Labour Standards Policy

Gailarde Ltd. is committed to ensuring that it is a responsible employer and works under within the codes of practice as laid within this policy. Gailarde ensures all its product sourcing complies with the Modern Slavery Act 2015 and we monitor this to ensure ethical practices throughout the supply chain are employed. The framework in place is that within the Labour Standards Assurance System (LSAS Level 3).

Within the textile industry ethical cotton sourcing is of the upmost importance. Gailarde Cotton Ethical Policy is in place to highlight our commitments to this cause. Suppliers shall always comply with this policy and with all applicable and national and international laws, regulations, codes and standards, both in the country in which the supplier works, and in the country in which the product and/or services are sourced/provided. Suppliers shall ensure, as far as is reasonably practicable, that their suppliers, agent(s), subcontractors and consultants, who are directly or indirectly involved in the provisions of goods and/or services to Gailarde Limited comply with this code.

MODERN SLAVERY
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 zero-tolerance 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. Our overseas audits support this.

We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chain. We expect the same high standards from all our suppliers. We prohibit the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude and we expect that our suppliers will hold their suppliers to the same high standards.

Code of Practice
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.
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 above the national legal minimum wage.
• Staff are given 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.

RESPONSIBILITY
Our Company Director and Head of Sales and Sustainability has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those associated with Gailarde comply with it.

COMPLIANCE

The prevention, detention and reporting of modern slavery, in any part of our business, is the responsibility of all those working for us or with us. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

You must notify your Manager or Director responsible for sustainability as soon as possible, if you believe or suspect, that a conflict with this policy has occurred, or may occur in the future. If you believe or suspect a breach of this policy has occurred or that it may occur, you must notify your manager or report it in accordance with our Whistleblowing procedure (below) as soon as possible. If you are unsure about whether an act, the treatment of workers in general, or their working conditions within any tier of our supply chain constitutes any of the various forms of modern slavery, raise it with your Manager or the Compliance Officer.

We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting, in good faith, their suspicion that modern slavery, in any form, is or may be taking place in any part of our business or in any part of our supply chain. If you believe that you have suffered any such treatment, you should inform your Manager immediately.

Communication and Awareness of Policy
Training on this policy, and 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.

Breaches of this Policy
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

ETHICAL TRADING
We recognise the responsibility that we share with our suppliers to source products in an ethical manner. 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 is a core element of our commitment to buy and sell our products responsibly.

Code of Practices
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.
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.
No Harsh or Inhumane Treatment Is Allowed
• Physical, verbal and/or sexual threats, abuse, harassment, or intimidation is expressly prohibited.

Monitoring
A senior member of the Gailarde team and a local representative of Gailarde visit each site at a minimum of once per year. In addition, every six months a questionnaire is sent to each of our suppliers asking specific questions about their compliance with regards to quality and labour standards (copy available on request). Once the completed form is returned, or after an in-person visit, we then review and if there are any non-conformities, 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 two weeks to implement corrective action and provide evidence that the remedial work required is either in place or a time frame is given for completion. After two weeks if they are still not compliant Gailarde would cease trading with them until they have complied or are demonstrating adequate steps to comply. We mitigate any risk by ensuring we have multiple suppliers available to fulfil our demands.

GAILARDE COTTON ETHICAL POLICY
Within our supply chain, we do not own the companies or factories that produce our goods, but we recognise our responsibility for the workers in those factories to ensure that our products are made in good working conditions. Most of our products are sourced from countries overseas such as China, Pakistan, and India.

Suppliers need to apply the Code of Practices to their own suppliers in all levels of production and must ensure that they do not knowingly source materials for use in Gailarde products that are made using forced or trafficked labour. We also require mandatory disclosure of all cotton and the country of origin and volume of these raw materials used in our products. This information is used to ascertain risk in relation to issues including forced labour in specific commodities such as cotton. Undisclosed sub-contracting, where approved factories send our products for manufacture to unapproved factories without specific consent and approval, is expressly prohibited and constitutes a breach of our Code of Conduct and General Terms and Conditions of Business. Workers in such unapproved sites can be more at risk of exploitation, and for this reason, we take any breaches extremely seriously and will not trade with them.

Uzbekistan is the fifth largest exporter of cotton worldwide. The cotton campaign, Responsible Sourcing Network and other watchdogs have long claimed that the government of Uzbekistan uses forced labour on an industry-wide scale. In 2015 the Uzbek government permitted the ILO to conduct monitoring of forced and child labour during the cotton harvest. Findings pointed to government-sponsored forced labour. We are committed to the Cotton Pledge, committing to not knowingly source Uzbek cotton for the manufacturing of any of our products until the Government of Uzbekistan ends the practice of forced child and adult labour in its cotton sector. In 2016 this ban was also extended to Turkmenistan. None of our products are sourced from these countries.

As a company all our cotton is completely traceable, which is key to our cotton policy. Our factory provides high-quality cotton seeds to farmers to encourage better practices in cultivating cotton. The aim is to develop greater awareness of the environment whilst still helping the farmers cultivate good quality cotton with better yields. Our factory has developed a partnership with the best producer of cotton seeds in the world. The combination of the factory stitching unit with NSL Group seeds truly means that we can follow our goods from bud to bedding.

This accountability is also key to protecting workers rights within the cotton industry.

Whistleblowers can contact Gailarde Chairman, Richard Roston, in total confidence via
office@gailarde.com, or +44 2089 052 776