This document has been compiled to assist all suppliers & factories involved in the production of Celtic & Co products to protect the integrity and reputation of our brand. It is to also ensure compliance with Celtic & Co’s sustainability, ethical trade and intellectual property policies.

This document is intended to be used as a guideline, country laws and regulations are the basis of this document and all factories and suppliers must comply with the relevant local laws and regulations, if you are unsure of what these are we encourage you to research this area and take any legal advice or help as appropriate.

Sustainability and providing a good quality naturally sourced product are at the heart of everything we do here at Celtic & Co., and we’d like all suppliers to offer transparency around their own practices so we can communicate this information clearly and accurately to our customers.

We believe that working together with our supply chain we can strengthen our businesses and improve the quality of both our products and the lives of people impacted by Celtic & Co through the promotion of safe and fair working conditions and responsible management of environmental and social issues in our supply chains.

The following standards are based on the Ethical Trading Initiative Base Code, reflecting relevant international standard labour practices. We want to ensure that all factories, suppliers, sub-contractors, raw material suppliers, production sites or finished goods vendors can comply with these codes and be honest with any Celtic & Co staff or Third-party auditors about any issues they have. If you are a member of the ETI then please let us know!

Please note that references to “factories” also covers the following: Finished Goods Vendors, raw materials suppliers, production sites, sub-contractors.

• EMPLOYMENT IS CHOSEN FREELY: There should be no forced, bonded or involuntary prison labour. Workers are not required to lodge “deposits” or identification papers with their employer and are free to leave their employer after a reasonable notice period.

• FREEDOM OF ASSOCIATION AND THE RIGHT TO COLLECTIVE BARGAINING ARE RESPECTED: workers have the right to join or form trade unions of their own choice and bargain collectively. The employer should adopt an open attitude to these activities and work representatives must not be discriminated against and should have access to carry out their representative duties at work.
  Where the right to freedom of association and collective bargaining is restricted by local law the employer should facilitate and not hinder the development of parallel means for independent and free association and bargaining.

• WORKING CONDITIONS ARE SAFE AND HYGIENIC: Workers should receive regular and recorded health and safety training and such training shall be repeated for new or re-assigned workers. Access to clean toilet facilities, drinking water and appropriate facilities for food storage should be provided. There should be a senior member of management staff responsible for health and safety. A safe and hygienic working environment should be provided; steps should be taken to prevent accidents and injury to health.

• CHILD LABOUR: There must be NO child labour. Staff under the age of 18 must not be employed in hazardous conditions, and not at night.

• YOUNG WORKERS (between 16 & 18): Employers are to keep a list of all young workers, ensuring working hours do not exceed local law. Young workers should not perform the following tasks, including, but not limited to, the use of chemicals, dust machines, tools or night work.Young workers should have access to education and should not be discouraged from additional education opportunities. If they are employed under an apprenticeship scheme / status the factory should follow the national rules governing such types of employment. No young workers should work overtime, which includes weekends and paid national holidays and the factory must comply with all laws regarding their wages and benefits.

• LIVING WAGES: All wages and benefits paid for a standard working week must meet a minimum of National legal standards or the Industry benchmark standard, whichever is higher. The factory must supply written information regarding their employment conditions and wages before commencing employment and staff must be informed in writing of the pay period (how and when they will be paid and any deductions that may be taken). Deductions from wages for disciplinary means is not permitted, nor any deductions (except those required by national law) should be taken without written permission of the employee. Any disciplinary measures that need to be taken must be recorded.

• WORKER FACILITIES: All facilities available to the workers must be clean, well maintained, well-lit and properly ventilated with the correct number of toilets / washing facilities for the number of workers and access to them are not restricted.
  Areas for eating and rest are specifically used and designed for, drinking water should have unrestricted access by the worker and measures are taken to eliminate dust and the presence of insects and rodents.

• EXCESSIVE WORKING HOURS: Working hours should comply with national laws or industry standards whichever provides the greatest protection. Workers shall not, on a regular basis be required to work more than 48 hours per week or 11 hours on any day and must be provided with 24 consecutive hours off for every 7-day working period. Overtime must be voluntary and not exceed 12 hours per working week and must not be demanded on a regular basis. Regular and reasonable breaks of a minimum of 15mins every 4 hours should be allowed. All national laws concerning pregnant women must be strictly enforced.

• DISCRIMINATION: There must not be any discrimination in hiring, compensation, access to training, promotion, termination (or retirement) based on race, caste, national origin, region, age, disability, gender, marital status, sexual orientation, union membership or political affiliation. The factory / supplier must have a documented grievance policy which covers how discrimination can be dealt with.
  Pregnant women should be allowed to return to work after giving birth if they so choose. Pregnancy testing and questions relating to pregnancy must not be part of the recruitment procedure. Pregnancy tests should only be used if required by national law or if it is to comply with local laws regarding heavy lifting or use of chemicals. Men and Women should receive equal pay for equal work.

• REGULAR EMPLOYMENT IS PROVIDED: Work performed must be based on an employment relationship established through national law. Regular employment must not be avoided using fixed term contracts, labour only contracting, sub-contracting or home working arrangements or through training and apprenticeship schemes where there is no intent to impart skills or provide regular employment.
  Workers contracts must be provided in a local language and documentation showing the worker is legally permitted to work must be kept on site.
• ENTITLEMENT TO WORK AND MIGRATION: Factories should only employ workers with the legal right to work in that country and the factory is responsible for validating this by reviewing original documentation. If employment agencies are used, they can only supply workers that are registered with them.

• NO HARSH OR INHUMANE TREATMENT IS ALLOWED: Physical, verbal and sexual abuse or discipline or the threat of abuse, harassment or other forms of intimidation are prohibited. Factories must have a formal grievance disciplinary procedure with documented records of individual hearings and this procedure will support fair treatment of staff. Official disciplinary procedures must follow local laws and regulations and dismissal should only be used on the grounds allowed by law and must be officially documented.

• SEARCHES: Best practice avoids the need for searches by having CCTV or a management system in place for control of products leaving and entering the building. However, when it is necessary to conduct employee searches:
  • Searches must be communicated to workers in their contract and made clear before joining.
  • Searches must be applied fairly and without discrimination.
  • Searches should be conducted sensitively and in a private area respecting male/male and female/female.
  • All those conducting searches should be trained to do so and have a full understanding of the human rights issues involved
  • Workers must not be penalised for time spent queuing
• ENTITLEMENT TO WORK AND MIGRATION: Factories should only employ workers with the legal right to work in that country and the factory is responsible for validating this by reviewing original documentation. If employment agencies are used, they can only supply workers that are registered with them.

• SUBCONTRACTING AND HOME WORKING: Factories who sub-contract must inform the relevant Product Developer of their intent. Sub-Contractors are not permitted to sub-contract further without permission of Celtic & Co. Factories who use home workers must inform the relevant Product Developer and should be managed correctly in accordance to this manual.

• HEALTH AND SAFETY: Relevant national and international laws and standards for health and safety must be followed and standards should be regularly revised to ensure any updates and changes to said laws are met. The factory health and safety policy must be communicated to all workers and be written in both English and local languages ensuring all employees understand.

• FIRST AID: A first aid box must be provided for every 100 workers, if the factory is spread out over more than one floor or building then there must be one box per floor or building. There should also be an allocated, responsible first aider for the use and maintenance of the content of the kit and there should be at least one trained first aider present per first aid kit and shift. The first aid box must be regularly checked for stock levels and expiry dates and must be clearly indicated with clear signage and be left unlocked during working hours. Where chemicals are being used a foot operated eye wash station should be provided.

• FIRE SAFETY: There are three main priorities that must be addressed:
  • Reducing the risk of fire
  • Having an effective emergency evacuation plan
  • Having adequate firefighting equipment readily available for use

In order to implement the above, management should nominate staff which are to be authorised and trained in the use of firefighting equipment and procedures during a fire related emergency. These include arranging fire drills at least twice a year or more frequently if there is a high turnover of staff. For this a designated safe assembly point should be communicated to the workers. Fire alarms should be tested weekly and evacuation plans to be reviewed on a regular basis with appropriate plans for any disabled or pregnant employees.

Factories are to also ensure there is adequate numbers and correct for purpose and functioning fire extinguishers provided and located in easily accessible and visible positions. These should never be locked away. Fire escape routes and exits must also be always kept clear and not chained or padlocked shut during working hours. For fire escape doors used by more than 50 people they should open outwards in the direction of escape and should not be locked or need a key to be opened.

• ELECTRICAL SAFETY: Damage to electrical equipment and wires must be repaired as soon as possible and the equipment should not be used until it has been repaired. Overloading electrical equipment can cause it to become hot and become a fire hazard. Electrical equipment must be regularly checked by a trained professional (at least every three years) and a written maintenance book for such equipment and installations should be kept.

• ANNUAL SAFETY CERTIFICATION: The following should be independently and externally checked annually: Passenger lifts, lifting equipment and lifting tackle; pressure systems such as compressed air receivers and pipework, steam and pressured hot water boilers, gas boilers and fire sprinkler systems.

• MACHINE SAFETY: Extra care must be taken in the cutting room and this area should always be kept clean and tidy. Person Protective Equipment (PPE) must be provided e.g. chain mail cutting gloves, dust masks etc. Workers must be specifically trained to operate any dangerous equipment.

• NOISE AND LIGHT LEVELS: The factory is responsible for checking noise levels where machinery or processes considered to be noisy are used. If the levels exceed the recommended maximum, then ear defenders (PPE) must be provided and used. If noise levels register above 85dba earplugs should systematically be provided. The factory should also ensure that lighting levels are enough for each workstation and processes being carried out there.

• PROTECTION OF THE ENVIRONMENT : Factories must carry out work in accordance with national laws, regulation, administrative practices and polices relating to the preservation of the environment in countries they operate; as well as in accordance with the relevant international agreements, principles, responsibilities, objectives and standards in relation to the environment.

• INTELLECTUAL PROPERTY: These are logos, brand names and designs protected and owned by Celtic Sheepskin Co ltd, trading as Celtic & Co. These are exclusive to Celtic & Co. and cannot be used by any 3^rd party without written consent of Celtic & Co. We take the abuse of our IP seriously, this includes but is not limited to the copying of product designs, selling unauthorised production from the factory, incorporating trademarks or logos into other non-Celtic & Co. products, using Celtic & Co. patterns or materials for other customers. Please report any theft of Celtic & Co. products immediately to your relevant Product Developer.