnerability for their workers; (b) work is performed on the basis of a recognized and documented employment relationship, established in compliance with national legislation, custom or practice and international labour standards, whichever provides greater protection.
Before entering into employment, suppliers are to provide workers with understandable information about their rights, responsibilities and employment conditions, including working hours, remuneration and terms of payment.
Suppliers should aim at providing decent working conditions that also support workers, both male and female, in their roles as parents or caregivers, especially with regard to migrant and seasonal workers whose children may be left in the migrants’ hometowns.
Suppliers shall not use employment arrangements in a way that deliberately does not correspond to the genuine purpose of the law. This includes, but is not limited to, (a) apprenticeship schemes where there is no intent to impart skills or provide regular employment, (b) seasonality or contingency work when used to undermine workers’ protection, and (c) labour-only contracting. Furthermore, the use of sub-contracting may not serve to undermine the rights of workers.
No Bonded Labour
Suppliers shall not engage in any form of servitude, forced, bonded, indentured, trafficked or non-voluntary labour.
Suppliers will risk allegations of complicity if they benefit from the use of such forms of labour by their suppliers.
Suppliers shall act with special diligence when engaging and recruiting migrant workers both directly and indirectly.
Suppliers shall allow their workers the right to leave work and freely terminate their employment provided that workers give reasonable notice to the employer.
Suppliers shall ensure that workers are not subject to inhumane or degrading treatment, corporal punishment, mental or physical coercion, and/or verbal abuse.
All disciplinary procedures must be established in writing and are to be explained verbally to workers in clear and understandable terms.
Protection of the Environment
Suppliers observe this principle when they take the necessary measures to avoid environmental degradation, without prejudice to the specific expectations set out in this chapter.
Suppliers should assess significant environmental impact of operations and establish effective policies and procedures that reflect their environmental responsibility. They will see to implement adequate measures to prevent or minimize adverse effects on the community, natural resources, and the overall environment.
Ethical Business Behaviour
Suppliers observe this principle when, and without prejudice to the goals and expectations set out in this chapter, they are not involved in any act of corruption, extortion or embezzlement, or any form of bribery. This includes, but does not confine to, the promising, offering, giving or accepting of any improper monetary or other incentive.
Actona Group has a zero-tolerance approach towards bribery and corruption and is committed to act professionally in all of its business dealings and relationships. Actona Group’s anti-bribery policy reflects our commitment to uphold all laws relevant to countering bribery and corruption. In particular, Actona Group and third parties acting on behalf of Actona Group, i.e. suppliers, distributors, officials etc., are committed to comply with the UK Bribery Act 2010.
Suppliers are expected to keep accurate information regarding their activities, structure and performance, and should disclose these in accordance with applicable regulations and industry benchmark practices.
Suppliers should neither participate in falsifying such information, nor in any act of misrepresentation in the supply chain.
Furthermore, they should collect, use and otherwise process personal information (including that from workers, suppliers, customers and consumers in their sphere of influence) with reasonable care. The collection; use and other processing of personal information is to comply with privacy and information security laws and regulatory requirements.
Consequences of Non-Compliance
Actona Group reserves the right to audit suppliers in order to ensure that they can verify that they live up to the requirements set by Actona Group’s Code of Conduct, and that they have correct due diligence processes in place in order to ensure compliance from subcontractors.
If a supplier fails to meet the requirements of the Actona Group Code of Conduct, and if no solutions can be agreed upon and implemented within a reasonable amount of time, Actona Group may choose to halt current production, cancel corresponding contracts, suspend future contracts and/or terminate the business relationship with the non-conforming supplier.