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Ethical Trading Policy

1. Introduction.

1.1 Bargain Buys recognises 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.

1.2 This policy has been approved by the Board of Directors.

1.3 Our Ethical Trading Policy is a core element of our commitment to buy and sell our products responsibly. We require all our suppliers to comply with our Ethical Trading Code (ETC) Appendix 1 to this document, to ensure key rights for workers.

1.4 It is based on the eight Fundamental Conventions of the International Labour Organisation (ILO) and national and international laws. The core conventions, cover collective bargaining, forced labour, child labour and discrimination. They require;

• freedom to join a union, bargain collectively and take action

     • Freedom of Association and Protection of the Right to Organise Convention, 1948, No 87

     • Right to Organise and Collective Bargaining Convention, 1951, No 98

• abolition of forced labour

     • Forced Labour Convention, 1930, No 29

     • Abolition of Forced Labour Convention, 1957, No 105

• abolition of labour by children before the end of compulsory school

     • Minimum Age Convention, 1973, No 138

     • Worst Forms of Child Labour Convention, 1999, No 182

• no discrimination at work

     • Equal Remuneration Convention, 1951, No 100

     • Discrimination (Employment and Occupation) Convention, 1958, No 111

Our ETC is referenced in our Standard Terms & Conditions of Purchase with our Suppliers.

2. Scope

This policy applies to all suppliers to Bargain Buys and is applicable to the supply of goods for resale and goods and /or services not for resale.

3. Implementation

Our ETC is integrated into our commercial and supplier management activities and our commitment to Ethical Trading is led by the Board of Directors.

We recognise the need to communicate our commitment to key stakeholders including the public, suppliers and the people who work for our suppliers. We seek to develop long-term relationships with our suppliers who share our ethical standards. These relationships with suppliers are based on the principle of fair, open and honest dealings at all times. Only suppliers that share our standards and can demonstrate compliance will be considered appropriate to trade with Bargain Buys.

4. Monitoring & Assessing Risk

This policy will be communicated to all employees, suppliers, contractors and Company partners at the outset of our relationship with them. We assess all our suppliers through our risk-based systems and then monitor them accordingly.

5. Improvement

We encourage and support continuous improvement in supplier standards and we regularly measure supplier improvement. Where we are alerted to breaches of our ETC we will take action that we consider appropriate.

We will work with suppliers to resolve ethical trading issues. If suppliers are unable or unwilling to address critical issues associated with any breach of our ETC within the required timescales, this may be considered a material breach and we reserve our right to terminate the relationship in accordance with our contractual rights.

We will strive to be open and honest when we work with others and ensure reporting is fair and transparent.

6. Specific Supplier Requirements

All suppliers are required to comply in all respects with our ETC which is referenced in our Supplier Standard Terms & Conditions of Purchase.

7. Monitoring and review

The Trading Director will monitor the effectiveness and review the implementation of this policy, regularly considering its suitability, adequacy and effectiveness. Any improvements identified will be made as soon as possible.

Appendix 1

Bargain Buys Ethical Trading Code (ETC)

The requirements of the Bargain Buys ETC constitute minimum and not maximum standards and relate to any member of the Bargain Buys Group.

Suppliers shall at all times comply with this code and with all applicable 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 Bargain Buys comply with this code.

Suppliers shall ensure that:

1. Employment is freely chosen

There is no forced, bonded or involuntary prison labour. Workers are not required to lodge monetary deposits or their identity papers with their employer and are free to leave their employment after reasonable notice.

2. Freedom of Association and Protection of the Right to Organise.

Workers 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 work place.

3. 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 environments. Workers are provided with 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 meet the basic needs of the worker.

4. Child labour shall not be used

There shall be no use of Child Labour. In the event of any Child found to be performing Child Labour, they shall be removed from the workplace immediately. Young persons under 18 shall not be employed at night or in hazardous conditions. These policies and procedures relating to Child Labour shall conform to the provisions of the relevant International Labour Organisation (ILO) Standards.

5. Remuneration.

Wages and benefits paid for a standard working week meet, at a minimum, national legal or industry benchmark standards, whichever is higher. In any event wages shall 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 including information with 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 as a disciplinary measure 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. All disciplinary measures should be recorded.

6. Working hours are not excessive.

Working hours must comply with national laws, collective agreements, and the provisions defined in the clauses below, whichever affords the greater protection for workers. Working hours, excluding overtime, shall be defined by contract. All overtime shall be voluntary. Overtime shall be used responsibly, taking into account all the following: the extent, frequency and hours worked by individual workers and the workforce as a whole. It shall not be used to replace regular employment.

7. No discrimination is practised.

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.

8. Regular employment is provided.

To every extent possible work performed must be on the basis of recognised employment relationships 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, sub-contracting and 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.

9. Treatment of employees.

No harsh or inhumane treatment is allowed Suppliers provide a workplace in which any form of harassment is unacceptable. Examples include physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidations.

10. Entitlement to work.

Only workers with a legal right to work in the country should be employed. For both workers and agency workers, original documents should be reviewed and then returned to workers to verify right to work.

11. Labour Providers

Labour providers should only supply workers registered with them. Relationships with Labour providers should be covered by a Service Level Agreement which meets all national legal requirements. Labour providers should be independently audited on a regular basis to ensure compliance with national requirements/legislation.

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