Ethical and Social Compliances Policies

Introduction

We have joined with our Supply Chain Partners to ensure we work together in a fair and equitable environment that supports Sustainable Ethical outcomes that focus on long term benefits to our Supply Chain Workers, their families, and the environment in which they are employed. Whilst we do not own the factories where our products are manufactured, we have established strong partnerships with the business owners, extending from smaller operations employing dozens of workers through to large enterprises with hundreds or thousands of workers.

The fair treatment and safe working conditions of our Supply Chain workers can only be achieved and maintained through a commitment to Fair and Responsible Purchasing and production practices that take into consideration, price negotiations and factory capacity ability to meet the demands of high and low production levels based on customer demands and requirements.

Our production team work closely with our Supply Chain Partners to ensure that production capacity planning reduces the risks associated with excessive worker overtime where negative outcomes including health and safety violations and the use of un-disclosed outsourcing and outworkers who are exposed to wage under payments and poor working conditions can occur.

Our teams understand that they have an important responsibility to create outcomes where workers human rights and payment of mandated living wages are respected and maintained at all times. In late 2022 we started to roll out a wide range of selected SEDEX eLearning modules to all internal team members, factory management and staff where focus covers Access to Grievance reporting, Responsible Buying requirements, Working hours and Workers Health and Safety.

Our Compliance Support Partners

Hotsprings Brands production team closely with our Ethical, Social and Sustainability Compliance team and our primary support partners SEDEX and the Ethical Trading Initiative to ensure that our core mandatory onboarding programs are met including improvement assistance projects to ensure that our onboarding programs are followed at all times including ongoing improvement assistance projects.

1. All manufacture facilities must sign, stamp, and return HSB Ethical and Social Compliance agreements.
2. All manufacturing facilities must satisfactorily complete HSB New Garment Supplier Capacity Assessment Questionnaire.
3. All supplier factories are required to join SEDEX as Supplier members and the following steps must be completed before production orders can proceed:
1. Factories must complete both Self Audit Questionnaires (SAQ’s) included Covid 19 SAQ in their SEDEX platform. Completed SAQ’s will be reviewed, and risk ratings will be communicated to HSB Team and supply chain partners.
2. Appropriate HSB team support will be allocated to High/Medium Risk outcomes to assist supplier factories with mitigation and improvement programs.
3. End of season factory reviews will be undertaken by HSB compliance and production teams. 

Buying/Production Team Responsibilities

HSB Responsible Sourcing commitments and practises are based on The Joint Ethical and Trading Initiatives Guide to Buying responsibly. Guide to buying responsibly | Ethical Trading Initiative (ethicaltrade.org) Buying/Production Teams must review all updated reports available via our SEDEX membership https://www.sedex.com/ where updates will be provided of factories where:

1. Workers Human Rights Potential Risks will be assessed via:
1. Reviews of Country Risks.
2. Tier mapping of Supply Chains.
3. Identification of worker risks by sector, nature of work, type of worker and employment relationships.
4. Reviews of recruitment processes.
5. Workers access to freedom of association and collective bargaining.
2. Team job descriptions and responsibility agreements are under review and will incorporate responsible sourcing goals and KPI’S into all personal development plans.
1. Our relationships with Suppliers must not be based on Unequal Power in balances of successful and efficient suppliers and their operations are keystones to business success and environments where mutual respect always operates.
2. Inaccurate or poor production specifications together with improper production forecasting to be always controlled.
3. Aggressive and unrealistic price negotiation are not justified due to adverse impacts covering Workers wages and health/safety conclusions.
4. Frequent and unwarranted changes to specifications must be avoided and controlled.
5. Unrealistic short lead times and placement of late orders must be controlled at all times. Factory capacity abilities can be reviewed via HSB Factories Capacity Assessment and reviews of previous factories performance ratings.
6. Excessive product sampling and re sampling request must be always controlled.
7. Shipping delays are to be mutually agreed with suppliers at all times and outstanding $ payments are to be actioned within agreed time frames.
8. Ongoing reviews of Factory Ethical Compliance Operations are required; in conjunction with HSB Ethical and Sustainability management.
9. No new factories or suppliers can be onboarded to the business unless all requirements under Core Mandatory Requirements have been successfully completed.
10. Buying/Purchasing team members must successfully complete all internal training and information skills training programs.

Conclusion

Our journey forward with our Supply Chain Partners to achieve a successful and ethically responsible environment that protects workers’ rights, entitlements, health and safety and enables the recognition of their importance and contribution to our combined successes is supported by the commitments seen in this document. Features of our journey will see ongoing improvement projects where regular updates will be shared across workers and team members.