1. Introduction

Within business carried out by Devold we are committed to be socially and environmentally responsible for all our actions. We have this responsibility towards all our customers who buy our products and to our suppliers who take part in the production or distribution of our products.

Based on our commitment we have set up the Devold Code of Conduct to make our position clear for all our suppliers, and for our own staff. Our Code of Conduct contains labor and environment requirements, as well as other ethical requirements, which accord with provisions in international conventions and instruments, such as the ILO Core Conventions.

In many cases the Code requirements are the same as provisions specified in National laws and regulations. Should the provisions of national law and the requirement of our Code of conduct differ, the highest standard shall always apply.

The requirements of our Code of Conduct are non-negotiable and shall be complied with by our suppliers, and their subcontractors, through all their activities. Yet, we stress that we will not terminate business in case of non-compliances. If non-compliances occur, we expect corrective actions to be taken within a reasonable time frame agreed upon between the supplier and Devold.

Only after repeated failure or unwillingness to carry out corrective actions, may business with the supplier be terminated. Also, when placing new orders, the level of compliance with our Code of Conduct and willingness to make improvements will be an important criterion in our selection of suppliers. The principle aim of our Code of Conduct is to help improve the social and environmental conditions of our suppliers.

Supplier is any party we have contracted with and who is responsible for a product, process or service supplied to Devold.

Subcontractor is a business entity in the supply chain directly or indirectly providing the supplier with goods and/or services integral to and utilized in/for the production of the supplier’s goods and/or services.

2. Principles

The business relationship between Devold and its suppliers shall be based on mutual respect, and all parties shall communicate in a good and constructive manner throughout the process.

Devold goal

Our goal is to influence the work for respect for Human & Labor Rights and environmental protection both within the company and towards our business partners.

Favoring of producers and producing countries

Devold shall, when choosing suppliers, in addition to other competition aspects, consider social and environmental standards.

Compliance with these standards and demonstrated will to improve these aspects of the operations, is considered as a competitive advantage and will be taken into consideration when choosing suppliers and vendors.

Boycott of individual countries

Devold and its suppliers shall avoid sourcing from partners operating in countries where there is broad international consensus by the United Nations to boycott because of the country’s human rights situation.

Continuous evaluation and improvement Devold internal policies and practices

Devold shall continuously evaluate and, if applicable, improve our own policy and purchasing practices in order to facilitate suppliers and subcontractors’ compliance with this Code of Conduct.

Neither Devold nor any of its employees shall ever offer or accept illegal or unlawful monetary gifts or other forms of remuneration in order to secure business-related or private benefit, or benefit for customers, agents or suppliers.

3. Code of Conduct

1. Freely Chosen Employment (ILO Conventions Nos. 29 and 105)

• There shall be no forced, bonded, or involuntary prison labor.
• Workers shall not be required to lodge “deposits” or identity papers with their employer and shall be free to leave their employer after reasonable notice.

2. Freedom of Association and the Right to Collective Bargaining (ILO Conventions Nos. 87, 98, 135 and 154)

• Workers, without distinction, shall have the right to join or form trade unions of their own choosing and to bargain collectively.
• Worker’s representatives shall not be discriminated against and shall have access to carry out their representative functions in the workplace.
• Where the right to freedom of association and collective bargaining is restricted by law, the employer shall facilitate, and not hinder, the development of parallel means for independent and free association and bargaining.

3. No Child Labor (UN Convention on the Rights of the Child, ILO Conventions Nos. 138, 182 and 79, and ILO Recommendation No. 146)

• Children and young persons under the age of 18 shall not be engaged in labor that is hazardous to their health or safety, including night work.
• Children under the age of 15 (14 or 16 in certain countries) shall not be engaged in labor that is detrimental to their education.
• New recruitment of child labor in infringing of the above mentioned conventions is unacceptable. If child labor, as described above, is already in existence, sustained efforts shall be made to redress the situation as quickly as possible. However, the children concerned shall be given the possibility of earning a livelihood, as well as acquiring an education until they are no longer of compulsory school age.

4. No Discrimination (ILO Conventions Nos. 100 and 111 and the UN Convention on Discrimination Against Women)

• There shall be no discrimination at the workplace based on ethnic background, religion, age, disability, gender, marital status, sexual orientation, union membership or political affiliation.
• Measures shall be established to protect workers from sexually intrusive, threatening, insulting or exploitative behavior, and from discrimination or termination of employment on unjustifiable grounds, e.g., marriage, pregnancy, parenthood, or HIV status.
• Women shall not be dismissed due to pregnancy.

5. No Harsh or Inhumane Treatment

• Physical abuse or punishment, or threats of physical abuse, sexual or other harassment and verbal abuse, as well as other forms of intimidation, shall be prohibited.

6. Safe and Hygienic Working Conditions (ILO Convention No. 155 and Recommendation No. 164)

• The working environment shall be safe and hygienic, 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 minimizing, so far as is reasonably practicable, the causes of hazards inherent in the working environment.
• Workers shall receive regular and documented health and safety training, and such training shall be repeated for new workers.
• Access to clean toilet facilities and to potable water, and, if appropriate, sanitary facilities for food storage shall be provided.
• Accommodation, where provided, shall be clean, safe, and adequately ventilated, and shall have access to clean toilet facilities and potable water.

7. Adequate Wages (ILO Convention No. 131)

• Wages and benefits paid for a standard working week shall meet, at a minimum, national legal standards, or industry benchmark standards, whichever is higher.
• Working hours, wages and overtime wages shall be set in accordance with relevant law.
• All workers shall be provided with a written and comprehensible contract outlining their wage conditions and method of payments before entering employment.
• Holiday pay, sickness allowance, maternity leave compensation, as well as other compensated absences established by law shall be covered by the manufacturer pursuant to the particular country’s laws and regulations.
• The piece rate shall be calculated according to the legal requirements and cannot be lower than the minimum piece rate.
• Deductions from wages as a disciplinary measure shall not be permitted.

8. No Excessive Working Hours (ILO Convention No. 1 and 14)

• Working hours shall comply with national laws and benchmark industry standards, whichever affords greater protection. It is recommended that working hours do not exceed 48 hours per week (8 hours per day).
• Workers shall be provided with at least one day off for every 7-day period.
• Overtime shall be limited. Recommended maximum overtime is 12 hours per week.
• Workers shall always receive overtime pay, as a minimum in accordance with current legislation.

9. Providing Regular Employment

• Obligations to employees under international conventions and social security laws, and regulations arising from the regular employment relationship, shall not be avoided through the use of short-term contracting (such as contract labor, casual labor or day labor), sub-contractors or other labor relationships.
• All workers are entitled to a contract of employment that shall be written in a language they understand.
• The duration and content of apprenticeship programs shall be clearly defined.

10. Consideration for Marginalized Populations

• Production and extraction of raw materials for production shall not contribute to the destruction of the resources and income base for marginalized populations, by claiming large land areas or other natural resources on which these populations depend.

11. Protection of the Environment

• Environmental measures shall be taken into consideration throughout the production and distribution chain ranging from the production of raw material to the consumer sale. Local, regional, and global environmental aspects shall be considered. The local environment at the production site shall not be exploited or degraded by pollution.
• Suppliers shall use management systems to ensure continual improvement and compliance with environmentally beneficial policies and practices and encourage own suppliers to implement and adhere to the same standards.
• Suppliers shall seek to reduce negative impacts on resource consumption (e.g. energy and water), emissions and waste.
• National and international environmental legislation and regulations shall be respected.
• Relevant discharge permits shall be obtained where required.
• Hazardous chemicals and other substances shall be carefully managed.

12. Ethical Conduct in the care and use of Animals

• In addition to ethical and environmentally friendly guidelines, we are also aware of our responsibility for the welfare of animals when we use materials made from these animals. Animals shall be treated according to regulations and humanely, and materials derived from animals shall be a by-product of food production.
• Devold does not accept mulesing, even if it is used pain relief, a procedure performed on Merino sheep in order to prevent fly strike. Devold does not accept clips as an alternative to mulesing.
• Only synthetic fur is to be used in the production of goods supplied to Devold.
• Leather products ought to be manufactured using only the skins of utility animals such as pigs, sheep and cows, where the animals having been originally slaughtered for the meat market.
• Devold shall not purchase leather, skins or animal fibers from areas known for bad farming practices or for transporting animals under inhumane conditions. The use of unethical and inhumane production processes is not in accordance with our animal welfare policy.
• Devold is against animal testing and encourages all business partners to follow our policy on this matter.

13. Protection of Devold confidential and proprietary rights and intellectual property

• Any confidential and proprietary information and intellectual property (including drawings and patterns, trademarks, and other confidential unregistered know-how) provided by Devold to the supplier shall remain the property of Devold and the supplier shall all times be kept confidential and not be disclosed to any competitors or other third parties unless specifically authorized by Devold in writing in advance. The supplier shall ensure that the information is stored and protected in a prudent manner and that copies cannot be taken without consent.
• Confidential and proprietary information and intellectual property rights shall only be used as agreed in writing with Devold and in accordance with the intended purpose.
• Upon termination of the agreement between Devold or upon Devold request the supplier shall return all confidential and proprietary information and intellectual property rights to Devold and any confidential information that has been stored electronically with the supplier shall be deleted.
• The supplier shall ensure that it will only disclose Devold’s confidential and proprietary information and intellectual property rights to those employees who need the information to provide the services agreed with Devold.
• The supplier shall ensure that all its employees who shall handle confidential and proprietary information and proprietary rights of Devold handle such information as confidential information.

14. Anti-corruption

• Corruption in any form is not accepted, including bribery, extortion, kickbacks and improper private or professional benefits to customers, agents, contractors, suppliers, or employees of any such party or government officials.

15. Management System

• The supplier shall take positive actions to implement the requirements of this standard, to incorporate the standard into all of its operations, and to make the standard an integral part of its overall philosophy.
• The supplier shall assign responsibility for all matters pertaining to this Code of Conduct to a manager within its organization.
• Top management of the supplier shall periodically review the operation of the requirements of this standard.
• The supplier accepts responsibility for observing the requirements of this standard with respect to all employees and workers under its control and supervision and agrees to:
  • assign responsibility for implementing this standard at each place that it owns or controls to an employee.
  • ensure that employees and workers are aware of the standard by communicating its contents in a language understood by them.
  • refrain from disciplining, dismissing or otherwise discriminating against any employee for providing information concerning observance of this standard.
• The supplier shall maintain appropriate records to demonstrate conformance to the requirements of this standard and shall be able to provide reasonable information and access to parties approved by Devold seeking to verify conformance.
• The supplier will make the observance of this Code of Conduct a condition of all agreements that it enters into with subcontractors. These agreements shall oblige these subcontractors to conform to all requirements of this standard and participate in the supplier’s monitoring activities as requested.
• Regarding the use of agents, or several factories or suppliers that have sub-contractors, all links shall be traceable concerning manufacturing location with respect to the manufactured goods delivered to Devold. Any sub-contracting shall be agreed upon by Devold prior to any production.

4. Auditing and Monitoring

To evaluate the compliance of this Code of Conduct Devold will make use of audits either by own personnel or by approved third parties. We reserve the right to monitor the compliance of this Code of Conduct by systematic, unannounced, or announced inspections, conducted by Devold personnel or independent auditors.

5. Corrective Action and Non-Compliance

Devold Code of Conduct sets the standard expected to be met by all our suppliers and partners during operation and manufacturing. We are fully aware that all expectations can’t be met immediately, but these as well as non-compliances are to be settled by corrective actions by the supplier. If repeated violations are established without any effort by the supplier to take appropriate actions, it is our duty to terminate the cooperation with such suppliers.