Labour Standards Modern Slavery & Ethical Trading

Gailarde Ltd is a trusted manufacturer and supplier of bedding, curtains, pillows, duvets, and associated items across the UK. We are committed to upholding the highest ethical and labour standards throughout our operations and supply chain. This document outlines our policy, aligned with legal requirements and ethical practices, and approved by our Directors.

Scope of the Policy

As part of our revision, we have combined the labour standards policy, modern slavery policy, and ethical trading policy into a more cohesive document to enhance the protection of workers’ rights within our own operations and supply chain.  

Gailarde Ltd. is committed to being a responsible employer and adheres to the codes of practice outlined in this policy. We ensure that all product sourcing complies with the Modern Slavery Act 2015 and the Human Rights Act 1998, monitoring ethical practices throughout the supply chain. To support this, we use the Modern Slavery Assessment Tool (MSAT) to assess risks both within our operations and among our suppliers. Recognising the importance of ethical cotton sourcing in the textile industry, we have implemented Gailarde’s Cotton Ethical Policy to reinforce our commitments.  

Suppliers must always comply with this policy, along with all relevant national and international laws, regulations, codes, and standards in both the country of operation and the country where products and services are sourced or provided. They must also ensure, as far as reasonably practicable, that their suppliers, agents, subcontractors, and consultants involved in providing goods or services to Gailarde Ltd. adhere to this code.  

We expect suppliers to uphold the effective recognition of the right to collective bargaining and freedom of association. Our labour standards policy aligns with the principles of the UN Global Compact.  

Compliance with this code is assessed annually. If non-conformances are identified, suppliers are issued a corrective action plan with a specific timeframe for resolution based on the severity of the issue. Suppliers must provide evidence that remedial actions are either in place or being implemented. Failure to demonstrate compliance may result in Gailarde Ltd. considering alternative supply arrangements.

Targets
We have implemented the following targets relating to labour standards to ensure we are doing our upmost best to continually improve and develop our practices and procedures to promote best practice in relation to labour standards:

• Zero confirmed incidents of bribery & Corruption
• 100% of Tier 1 suppliers covered by a social and environmental audit by 2030

Ethical Code
Employment Is Freely Chosen
• No forced, bonded or involuntary labour shall be used.
• Staff are not required to lodge deposits or identity papers with us.
• Staff are free to leave their role after reasonable notice.
• Staff have freedom of association

Working Conditions Are Safe And Hygienic
Adequate steps shall be taken to prevent accidents and injury to health arising out of, associated with, or occurring in the course of work by minimising, so fare is reasonably practicable, the causes of hazards inherent in the working environment.• Staff receive health & safety information.
• Staff have access to toilet facilities and drinking water.
• Workforce has a published Health & Safety Policy.

Child Labour Shall Not Be Used
• There shall be no recruitment of child labour.
• Children or persons under 16 are not employed at any time, day or night.
• Young persons under 18 shall not be employed at night or in hazardous conditions.

Living Wages Are Paid
• Staff rates are equal to or about the national legal minimum wage.
• Staff are giving information about their employment conditions in respect to wages.
• No deductions are made from wages as a disciplinary measure, and pay slips detailing lawful deductions are proved for each pay period.
• Staff are given clear understandable written terms and conditions of employment that details the employment relationship and the respective obligations of the employee and employer.

Working Hours Are Not Excessive
• Staff are not forced to work in excess of 48 hours per week, a voluntary opt-out agreement is available for those wishing to work in excess of 48 hours per week.

No Harsh or Inhumane Treatment Is Allowed
• Physical, verbal and sexual threats, abuse, harassment or intimidation is expressly prohibited and grounds for summary dismissal, if proved.

No Discrimination Is Practised
• There is no discrimination in pay, hiring, compensation, access to training, promotion, and termination of employment or retirement on the grounds of race, nationality, religion, age, disability, marital status, sexual orientation, union membership or political affiliation.
• Opportunities for personal and career development are equally available to all employees.

Monitoring
The following policies are monitored using the following procedures:
• We send out a supplier self-assessment questionnaire on an annual basis. The questionnaire asks specific question about how suppliers are implementing labour standards (copy available on request.) Once the completed form is returned, we then review the suppliers’ answers and if there are any non-conformances we contact the supplier to discuss the irregularities and confirm what steps are required to rectify any issues in writing.
• Once a non-conformity arises the supplier is given a specific timeframe based on the severity of the non-conformance to implement corrective action and provide evidence that the remedial work required is either in place or in is being implemented. If a supplier does not provide us with any evidence that the corrective action is being mitigated, then we will consider all options including finding an alternative supplier.
• Gailarde mitigates disruption risk by using multiple suppliers to ensure continuity of supply in cases a relationship is terminated. However, to date, all suppliers have met all our requirements. 

Modern Slavery Policy

Introduction

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which are the deprivation of a person’s liberty by another to exploit them for personal or commercial gain. We have a zerotolerance approach to modern slavery and Gailarde is committed to acting ethically and with integrity in all business dealings and relationships. It is our responsibility to implement and enforce efficient systems and controls to ensure modern slavery is not taking place anywhere in our own business or our supply chain. We are committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chain. We prohibit the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude.

We ensure that all product sourcing complies with the Modern Slavery Act 2015. Our Cotton Ethical Policy further ensures that all countries we work with meet our ethical sourcing standards.  

Suppliers must take all reasonable steps to ensure that their own suppliers, agents, subcontractors, and consultants who are involved in providing goods or services to Gailarde Ltd. comply with this code. We prohibit the use of worker-paid recruitment fees and the confiscation of workers original identification documents within our own operations and supply chain. We ensure all employees have freedom of movement and any victims of modern slavery have access to remedy, compensation, and justice. We expect that our suppliers will hold their suppliers to the same high standards. 

 

Responsibility  

To demonstrate our commitment, we complete the Modern Slavery Assessment Tool (MSAT) annually and require our suppliers to complete our supplier self-assessment questionnaire each year. This questionnaire is aligned with the MSAT to ensure consistency in monitoring compliance.  

Compliance  

The prevention, detection, and reporting of modern slavery in any part of our business is the responsibility of everyone working for or with us. Employees and partners must avoid any activity that could lead to or suggest a breach of this policy.  

If you believe or suspect that a conflict with this policy has occurred or may occur, you must notify your manager or a Director as soon as possible. Suspected breaches should also be reported in accordance with our Whistleblowing Policy.  

If you are unsure whether an act, the treatment of workers, or their working conditions within any tier of our supply chain constitute modern slavery, you should raise your concerns with your manager or a Director.  

We encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they are mistaken. We are committed to ensuring that no one faces any detrimental treatment as a result of reporting concerns about modern slavery. If you believe you have experienced such treatment, you should inform your manager immediately.

Communication and Awareness
Training on this policy, with the risk our business faces from modern slavery in the supply chain, will be given where needed.
Our zero-tolerance approach to modern slavery must be communicated to all suppliers from the outset of our business relationship with them and reinforced as appropriate thereafter.

Policy Breaches
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
If this policy is breached, we will consider all options including finding an alternative supplier. 

Ethical Trading Policy

We recognise the responsibility we share with our suppliers to source products ethically. We want our customers to be confident that the people who make our products are treated fairly, are not exploited, and are not exposed to unsafe working conditions. Our Ethical Trading Policy is a key part of our commitment to responsible buying and selling.  

Gailarde Ltd. conducts an annual assessment on modern slavery using the Modern Slavery Assessment Tool (MSAT) to identify risks. We also use a supplier self-assessment questionnaire to monitor sustainability performance, ensuring relevant questions align with the MSAT. This questionnaire helps us oversee all factories and suppliers to improve labour standards within the supply chain. Additionally, we hold ISO 14001 and 9001 certifications, which contribute to ethical trading and labour rights.  

Environment  

Gailarde is committed to the efficient use of natural resources and energy and to continuously improving the environmental impact of its operations and products through sustainable practices. These commitments are central to how we do business, and we encourage our suppliers to share this approach. We expect suppliers to implement effective policies, processes, and procedures to manage their environmental impact.  

Companies that supply Gailarde are encouraged to comply with all relevant laws, regulations, and industry best practices. This includes adhering to environmental laws related to chemical and waste management, disposal, recycling, industrial wastewater treatment, air emissions controls, environmental permits, and reporting. Suppliers should also have an Environmental Management System with written policies and processes that align with legal and industry standards.  

To reduce waste, suppliers should incorporate circular economy principles in product design by minimising material use, maximising recycled conten - particularly from post-consumer waste and ensuring products are easily recyclable at the end of their life cycle. Suppliers should also have policies in place to reduce and remove plastic and prioritise the use of recycled materials in packaging wherever possible.

Encourage biodiversity
• Make efforts to conserve natural resources in their operations and sourcing practices and engage in practices that encourage biodiversity.
Sustainable product design
• Assess the environmental impact of processes and products and establish objectives and targets to deliver continual improvement.
Water efficiency
• Have a policy that includes efficiency, preparation, use and disposal of water.

Governance and Responsibility

Our Company Director and Head of Sales and Sustainability oversee compliance with this policy. Senior management provides resources to maintain effective labour standards assurance and regularly monitors implementation.

Transparency and Accountability

This policy is shared with all employees, suppliers, customers, and stakeholders. Any breaches are addressed promptly to uphold the integrity of Gailarde Ltd’s operations and reputation.

Declaration & Sign off

Gailarde are committed to implementing all the above policies to help monitor and improve our labour standards throughout our operations and supply chain. We will also do our upmost best to source responsibly to help protect the environment to ensure we are operating in an ethical manner both in relation to labour standards and protecting the environment.

Signed: 

For further details, enquiries, or to report concerns, contact:
Richard Roston, Chairman
Email: office@gailarde.com
Phone: +44 2089 052 776