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Mothercare and

Early Learning Centre

Responsible Sourcing Handbook

February 2017

Mothercare/ELC RS Handbook, February 2017

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Table of Contents

1. Introduction from the Chief Executive Officer p3 2. Mothercare/ELC Responsible Sourcing Code of Practice p4 3. Mothercare/ELC Responsible Sourcing Policies p14

- Compliance with our Code of Practice p14 - Child Labour Policy p17 - Sub-contracting and Sub-Supplier Policy p19 - Home Worker Policy p20 - Migrant Worker Policy p21 - Timber Sourcing Policy p23 - Animal Welfare Policy p25

4. Supplier Responsible Sourcing Commitment p26 5. Factory Responsible Sourcing Approval Process p27 6. Contact Details p29

Version: February 2017. Owner: Global Head of Corporate Responsibility Revisions Tracker

What When Who Why


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1. Introduction from the Chief Executive Officer Dear Supplier Welcome to Mothercare and Early Learning Centre’s Responsible Sourcing Handbook. Responsible Sourcing is a key element of our Corporate Responsibility programme. Our social and environmental commitments sit alongside our vision to be the leading global retailer for parents and young children. We are committed to respecting internationally recognised human rights, as outlined in the United Nations Guiding Principles (UNGPs) on Business and Human Rights. The policies in this handbook also enable us both to meet our respective legal obligations. This handbook replaces any other versions you may have received prior to 2017. Responsible sourcing means partnering with suppliers that:

provide decent, safe and fair working conditions for their employees;

treat employees with dignity and respect;

reduce the environmental impacts of their operations; and

demonstrate a strong commitment to business ethics. This document outlines our requirements of suppliers in these areas. As a minimum, we require suppliers to meet the legal obligations in the countries and regions in which they operate. In addition, we expect suppliers to commit to respecting human rights as outlined in the UNGPs on Business and Human Rights as mentioned above. The Mothercare/ELC Code of Practice and Responsible Sourcing Policies are part of our terms and conditions of trading. All suppliers and factories of Mothercare and Early Learning Centre branded products must meet these requirements. Global sourcing is an essential element of our business; our supplier partnerships allow us to source stylish, innovative and quality products. We are committed to working with suppliers that are transparent, collaborative and willing to work on continuous improvements. In return, we will deal openly and fairly with our suppliers. However, we will also take action if suppliers do not share our values or do not meet the required standards. We hope you find this document useful. Our Responsible Sourcing team is available to assist you if you have any queries; contact details are provided on page 29.

Mark Newton-Jones Chief Executive Officer, Mothercare Plc

http://www.ohchr.org/Documents/Publications/GuidingPrinciplesBusinessHR_EN.pdf



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2. Mothercare/ELC Responsible Sourcing Code of Practice

Introduction

This Code of Practice sets out the standards we require at our suppliers’ factories, i.e. suppliers with whom we have a direct agreement to produce Mothercare or Early Learning Centre goods or services. Our Code of Practice is based on:

- The UN Guiding Principles on Business and Human Rights, which outline the corporate responsibility to respect human rights, avoid infringing on the human rights of others and address relevant adverse human rights impacts;

- The Ethical Trading Initiative’s (ETI) Base Code, which is founded on the conventions of the International Labour Organisation (ILO) and is an internationally recognised code of labour practice;

- The UK Bribery Act 2010, which states that bribery and corruption on an individual and company basis is a criminal offence; and

- The UK Modern Slavery Act 2015, which requires eligible businesses (including Mothercare/ELC) to report against the measures taken to eradicate slavery and human trafficking in their operations and supply chains.

It is our suppliers’ responsibility to enforce these standards at their factories and within their own supply chains. Implementation of this code must be sensitive to the rights and livelihoods of the workers it is aiming to protect. In addition to these standards, suppliers must comply with all relevant local and national laws. If there is a conflict between national law and this Code of Practice, the supplier must adhere to the standard which provides the worker with the greatest protection. There may also be country-specific requirements which we will discuss with suppliers, such as satisfactory age proof documentation in India. Suppliers must implement management systems and training for all employees (staff, workers and supervisors) to ensure compliance with this Code and all relevant national laws. We monitor compliance with this Code via third party factory audits and internal Responsible Sourcing factory audits. We also carry out projects such as training and capacity building with suppliers and other partners such as the Ethical Trading Initiative, other retailers, consultants and non-governmental organisations. We require suppliers’ full co-operation with these projects. Policies available in the Responsible Sourcing Handbook provide greater detail for suppliers in the following areas:

Responsible Sourcing Implementation Policy – how to apply the Code of Practice

Child Labour Policy

Sub-contracting and Sub-Supplier Policy

Home Worker Policy

Migrant Worker Policy


http://www.ethicaltrade.org/eti-base-code

http://www.ilo.org/global/standards/introduction-to-international-labour-standards/conventions-and-recommendations/lang--en/index.htm

http://www.legislation.gov.uk/ukpga/2010/23/pdfs/ukpga_20100023_en.pdf

http://www.legislation.gov.uk/ukpga/2015/30/contents/enacted/data.htm


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Timber Sourcing Policy

Animal Welfare Policy These policies can be found in the Responsible Sourcing Handbook from page 14. This Code of Practice is arranged into the following clauses:

1. Bribery and Corruption Are Prohibited 2. Employment is Freely Chosen 3. Freedom of Association and the Right to Collective Bargaining Are Respected 4. Working Conditions Are Safe and Hygienic 5. Worker Accommodation and Crèche Facilities Are Suitable (where provided)

6. Child Labour Shall Not Be Used 7. Living Wages Are Paid 8. Working Hours Are Not Excessive 9. No Discrimination is Practised 10. Regular Employment is Provided 11. No Harsh or Inhumane Treatment is Allowed 12. Disciplinary and Grievance Procedures Are Available 13. Environmental Impacts Are Managed and Reduced


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1. BRIBERY AND CORRUPTION ARE PROHIBITED

1.1 In line with the UK Bribery Act 2010, bribery and corruption on an individual and company basis is a criminal offence and is prohibited by Mothercare/ELC.

1.2 Bribery occurs when a person offers, promises or gives a bribe (which can be

money or any other form of advantage) to another person or entity intending that they operate in an improper way or with the intention of obtaining or retaining business or an advantage in the conduct of business. It is also an offence to accept, request or agree to receive a bribe.

1.3 The UK Bribery Act 2010 applies to any bribes paid in connection with Mothercare/ELC's business, anywhere in the world. We therefore require our suppliers and any sub-suppliers to comply with the UK Bribery Act and with Mothercare/ELC’s Anti-Bribery and Corruption Policy (included in supplier contracts as part of our terms and conditions of trade), in addition to any locally applicable anti-bribery laws.

1.4 Suppliers shall conduct their business in a way that is consistent with fair and vigorous competition and in compliance with all applicable laws. Suppliers must not offer, give to, or receive from any person, including Mothercare/ELC staff, agents or contractors working on our behalf, any payment, gift or other benefit that could be considered a bribe. Mothercare/ELC employees are, in turn, required to refuse to accept, offer or give any payment, gift or other benefit that could be construed as a bribe.

1.5 We expect transparency and a willingness to improve from all of our suppliers and at all sites at which they operate. Double books, fake or inconsistent records will not be accepted as proof of compliance with these anti-bribery requirements or our Code of Practice.

2. EMPLOYMENT IS FREELY CHOSEN

2.1 All suppliers must ensure they are familiar with the UK government’s Modern

Slavery Act 2015 and its obligations. Suppliers must be willing to support Mothercare/ELC in ensuring that we comply with this law through Responsible Sourcing factory audits, compliance with our Code of Practice and Responsible Sourcing policies and support for any related projects or investigations.

2.2 There is no forced, trafficked or bonded labour and no use of involuntary prison labour.

2.3 All work is conducted on a voluntary basis and not under threat of any penalty, sanctions or loss of monies owed to the worker.

2.4 Workers are not required to lodge deposits, financial guarantees or their identity papers with their employer and are free to leave their employer after reasonable notice.

2.5 Employers respect the right of workers to leave the workplace after their shift.

http://www.legislation.gov.uk/ukpga/2010/23/pdfs/ukpga_20100023_en.pdf




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2.6 Workers are paid at regular intervals - maximum monthly.

2.7 Workers’ use of any accommodation provision must be voluntary and must not

restrict workers’ freedom of movement, freedom of association or the principle that all work is conducted on a voluntary basis.

3. FREEDOM OF ASSOCIATION AND THE RIGHT TO COLLECTIVE BARGAINING ARE RESPECTED 3.1 Workers, without distinction, have the right to join or form trade unions of

their own choosing and to bargain collectively.

3.2 The employer adopts an open attitude towards the activities of trade unions and their organisational activities.

3.3 Worker representatives are not discriminated against and have access to carry out their representative functions in the workplace.

3.4 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 association and bargaining.

4. WORKING CONDITIONS ARE SAFE AND HYGIENIC 4.1 A safe and hygienic working environment shall be provided.

4.2 The employer shall assign responsibility for health and safety to a senior

management representative who carries out regular risk assessments. A clear set of procedures regulating occupational health and safety will be established and followed, with regular checks.

4.3 Suppliers must provide adequate safeguards against fire, and must ensure the strength, stability and safety of buildings and equipment.

4.4 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.

4.5 Appropriate and effective personal protective equipment is provided as needed.

4.6 Workers shall receive regular and recorded health and safety training, and such training shall be repeated for new or reassigned workers.

4.7 Access to clean toilet facilities and potable water and, if appropriate, sanitary facilities for food storage and preparation, shall be provided.

4.8 The supplier must provide access to adequate medical assistance and facilities.


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5. WORKER ACCOMMODATION AND CRECHE FACILITIES ARE SUITABLE (where

provided)

5.1 WORKER ACCOMMODATION 5.1.1 Workers must stay in factory-provided accommodation voluntarily. Using this

accommodation must not restrict workers’ freedom of movement, freedom of association or the principle that all work is conducted on a voluntary basis.

5.1.2 There may be reasonable requirements relating to freedom of movement in order to ensure worker safety, such as a log of movements or a time at which workers are expected to return to site in the evening.

5.1.3 Workers must not be expected to deposit their original certificates or identification documents as a condition of accommodation.

5.1.4 Accommodation buildings must meet all local building and health and safety regulations and occupancy limits.

5.1.5 Accommodation must be clean, safe, and meet the basic needs of the workers.

5.1.6 Accommodation must have at least two unobstructed emergency exits per floor that lead to a safe location. Exits must be indicated by illuminated signs.

5.1.7 Accommodation must have a fire alarm that can be heard in all parts of the building. There must be smoke detectors and fire extinguishers on each floor.

5.1.8 Emergency evacuation drills must be conducted at least twice per year so that workers understand evacuation procedures.

5.1.9 A sufficient number of toilets must be provided as required by law. Toilets must be cleaned and maintained regularly.

5.1.10 Canteens or kitchens (where provided) should be kept clean with adequate lighting, ventilation, fire exits and extinguishers.

5.1.11 There shall be adequate personal space provided per worker as outlined by law. If there is no law in place, there must be space for workers to sleep, store personal belongings and have space to move freely and safely.

5.1.12 Workers must be allowed to have their own mobile phones whilst staying in

the accommodation.


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5.1.13 The privacy of the workers must be respected. CCTV cameras inside the accommodation are not acceptable and gender sensitive guards and cleaners should be arranged.

5.1.14 A bed and pillow will be provided to every worker. Each room shall have

sufficient lighting, windows and ventilation. Potable water for drinking should be available on each floor.

5.1.15 All workers shall be provided with individual lockers with a key for their

valuables. 5.1.16 A qualified nurse must be available and there must be adequate means for

reporting emergencies. 5.1.17 The opportunity to see a doctor if required must be available to the

workers. Adequate provisions shall be provided for unwell workers to rest. 5.2 CRECHE CONDITIONS 5.2.1 A factory is not a safe environment for a child. Where crèche facilities are

provided at the factory, they must be sufficiently segregated from the factory floor so as not to expose the children to danger and always supervised by appropriately qualified staff.

5.2.2 The crèche building must be of sound construction and meet building safety

standards. The space must be safe and hygienic with adequate fire exits and necessary fire-fighting equipment.

5.2.3 The crèche should include a suitable washroom as well as space for parents to

feed or attend to their children. The crèche shall be adequately furnished and equipped with cots or cradles, bedding and space for resting, playing and learning.

5.2.4 Provisions shall be made for the supply of free milk and nutritious

refreshment for the children. 6. CHILD LABOUR SHALL NOT BE USED 6.1 There shall be no employment of child labour. A ‘child’ is defined as a person

who is younger than:

The legal minimum age for employment; or

The age of completion of compulsory education, whichever is higher. In any event, suppliers must not employ a person under the age of 15 in any circumstances.

6.2 If a child is found working directly or indirectly for a supplier, the supplier

must implement a remediation plan that puts the best interests of the child first and enables the child to access and remain in appropriate, quality education until no longer a child (see Child Labour Policy for more information).


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6.3 Young people under 18 shall not be employed at night or in hazardous

conditions.

6.4 Workers under the age of 18 must be subject to an appropriate risk assessment and regular monitoring of health, working conditions and hours of work.

6.5 A factory is not a safe environment for a child. Where crèche facilities are provided at the factory, they must be safe and hygienic, sufficiently segregated from the factory floor so as not to expose the children to danger and always supervised by appropriately qualified staff. Please see further guidelines for crèche facilities under 5. Worker Accommodation and Crèche Facilities Are Suitable.

7. LIVING WAGES ARE PAID 7.1 Wages and benefits meet or exceed national legal minimum wage and all

applicable laws and regulations. If industry benchmark standards and/or collective bargaining agreements are in place, provided they are higher than the minimum wage, these must be followed. In any event wages should always be enough to meet basic needs and to provide some discretionary income.

7.2 All workers shall be provided with written and understandable information about their wages and employment conditions before they enter employment and about the particulars of their wages for the pay period concerned each time that they are paid.

7.3 Deductions from wages as a disciplinary measure shall not be permitted nor shall any deductions from wages not provided for by national law. Workers must be fully informed of any deductions made to their pay and these deductions must be recorded. All disciplinary measures must be recorded.

7.4 Workers are paid at regular intervals, maximum monthly, and on time.

7.5 Employers must ensure that men and women receive equal pay and benefits for the same job.

8. WORKING HOURS ARE NOT EXCESSIVE 8.1 Working hours must comply with national laws or benchmark industry standards

or relevant international standards, whichever affords greater protection to workers’ health, safety and welfare.

8.2 In any event, working hours, excluding overtime, must not exceed 48 hours per week. At least one day off for every 7-day period or, where allowed by law, two days off in every 14-day period, will be provided, as well as annual holidays.

8.3 All overtime shall be voluntary and not requested on a regular basis. It shall not be used to replace regular employment. Overtime shall always be


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compensated at a premium rate, which must meet local law requirement. If no local law requirement exists, the premium rate is recommended to be not less than 125% of the regular rate of pay.

8.4 Total working hours may exceed 60 hours in any 7-day period only in exceptional circumstances where all of the following are met:

This is allowed by national law;

This is allowed by a collective agreement freely negotiated with a workers’ organisation representing a significant portion of the workforce;

Appropriate safeguards are taken to protect the workers’ health and safety; and

The employer can demonstrate that exceptional circumstances apply such as unexpected production peaks, accidents or emergencies.

9. NO DISCRIMINATION IS PRACTISED 9.1 Employers must treat all workers with respect and dignity.

9.2 There is no discrimination in any working conditions or accommodation

provisions based on race, caste, national or ethnic origin, gender, language, religion, age, disability, marital status, pregnancy, sexual orientation, union membership or political affiliation.

9.3 Suppliers shall not require pregnancy tests or medical tests either as a condition for employment or as a requirement for continued employment. Pregnancy tests or medical tests are allowed only if both of the following conditions are met:

Applicable law requires the pregnancy test or the medical test is determined (in writing) by a qualified health professional to be required as a safety measure prior to working in a particular environment; and

The worker provides written consent to the test.

9.4 Suppliers shall make reasonable efforts to accommodate workers with chronic illnesses, which may include rearranging working time, providing special equipment, opportunities for rest breaks, time off for medical appointments, flexible sick leave, part-time work, and return-to-work arrangements.

9.5 Suppliers shall not prohibit female workers from becoming pregnant nor threaten female workers with adverse employment consequences, including dismissal, loss of seniority, or deduction of wages, in order to discourage them from becoming pregnant.

9.6 Suppliers must comply with all applicable laws and regulations regarding pregnancy and postnatal employment protections, benefits, and pay. Suppliers shall not:

refuse to hire a pregnant applicant for a non-hazardous position; or

terminate a worker’s employment solely based on the worker’s pregnancy status.


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9.7 Suppliers must take reasonable measures to ensure the safety and health of pregnant women and their unborn children, including accommodating the worker in a non-hazardous position.

9.8 Suppliers should have an equal opportunity employment policy that promotes

gender equity in employment practices and allows for maternity leave provision and support for child care where appropriate.

10. REGULAR EMPLOYMENT IS PROVIDED 10.1 To every extent possible work performed must be on the basis of a recognised

employment relationship established through national law and practice.

10.2 Obligations to employees under labour or social security laws arising from the regular employment relationship shall not be avoided through the use of temporary labour arrangements, excessive fixed-term contracts of employment, labour-only contracting, sub-contracting, home-working arrangements or through apprenticeship schemes where there is no real intent to impart skills or provide regular employment.

10.3 If agency workers or workers engaged through a labour provider or contractor are present on site, suppliers are responsible for the rights and welfare of these workers. Suppliers must have a process to record all workers on site, ensure they are paid at least the national minimum wage regularly, and ensure their employment meets any local laws relating to workers engaged indirectly.

10.4 Suppliers must have a clear written agreement with any labour providers to ensure that the welfare and rights of workers are safeguarded. This includes their health and safety, payment and benefits, accommodation, freedom of movement, and non-discrimination. Suppliers must monitor that labour providers adhere to this agreement.

11. NO HARSH OR INHUMANE TREATMENT IS ALLOWED 11.1 Suppliers must be committed to a workplace free of harassment.

11.2 Physical abuse or discipline, the threat of physical abuse, sexual or other

harassment, verbal abuse, corporal punishment or other forms of mental and physical coercion and intimidation are prohibited.

12. DISCIPLINARY AND GRIEVANCE PROCEDURES ARE AVAILABLE 12.1 Written disciplinary procedures must be established and explained in clear and

understandable terms to workers.

12.2 All disciplinary and other performance management actions must be recorded and explained to workers.

12.3 Workers have the right to a trade union or other appropriate representation at disciplinary hearings which may result in significant penalties or dismissal.


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12.4 Employers must provide a grievance mechanism for workers to raise workplace

concerns, without fear of reprisal, and with an option of anonymity. Feedback will be given in a timely manner.

12.5 The existence and scope of this grievance mechanism must be clearly communicated to all workers and all workers must have equal access.

13. ENVIRONMENTAL IMPACTS ARE MANAGED AND REDUCED 13.1 At the very least, suppliers must meet all relevant local and national laws

governing environmental protection.

13.2 Every reasonable effort must be made to reduce the environmental impact of business activities. In addition to complying with local and national laws, proactive steps should be taken to optimise the use of energy and natural resources and dispose of waste in a way that is not detrimental to the local environment and community.

13.3 Hazardous waste must be recovered and treated in an appropriate manner to ensure it is not released into the environment.

13.4 Suppliers must support Mothercare/ELC to ensure its supply chain minimises its impact on the environment by taking part in environmental assessments and projects aimed at identifying and reducing impacts and improving performance.


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3. Mothercare/ELC Responsible Sourcing Policies

Compliance with our Code of Practice Background This policy gives suppliers more information about the way in which Mothercare/ELC implements our Code of Practice and Responsible Sourcing policies and explains the requirements for suppliers to demonstrate that they meet our standards. 1. Mothercare/ELC will only trade with suppliers which can demonstrate that they

are consistent with our Code of Practice and Responsible Sourcing (RS) policies. 2. Production must not begin until factory approval is given (see Factory

Responsible Sourcing Approval Process page 27). If production begins without this, we reserve the right to cancel orders or refuse goods and apply charges for loss of profits.

3. In order to be approved, each factory must submit an acceptable annual, third party audit (see page 27) and make continuous improvements within reasonable time frames. If an acceptable audit is not already available and suppliers have to book a new audit, suppliers will bear the associated costs. Mothercare/ELC may also carry out an internal Responsible Sourcing factory audit.

4. It is the supplier’s responsibility to declare all factories they wish to use for the

primary manufacture of Mothercare or Early Learning Centre (ELC) products in time to allow the full approval process to take place (see Sub-contracting and Sub-Supplier Policy page 19).

5. We accept that in certain circumstances the use of sub-contractors, sub-suppliers, home and migrant workers is a necessary part of our supply chain. Suppliers must comply with our Sub-contracting and Sub-Supplier, Home Workers and Migrant Workers Policies (see pages 20 to 22). Mothercare adopts a zero-tolerance approach towards unauthorised sub-contracting.

6. The following circumstances require suppliers to follow the Factory Responsible Sourcing Approval Process:

a) Current or new supplier wishes to use a new factory. b) Current supplier wishes to use a new factory even if that factory is under

their ownership or within the same supplier group. c) Factories switch from producing 3rd party branded goods to producing

Mothercare/ELC branded goods. d) Factories plan to move to new premises (prior to moving).

7. Certain branded or licensed products may be subject to their own Code of Practice requirements. Suppliers and factories making these products must engage with the responsible sourcing team on the requirements of these branded or licensed products, and may be also required to demonstrate compliance to the Mothercare/ELC Code of Practice.


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8. Suppliers of Mini Club products are required to meet the responsible sourcing

policies of the Mini Club brand, which is a joint venture between Mothercare and Boots UK Limited. Suppliers concerned will be informed of these requirements.

9. All licensed products must be manufactured in approved factories. Non-

compliance with the licensor’s requirements may result in the site or the supplier being blacklisted from producing the licensor’s goods for all customers and/or fined.

10. We expect transparency from all of our suppliers and their factories. Suppliers

must ensure that all Mothercare/ELC employees and/or third party audit companies are given unrestricted access to premises, workers and documentation. ‘Double books’, fake or inconsistent records will not be accepted as proof of compliance.

11. Mothercare/ELC maintains the right to visit any factory used for the production of Mothercare/ELC products, announced or unannounced. These visits will be undertaken by an employee of Mothercare/ELC (who will carry identification) or by a nominated third party (who will carry an authorisation letter and identification). If access is denied or the audit is refused, no further orders will be made to the supplier until this can be resolved and the cost of the audit may be charged back to the supplier.

12. Twelve months’ records must be kept at the factory even if the records have already been audited by Mothercare or another third party. It is not acceptable to state that they are at another office or with the accountant, even if the audit is unannounced.

13. The goal of our Responsible Sourcing team is to help factories understand our Code of Practice and provide support to implement it. However, if Mothercare/ELC’s Responsible Sourcing team has to carry out more than one visit to factories in order to approve them due to ‘audit failure’, we will charge for the audit. The charge will be $500 USD plus travel expenses. Audit failure happens when the factory supplies inaccurate, incomplete, insufficient or falsified working hours and wages records and/or denies access to a key element of the audit, such as visiting all production and accommodation areas or interviewing workers.

14. Our approach to compliance is based on continuous improvement. However,

there are certain issues deemed Zero Tolerance which we will not accept in our supply base. If a Zero Tolerance issue is identified at a new factory, it will not be approved. If a Zero Tolerance issue is identified at a current factory, no new orders will be placed until the issue has been resolved. Existing orders may be allowed to continue if an improvement plan is agreed and followed. We reserve the right to cancel orders and/or terminate supplier relationships with immediate effect in extreme cases.


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Zero Tolerance issues include (this is not an exhaustive list):

Bribery and corruption

Non-transparency

Child labour

Forced, bonded or trafficked labour

Extreme working hours

Non-payment of minimum wage

Unsafe premises that pose a direct risk to life

Physical or verbal harassment and intimidation

Severe pollution of local water/air or by hazardous waste.

Suppliers must notify the Responsible Sourcing Team immediately if a Zero Tolerance issue is identified either by themselves or through an audit carried out by another customer.

15. Suppliers must make Mothercare/ELC aware immediately if any of the

following takes place at their factories: a) Serious accident or fire b) Strike, worker unrest or riot c) Media or non-governmental organisation enquiry/accusation.

16. Mothercare/ELC is a member of the Ethical Trading Initiative and suppliers are

expected to engage in related project work aimed at understanding the root causes of non-compliances and implementing improvement strategies.

17. In order to meet our obligations under timber regulations, relevant suppliers must be able to prove product legality through the provision of supporting documentary evidence. Documentation demonstrating compliance with recognised third party schemes such as SGS (Société General de Surveillance) or wood that has a Forest Law Enforcement, Governance and Trade (FLEGT) license will be accepted. See Mothercare/ELC’s Timber Policy for more information (page 23).


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Child Labour Policy Background Mothercare/ELC recognises the rights of every child to be protected from economic exploitation. Children who work are deprived of their rights to a childhood and education and are at risk of endangering their physical, mental and social well-being. Safeguarding the best interests of children and young people is the guiding principle of any action taken under this policy. Mothercare/ELC’s Code of Practice prohibits the employment of children and the inappropriate employment of young people in our suppliers’ factories. It states the following: 1. There shall be no employment of child labour. A ‘child’ is defined as a person who

is younger than:

The legal minimum age for employment; or

The age of completion of compulsory education, whichever is higher. In any event, suppliers must not employ a person under the age of 15 in any circumstances.

2. If a child is found working directly or indirectly for a supplier, the supplier must

implement a remediation plan that puts the best interests of the child first and enables the child to access and remain in appropriate, quality education until no longer a child.

3. Young people under 18 shall not be employed at night or in hazardous conditions. 4. Workers under the age of 18 must be subject to an appropriate risk assessment

and regular monitoring of health, working conditions and hours of work.

5. A factory is not a safe environment for a child. Where crèche facilities are provided at the factory, they must be safe and hygienic, sufficiently segregated from the factory floor so as not to expose the children to danger and always supervised by appropriately qualified staff. Please see further guidelines for crèche facilities in our Code of Practice under 5. Worker Accommodation and Crèche Facilities Are Suitable.

Implementation Suppliers must have management systems and processes in place to ensure that they do not recruit child labour. Appropriate age proof must be regularly checked with the worker present. Falsified age-proof or using an older person’s identification are common causes of employment of underage workers. It is the supplier’s responsibility to have systems in place to prevent this.


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Suppliers must also have systems to ensure that young workers (under 18 years) are recorded and monitored to protect them from exploitation such as working night shifts or in hazardous environments. Where necessary, Mothercare/ELC can provide guidance on appropriate management systems. Remediation In line with Mothercare/ELC’s policy, if a child is found working directly or indirectly for a supplier, the supplier must implement a remediation plan that puts the best interests of the child first and enables the child to access and remain in appropriate, quality education until no longer a child. In the event of a confirmed case of child labour in our supply base, a tailored programme will be developed to suit the individual situation. This will involve removing the child from work, liaising with their family and helping them to find a school, supporting them through their education and ensuring that the child’s family is paid the legal minimum wage regularly, until the child reaches the working age. The employer must undertake a thorough investigation to detect any further breaches of this policy and implement a remediation programme to cover any other children identified. The employer must also implement a management system to ensure that no further recruitment of children occurs. Mothercare will support and guide this process and it is our expectation that all associated remediation costs will be paid for by the supplier.


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Sub-contracting and Sub-Supplier Policy Background Mothercare/ELC recognises that its suppliers’ factories may sub-contract certain processes in the production of Mothercare/ELC goods. Historically the lack of visibility of these sub-contractors has made them less accessible and therefore less exposed to efforts to improve labour standards. Requirements 1. We must know where our goods are made. Unauthorised sub-contracting will be

treated as ‘zero-tolerance’. 2. Suppliers must follow our Factory Responsible Sourcing Approval Process.

Suppliers must notify us of any intended sub-contracting of primary processes (see below) in advance and these production sites must be approved as a new factory (see page 27).

3. Primary processes involve major transformations of the product in question.

This is dependent on the product type but tends to involve processes without which the product would not be complete. If you are unsure, please speak with your Mothercare/ELC buyer or technologist. As a general rule:

for clothing this is ‘cut to pack’

for toys this is usually injection moulding or sewing, assembly and packing

for home and travel products this is production of key components, assembly and packing.

4. If a primary process takes place at more than one unit, all units must be

declared and approved. 5. Factories, not suppliers, are approved for production. If a current supplier

wishes to use a site which is under their ownership but new to Mothercare/ELC, this must be declared in advance and approved as a new factory.

6. If a cotton spinning, fabric dyeing or processing unit is owned by the same group as a factory, we may also request to carry out an audit of such units.

7. Suppliers must ensure all sub-contractors understand and apply

Mothercare/ELC’s Code of Practice and keep records of any corrective actions as a result of ethical audits.

8. We accept that secondary processes or production of component parts may be

carried out by sub-suppliers. Suppliers must ensure they keep records to demonstrate that all sub-suppliers adhere to Mothercare/ELC’s Code of Practice and must be prepared to provide updates on request.

9. Mothercare/ELC may audit sub-contractors or sub-suppliers of Mothercare or Early Learning Centre products in order to monitor their working conditions and expects suppliers to assist with this.


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Home Worker Policy

Background Working from home for many is a preferred alternative to working in a factory as it can afford greater flexibility with work and family life. Home workers may possess specialist skills for specific products or components. Historically the lack of visibility of home workers in supply chains, combined with their complicated employment status, has made them a particularly vulnerable group of workers. Defining ‘Home work’ Our definition of home work is based upon the ILO definition: ‘work carried out by a person, in his or her home or in any other premises of his or her choice, other than the workplace of the employer for remuneration which results in a product or service as specified by the employer’. Our Position We accept the possible presence of home workers in our supply chains. We acknowledge our responsibility to put policies and procedures in place that seek to ensure the welfare of such workers. Our Commitments We acknowledge that monitoring and improving employment conditions for home workers is a complex issue. Under this home worker policy, we commit to:

a) communicate our position on home working to our stakeholders; b) ensure that the identified presence of home workers in the supply chain will

not lead to the relocation of work or cancellation of orders; and c) work with our suppliers on the sustainable improvement of employment

conditions of home workers in our supply chain. We will aim to do this by following the guidance set out in the Ethical Trading Initiative’s Homeworker Guidelines.

Our Suppliers’ Commitments We expect our suppliers to:

a) commit to a policy of acceptance and transparency of home working; b) communicate this policy to their own supply chains, including home workers

themselves; c) work with us to map supply chains; and d) work with us to implement action plans for improving employment conditions

for home workers where these do not meet those set out in our Code of Practice.


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Migrant Worker Policy Background We acknowledge the existence of migrant labour within global supply chains as workers seek better opportunities for their families and futures. These migrant workers may be vulnerable to exploitation, in particular to offences such as human trafficking and forced labour, as outlined in the UK government’s Modern Slavery Act 2015. Monitoring and improving recruitment and employment conditions for migrant workers are challenging issues but we are committed to work with suppliers on this. Our definition of a migrant worker is based on the ILO definition: ‘a person who migrates from one country to another with a view to being employed otherwise than on their own account’. Our Commitments We commit to:

1. communicate our position on migrant workers to our stakeholders; and 2. work with our suppliers to identify migrant workers in our supply chain and to

improve their recruitment and employment conditions in line with our Code of Practice.

Supplier Responsibilities 1. Recruitment

a) Suppliers must do business with reputable, government registered recruitment agencies and only employ migrant workers who are legally permitted to work in the receiving country.

b) Suppliers must ensure that they adhere to the laws of the host country and

the country of origin of the migrant worker.

c) Migrant workers shall not be expected to pay, directly or indirectly, any deposit or fees to recruitment agencies or agents.

d) Suppliers must pay all costs, including recruitment fees, renewal fees or

travel costs associated with recruiting migrant labour. The supplier must not charge back these costs to the worker.

e) The employment contract must be in a language understood by the migrant

worker. The contract must be between the company and the migrant worker, not the agency or broker.

f) The supplier must explain all employment and living conditions in the host

country in the migrant workers’ language prior to signing an employment contract.

2. Employment

a) All employment conditions for migrant workers should be no less favourable than those afforded to local workers.




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b) Migrant workers shall not be expected to lodge their passports or identity papers with their employer. Only photocopies can be kept on file. Where workers ask that ID documents be held for safekeeping, they must be available to the worker within 24 hours and the supplier must retain a written record of the worker’s agreement to this.

c) Migrant workers will be able to return home for any reason and at any time

without fear of reprisal and without incurring extraordinary debt.

d) Suppliers must pay all travel costs to the worker’s home country for any migrant worker prior to conclusion of contract if the migrant worker must travel home due to a family emergency or if the migrant worker wishes to leave the factory at any time, unless the migrant worker is in clear breach of contract.

e) Detailed records of all migrant workers employed by the supplier must be

kept up to date and must be made available to Mothercare/ELC or its representatives, if requested.

f) All workers must have full and complete control over the monies they earn.

Suppliers will not withhold any monies from workers’ pay for the purposes of insurance, guarantees, bonds, membership or recruitment fees.

g) Suppliers will provide all wages and benefits to workers directly, not via a

third party.

h) Suppliers will have a policy in place regarding the treatment and care of migrant workers who are injured at work, become ill or become pregnant. Health and safety policies should be communicated to all workers.

i) Accommodation provided to migrant workers must be of a safe and decent

standard and meet all local building regulations and other standards outlined under clause five of Mothercare/ELC’s Code of Practice: Worker Accommodation and Crèche Facilities Are Suitable.

j) In line with Article 4 of ILO Convention 181, measures shall be taken to

ensure foreign workers are not denied or impeded in the right to join the union of their choice and the right to bargain collectively.

3. Contract Completion

a) The supplier must arrange and pay for the migrant worker’s airfare or other reasonable transportation costs home.

b) Prior to the migrant worker leaving, the supplier must pay the worker any

wages, benefits or other amounts due.


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Timber Sourcing Policy

Background Mothercare/ELC is committed to the responsible sourcing of timber. This policy sets out requirements of the timber and wood products that we source and ensures that we comply with the European Union Timber Regulations (EUTR – Regulation, EU No. 995/2010). This policy applies to all suppliers of Mothercare and Early Learning Centre branded products and their suppliers. All suppliers must ensure that they keep up-to-date with relevant legislation relating to timber sourcing.

1. Mothercare/ELC will engage with all relevant suppliers to maintain a robust product assessment programme.

2. Mothercare/ELC will continually risk assess relevant suppliers and review

this with third parties where necessary.

3. Wherever possible we will prioritise products manufactured from recycled wood or Forest Stewardship Council (FSC) wood.

4. We will not buy wood or wooden products that originate from known high

conservation value forests as designated by the FSC or from acknowledged controversial sources.

5. We will not use wood from any tree species on the below lists:

Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) list: www.cites.org; and/or

The IUCN Red List of Threatened Species: www.iucnredlist.org.

6. We will seek to use recycled wood wherever possible without compromising product quality, performance or manufacturing requirements.

7. Wherever possible we will seek to source all our cards and gift wrap paper

from a sustainable source.

8. Suppliers must support and promote our policy within their own businesses and supply chains.

9. Suppliers must be able to prove product legality through the provision of supporting documentary evidence. Documentation demonstrating compliance with recognised third party schemes such as SGS (Société General de Surveillance) or wood that has a Forest Law Enforcement, Governance and Trade (FLEGT) license will be accepted.

10. Mothercare/ELC will accept timber from a timber producing country that has

a Voluntary Partnership Agreement with the European Union and has a license which verifies that the timber is legal.

https://www.cites.org/

http://www.cites.org/


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11. Mothercare/ELC will accept timber from the Programme for the Endorsement of Forest Certification, (PEFC) which encompasses schemes such as Canadian Standards Association (CSA) and Sustainable Forest initiative (SFI) and is regarded as coming from a known and legal source.

12. For wooden products which are not certified as FSC, PEFC, CSA or SFI as

described above, Mothercare/ELC will require full visibility of the supply chain including documentary evidence depending on the location of the sourced forest and processing site(s). Such information will include supplier records, product species, country of origin and volumes purchased. Suppliers may be expected to provide this information via a secure third party contracted by Mothercare/ELC.


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Animal Welfare Policy

Background Mothercare/ELC is committed to the responsible sourcing of raw materials derived from animals. Our suppliers must meet the animal welfare standards set out below and must be able to show the provenance of such raw materials. Endangered Species

No products in full or part are to be sourced from endangered species from the Convention on International Trade in Endangered Species list: www.cites.org or from the International Union for the Conservation of Nature red list as critically endangered, endangered or vulnerable: www.iucnredlist.org.

Fur - real fur or real fur pelts must not be used in our products. Angora Rabbit Fibre must not be used in our products. Leather

Leather or skin must only be sourced as a by-product and not the sole purpose of the slaughter of an animal.

Leather or skin must not be obtained whilst the animal is alive or from aborted animals (such as for Astrakhan or Karakul).

Leather or skin from exotic or endangered species must not be used in our products.

Pig skin must not be used.

Cow hide must not be sourced from India. Wool, Cashmere, Mohair, Feathers and Down

Sheep’s wool, lamb’s wool, cashmere, mohair, feathers and down must be sourced from producers which follow high standards of animal welfare: www.gov.uk/guidance/animal-welfare.

Mothercare/ELC does not permit the use of mulesed wool or skins from mulesed sheep.

Animal fibres, feathers and down must not be harvested by live plucking.

Testing on Animals

Mothercare cosmetics, and their ingredients, must not be tested on animals. We will have to cease our trading relationship if a supplier refuses to follow the Code of Practice and/or any other policy included in this RS Handbook.

http://www.cites.org/

http://www.iucnredlist.org/

http://www.gov.uk/guidance/animal-welfare


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4. Supplier Responsible Sourcing Commitment We, as a supplier of product to Mothercare/ELC, agree to comply with Mothercare/ELC’s Code of Practice and Responsible Sourcing Policies and understand that these form part of Mothercare/ELC’s terms and conditions of trading. Name and Role: Company Name: Date: Signature:


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5. Factory Responsible Sourcing Approval Process

This factory Responsible Sourcing (RS) approval process allows suppliers to receive RS approval for factories intending to produce Mothercare and Early Learning Centre (ELC) own brand products. This does not apply to third party branded lines. This section outlines the RS aspect of factory approval but not the entire factory approval process. Please speak with your buyer or technologist for the other aspects of the factory set-up process (such as technology approval) before your factory is fully approved for production. Suppliers wishing to produce for Mini Club must be approved by Boots’ designated third party auditor. The RS team can help arrange this. Note that factories producing for both Mothercare/ELC and Mini Club can use the Mini Club audit for Mothercare/ELC approval, there is no need to provide a further third party audit report. RS approval must be given before a factory can produce for Mothercare, ELC and Mini Club. Suppliers must follow the Factory RS Approval Process when:

a) a current or new supplier wishes to use a new factory; b) a current supplier wishes to use a new factory for Mothercare/ELC goods,

even if it is under their ownership or within the same supplier group; c) factories switch from producing branded goods to producing Mothercare/ELC

branded goods; or d) factories plan to move to new premises (prior to moving).

Factory RS Approval Process – please see flowchart below. For each new factory, please send the following documents to [email protected]:

1. Factory RS approval request form (available from your buyer/technologist or above email address).

2. An acceptable third party ethical audit (see below). Suppliers can share an audit they already have, it does not have to be arranged for Mothercare, but it must meet the below criteria.

Accepted Factory Ethical Audits To demonstrate compliance with our Code of Practice, suppliers must submit the original factory ethical audits which are:

No older than one year

Full initial or full follow-up, not partial

Carried out by an approved independent third party (see below)

Conducted to one of the below standards/types

Updated annually. Accepted Audit Standards/Types

SMETA (SEDEX Members Ethical Trade Audit)

ICTI (International Council of Toy Industries) – Mothercare/ELC accepts ICTI’s designated audit firms.

mailto:[email protected]


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Ethical Trading Initiative Base Code audits or social audits carried out by an approved company (below).

Approved Companies - Arche Advisors - SMT - Bureau Veritas - The Reassurance Network - Elevate (previously Level Works) - TUV Rhineland - Impactt - TUV-SUD - ITS (Intertek Testing Services) - UL - SGS - Verité - Verisio

Mothercare Internal Responsible Sourcing Audits The RS team will confirm if an internal audit will also be carried out and the proposed date. If a factory fails the internal audit, the factory will not be approved, regardless of the result of the third party audit. Audit Gradings and Timescales

Mothercare/ELC’s Responsible Sourcing team will review the factory audit and issue

a grade and follow-up timescales. Follow-up dates depend on the grade and will be

based on the date of the full audit, not partial follow-ups nor on the date of

submission.

The supplier must provide follow-up evidence within the timescales outlined and

may be requested to take part in supplier development training to help improve

performance.

Factories graded Red: Zero-Tolerance will not be approved for production and may

be issued a Corrective Action Plan and asked to demonstrate progress against this in

order to be reconsidered for approval.

Factories which are graded ‘green: low risk’ are expected to submit annual third party factory audits. RS team members will still visit these factories on a periodic basis where possible.

RED: Zero-Tolerance Immediate action needed

New factory – rejected

ORANGE: High Risk Follow up before 3 months

YELLOW: Medium Risk Follow up before 9 months

GREEN: Low Risk Annual audit


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Factory Responsible Sourcing Approval Process

6. Contact Details We have a team of Responsible Sourcing professionals based in Bangladesh, China and India. For any enquiries, please contact [email protected] and you will be directed to the relevant team.

mailto:[email protected]


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