- This Code of Conduct is applicable to all suppliers of goods and services associated with Debenhams or any other company, wholly or partly owned, directly or indirectly, by Debenhams. Suppliers of goods applies to all suppliers, which include outsourced processes, Goods not for Resale suppliers, service providers and labour providers.
- As a fundamental part of our Supplier Code of Conduct, Debenhams respects International principles of Human Rights, including but not limited to those expressed in our Human Rights Policy, UN Declaration of Human Rights, United Nations Guiding Principles and those principles contained within the UK Government Modern Slavery Act 2015. The Principle Standards are drawn from the ILO core conventions and accompanying requirements are aligned to the ETI Base Code.
- Debenhams will only engage with reputable suppliers, factories and service providers to ensure that when our consumers purchase goods from Debenhams, they can be sure that they have been produced under acceptable conditions.
- Acceptable conditions means lawfully, through fair and honest dealing, without exploitation of the people employed within the factories and organisations who produce the products, which must at all times be, produced in decent working conditions and with consideration to the environment.
- The Code is designed to be ethical, achievable, auditable and applicable to all sourcing countries, to promote the on-going development of Debenhams™ sources of supply.
- Debenhams expects its suppliers to understand, take responsibility for ownership of implementing the Supplier Code of Conduct throughout their own supply chains and business operations.
- The Code is a statement of the minimum requirements, which must be met in order to trade with Debenhams.
- The provisions of the Code constitute minimum and not maximum standards, and the Code must not be used to prevent companies from exceeding these standards.
- Companies applying the Code are expected to comply with national and other applicable local laws and where the provisions of law and the Code address the same subject, to apply that provision which affords the greater protection. The provisions of the Code are not an exhaustive list.
Employment is freely chosen
- There is no forced, bonded or involuntary prison labour.
- Workers are not required to lodge “deposits” or their identity papers with their employer and are free to leave their employer after reasonable notice.
- Freedom of Association
- Workers, without distinction, have the right to join or form trade unions of their own choosing and to bargain collectively.
- The employer adopts an open attitude towards the activities of trade unions and their organisational activities.
- Workers representatives are not discriminated against and have access to carry out their representative functions in the workplace.
- Suppliers must have confidential procedures which allow worker representation for any issue concerning the labour standards referred to in the Code and which will enable protection for all workers and participation by workers who may be vulnerable, such as women and adolescents.
- Where the right to freedom of association and collective bargaining is restricted under law, the employer facilitates, and does not hinder, the development of parallel means for independent and free association and bargaining.
- Working Conditions are Safe and Hygienic
- A safe and hygienic working environment shall be provided, bearing in mind the prevailing knowledge of the industry and of any specific hazards. 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 far as is reasonably practicable, the causes of hazards inherent in the working environment.
- The company observing the Code shall assign responsibility for health and safety to a senior management representative.
- Workers, managers and those indirectly employed by the company, shall receive regular and recorded health and safety training, and such training shall be repeated for new or reassigned workers.
- Relevant first aid equipment must be available and stocked at the premises and where legally required, a doctor or nurse should be available during working hours.
- Access to clean toilet facilities, potable water and if appropriate, sanitary facilities for food storage shall be provided.
Building Structure Safety and Fire Safety
- All suppliers and business partners should make employees’ safety a priority at all times which includes building safety of the working environment as well as worker accommodation.
- Suppliers should ensure that all factories should have approved and valid building certification and government approved layout plans where applicable by law. Where this is not applicable, the plans should be approved by an independent certified structural engineering body.
- The factory must have adequate fire and emergency plans, frequent fire drills conducted at all work areas including canteens and dormitories.
- All exits must be kept clear and unlocked during working hours.
- Accommodation, where provided, shall be clean, safe and meet the basic needs of the workers. This means having a place to live that is adequately heated, ventilated, clean toilet facilities, access to safe drinking water, lockable storage and with a reasonable amount of personal space.
- Where dormitories or accommodation is provided, then this should be separated from the workplace and should have a separate entrance with evacuation plan and adequate firefighting equipment.
- Workers are free to leave the accommodation facility at any time without repercussion or penalties.
- Workers should not be locked in the accommodation at any time during the 24-hour day.
- Separate accommodation should be provided for male and female workers.
- For family housing, the factory should ensure that children staying within the accommodation should not enter the production facility.
- Employment of children
- Child labour shall not be used and there shall be no new recruitment of child labour.
- Companies shall develop or participate in and contribute to policies and programmes that provide for the transition of any child found to be performing Child labour. This will enable him or her to attend and remain in education until they reach adulthood.
- Children and young persons under 18 shall not be employed at night or in hazardous conditions.
- The policies and procedures relating to employment of children shall conform to the provisions of the relevant International Labour Organisation (ILO) standards.
The following are the definitions to be used for the above:
Child™: Any person less than 15 years of age unless local minimum age law stipulates a higher age for work or mandatory schooling, in which case the higher age shall apply.
Young Person™: Any worker over the age of a Child as defined above and under the age of 18.
Child Labour™: Any work by a Child or Young Person younger than the age(s) specified in the above definitions, which does not comply with the provisions of the relevant ILO standards, and any work that is likely to be hazardous or to interfere with the Child’s or Young Person’s education, or to be harmful to the Child’s or Young Person’s health or physical, mental, spiritual, moral or social development.
- Fair wages are paid
- Wages and benefits paid for a standard working week, within the legal working hours limit and meet a minimum national legal standards or industry benchmark standards, whichever is higher. In any event wages should always be enough to meet basic needs and to provide some discretionary income.
- All workers shall be provided with written and understandable information about their employment conditions in respect to wages before they enter employment and about the particulars of their wages for the pay period concerned each time they are paid.
- Deductions from wages such as disciplinary measures shall not be permitted nor shall any deductions from wages not provided for by national law be permitted without the expressed permission of the worker concerned.
- Working hours are not excessive
- Working hours comply with national laws and benchmark industry standards, which affords the greater protection to the workers.
- In any event, workers shall not on a regular basis be required to work in excess of 48 hours per week and shall be provided with at least one day off for every 7 day period or where allowed by national law, two days off in every 14 day period.
- Overtime shall be voluntary, not exceed 12 hours per week, shall not be demanded on a regular basis, appropriate safe guards are taken to protect the workers safety and shall always be compensated at the national premium rates.
- Disciplinary practices and Discrimination
- No harsh or inhumane treatment is allowed. Physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation shall be prohibited.
- There is no discrimination in hiring, compensation, access to training, promotion, termination or retirement based on race, caste, national origin, religion, age, disability, gender, marital status, sexual orientation, union membership or political affiliation.
- Regular employment is provided
- To every extent possible, work performed must be on the basis of recognised employment relationship established through national law and practice.
- Obligations to employees under labour or social security laws and regulations arising from the regular employment relationship shall not be avoided through the use of labour only contracting, home-working arrangements, or through apprenticeship schemes where there is no real intent to impart skills or provide regular employment, nor shall any such obligations be avoided through the excessive use of fixed-term contracts of employment.
- Migrant and temporary workers employed by the factory should have the same entitlements as permanent employees. The employer should cover any commissions and other fees in connection with local and overseas recruitment. The employer or employment agent must not retain any original identification papers and/or passports unless required by law.
Modern Slavery Act
- The Modern Slavery Act was introduced in March 2015 to combat slavery and human trafficking. Debenhams Prohibits and has a zero tolerance to all forms modern slavery throughout our global organisation, operations and supply chains. The term Modern Slavery is used to encapsulate slavery, servitude, child labour, forced compulsory labour as well as human trafficking.
- You must at all times comply with our Human Rights Policy and all applicable law and regulation regarding slavery, human trafficking and compulsory labour practices, including the Modern Slavery Act and maintain a complete set of records to trace the supply chain of all goods and services provided.
- You will operate with us on the basis of full transparency in this regard, declaring to us immediately if you become aware of or have reason to suspect there are any forms of human rights abuses in your supply chain and using reasonable endeavours to assist us with any audit or investigation we undertake with regard to slavery or our reporting requirements under applicable law and regulation.
- Labour Providers
- Where suppliers and or factories make use of labour providers (employment agencies/ labour contractors) in their supply chain, they shall be fully transparent and apply due diligence to meet the provisions of this code to comply with the national and all other applicable local laws.
- Suppliers should apply their own appropriate due diligence to ascertain the employment conditions of the workers. The use of labour providers should not be used to avoid payment of fair wages and other benefits given to permanent workers or required by law.
- Suppliers are encouraged to offer continuity of service and security of employment to workers.
Monitoring, Inspection and Assessment
Debenhams expects all suppliers, service providers and other business partners to be transparent at all times. All suppliers should have detailed information of where the products are being produced, including subcontracting and homework and should regularly monitor and conduct audits on their supply base with relevant documentation.
Senior management of suppliers must be appointed with responsibility for ensuring that:
- All their component, raw material suppliers and outsourcing contractors are aware of and shall comply with this Code.
- Records shall be kept as evidence that notification of this Code has been shared throughout the supply chain, and regular reviews and auditing has been undertaken.
Debenhams own brand suppliers should ensure that factories are approved as per Debenhams Conditions of Trading prior to the production of goods and services. In such cases, access to the factory premises shall be permitted to Debenhams staff and their representatives for the purpose of monitoring, inspecting and auditing the implementation of the Code at all times, announced or unannounced.
- Subcontracting is not permitted and is defined as the manufacturing of product in an unknown unapproved factory.
- The use of a non-approved factory is in breach of the Supplier Code of Conduct and Conditions of Trading.
- All purchase orders must be raised to the correct approved Factory at all times.
- For production purposes if an existing supplier requires more factories, then they need to follow the new Factory Approval Process, after Strategic Approval has been given.
- Factories used for the out-sourcing of ancillary components of the goods are acceptable for processes which are not part of the main manufacturing process, these include: hand embroidery, printing, dying/finishing (i.e. mills), laundries, sub-component suppliers e.g. zips, electrical components. These outsourced facilities must at all times be compliant with our Environmental & Chemical Policy.
- All of these outsourced facilities must be declared to the third party audit company and Debenhams at all times, by recording in the factory compliance Workbook.
- Suppliers, contractors and subcontractors must disclose to Debenhams if they use homeworkers as a part of their manufacturing process.
- Homeworkers must not be subject to forced or bonded labour. Children of homeworkers may not be hired or contracted to perform work.
- Homeworkers should be promptly paid rates equivalent to or greater than the minimum wage defined in national legislation or industry benchmark standards, whichever is higher, for all work carried out. Homeworkers should be made aware of the hazards of excessive work.
- Homeworkers should enjoy social security benefits, holiday/maternity pay, and other benefits comparable to other workers, even where these are not a statutory requirement.
- Suppliers must manage all waste that they generate in accordance with local laws or in such a way as to avoid harm to the environment or the local population.
Suppliers must comply Debenhams Environmental policies.
The Code of Conduct has been drawn up with reference to the International Labour Organisation Conventions and Recommendations, Modern Slavery Act 2015 and ETI (Ethical Trading Initiative) Base Code.
ILOC 1 Hours of Work (Industry) Convention, 1919
ILOC 26 Minimum Wage-Fixing Machinery Convention, 1928
ILOC 29 Forced labour Convention, 1930
ILOR 85 Protection of Wages Recommendation, 1949
ILOR 87 Freedom of Association & protection of the Right to Organise Convention 1948
ILOC 95 Protection of Wages Convention, 1949
ILOC 98 Right to Organise and Collective Bargaining Convention, 1949
ILOC 100 Equal Remuneration Convention, 1951
ILOC 105 Abolition of Forced Labour Convention, 1957
ILOC 111 Discrimination (Employment and Occupation) Convention, 1958
ILOC 131 Minimum Wage Fixing Convention, 1970
ILOC 138 Minimum Age Convention, 1973
ILOR 146 Minimum Age Recommendation, 1973
ILOC 155 Occupational Safety and Health Convention, 1981
ILOR 164 Occupational Safety and Health Recommendation, 1981
ILOC 181 Private Employment Agencies Convention, 1997
Article 32 N Convention on the Rights of a Child
ETI Base Code Base Code is founded on the conventions of the International Labour Organisation (ILO) and is an internationally recognised code of labour practice.
The Modern Slavery Act 2015 (Transparency in Supply Chains) Regulations 2015