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Ethical Sourcing & Modern Slavery


This Ethical Sourcing & Modern Slavery Policy is built on the principles of the Ethical Trading Initiative and International Labour Organisation Conventions, to ensure there is a commitment that goods and services are sourced in a responsible manner while working with suppliers to improve their social and environmental practices. 

If a supplier is unable to demonstrate a commitment to comply with this Policy, Generation-e may cease its relationship with the supplier. 

This Policy sets out the minimum requirements, expected of our suppliers.  Where the provisions of the law and this Policy address the same topic, whichever affords greater protection applies.  Suppliers are expected to communicate this Policy to their suppliers.  Where reasonably practicable, they should extend the principles of this Policy through their supply chain. 

Generation-e considers bribery and corruption in any form and denial of site access to be business-critical issues resulting in immediate cease of trade.


Business Integrity

  • Suppliers must engage ethically in all dealings and provide transparent documentation and records when requested.
  • Bribes, favours, benefits or other similar unlawful or improper payments, in cash or in kind, are strictly prohibited, whether given to obtain business or otherwise.
  • Suppliers must keep accurate records of all payments made and received in cash or in kind, for audit purposes.


Access to the site of manufacture

  • Factories are required to grant access to the site of manufacture if an independent audit is requested.
  • Access is also to be granted in circumstances where Generation-e wishes to investigate alleged human rights abuses. 

All suppliers must comply with this Policy as well as all local, national and other applicable laws and regulations in the countries in which they operate relating to ethical sourcing and modern slavery 


No forced or bonded labour

  • Employment shall be freely chosen. Suppliers shall;
    • Not use any type of forced labour (any work or service extracted from any person under the menace of any penalty, which work has not been freely chosen by the person), bonded labour (work which is not for compensation received by the worker, but to repay a debt, which is often incurred by another person offering the worker’s labour in exchange) or indentured labour (in which an employer forbids workers from leaving employment at the workers discretion).
    • Respect the freedom of movement of their workers and not restrict their movement by controlling identity papers, holding money deposits or taking any other action to prevent workers from terminating their employment; and
    • Ensure that workers are free to leave their employer after reasonable notice. 


Freedom of association, grievance mechanisms and recourse 

  • Suppliers must respect the rights of workers to lawfully associate or not to associate with groups of their choosing, as long as such groups are legal in the country of operation.
  • Workers should have the right to join or form trade unions of their choosing.  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 and free association and bargaining.
  • Suppliers should not interfere with, obstruct or prevent legitimate related activities, such as collective bargaining.
  • Workers are allowed to select worker representatives.  Representatives should not be discriminated against and should have regular access to company management or appropriate process in order to address grievances and other issues.
  • Suppliers must have a policy in place for workers to approach management on issues of concern, on their own or through worker representatives, confidentially. 


Child labour shall not be used

  • Suppliers must not use child labour.  ‘Child labour’ is defined as any work by a child or young person, which does not comply with the provisions of the relevant ILO standards, and any work that is likely to interfere with that person’s education, or to be harmful to that person’s health or mental, spiritual, moral or social development. ‘Child’ is defined as a person under the age of 15, or below the age at which school attendance is not compulsory under local law, which is older.  ‘Young person’ is defined as a person under the age of 18 but not classified as a child.
  • Suppliers must comply with the minimum legal working age in the country in question or in the absence of such law, by the ILO Convention 138.
  • Suppliers must have the appropriate processes for verifying the age of all employees and job applicants and that the process is documented to ensure no child labour is used.  Policies, procedures, and training must be in place for legally employable juvenile employees (young employees, interns, and apprentices).
  • Children and young persons below the age of 18 must not be employed at night and in hazardous conditions.
  • Suppliers must accept the principles of remediation of child and under age workers, and where such labour is discovered suppliers must establish and implement appropriate remediation for such workers and introduce effective systems to prevent the use of child labour in the future.  Principals of remediation is defined as a program enabling child and underage workers to return to quality education and establish and implement effective systems to prevent the use of child labour in the future.


No illegal labour

  • Suppliers must be able to verify the legal entitlement of their employees to work in the country of employment. 


No harsh or inhumane treatment is allowed

  • Workers shall be treated with dignity and respect, and suppliers must provide a workplace free from harassment, including physical, sexual, verbal or visual behaviour that creates an offensive, hostile or intimidating environment.


Wages and benefits are paid as per legal requirements

  • Wages, overtime compensation and legally mandated benefits and benefits paid for a standard working week must meet as a minimum national or industry standards, whichever is the higher.
  • All workers must be provided with written and understandable information about their employment conditions in respect to wages, before they enter employment, and about the particulars of their wages for the pay period concerned each time that are paid.
  • Deductions from wages as a disciplinary measure is not permitted.  All disciplinary measures must be recorded.
  • Deductions from wages not provided for by law shall not occur without the express permission of the worker concerned.
  • Record keeping must be accurate and transparent. 


Working hours are not excessive

  • Working hours must comply with applicable local laws.
  • Workers should not be required to work more than the maximum hours per week as stipulated by local laws or in the absence of such law by the applicable ILO convention.
  • Overtime shall be agreed, shall not be excessive, shall not be requested on a regular basis and shall be compensated as prescribed by applicable local laws.
  • Workers must have at least one day off in 7 days or two days off in every 14 days.
  • Record keeping on hours worked must be accurate, complete, and transparent always.
  • Working hours exceeding 60 hours a week must not be a systemic occurrence. Employer is required to demonstrate:
    • Exceptional circumstances apply such as unexpected production peaks, accidents, or emergencies.
    • Appropriate safeguards to protect workers’ health and safety have been undertaken.
    • This is permissible by national law.
    • A collective agreement that is freely negotiated with a workers’ organisation representing a significant portion of the workforce, is in place. 


No subcontracting without written approval

  • There must be no sub-contracting unless documented and available for review by Generation-e or an independent auditor, including but not limited to records of subcontractors’ names and locations.
  • Where subcontracting is permitted, suppliers must have adequate policies and processes in place for properly managing subcontracting, to ensure that subcontractors operate in accordance with this Policy and is undertaken strictly in accordance with the contract. 

Working conditions are safe & hygienic

  • Suppliers shall provide a safe and hygienic working environment that is without risk to health, taking into consideration knowledge of the relevant industry and specific hazards.
  • A senior management representative must be assigned responsibility of health and safety.  Trained personnel must administer and oversee health and safety.
  • Workers shall receive adequate and regular training to perform their jobs in a safe manner.  Training records must be maintained accurately.
  • Personal protective equipment and machinery safeguards must be supplied and workers trained in their use.
  • Safeguards on machinery must meet or exceed local laws.
  • Accommodation, if provided, must be clean, safe and meets workers’ basic needs.
  • Access to clean toilet facilities, clean drinking water, and sanitary facilities for food storage and preparation, where applicable, must be provided.
  • Workers have the right to refuse the work that is unsafe.


No discrimination is practised

  • All conditions of employment must be based on an individual’s ability to do the job, not on personal characteristics such as gender, ethnic origin, religion, age, disability, personal beliefs, marital status, sexual orientation, union membership or political affiliation.
  • Suppliers must ensure that they provide an environment where their employees can work without distress or interference caused by harassment, discrimination or any other inappropriate workplace behaviour.
  • Pregnancy testing of employees/potential recruits is not allowed.  Pregnant workers must not be dismissed.


Hiring & Regular employment 

  • Suppliers must provide each worker with a clear, understandable labour contract containing all legally required employment terns, entitlements and conditions.
  • Suppliers should work towards providing permanent employment for workers and avoid labour-only contracting arrangements, consecutive short-term contracts, excessive piece work or false apprenticeship schemes to avoid obligations of regular employment to workers. 


Migrant Workers

  • Migrant workers shall have the same entitlements as local workers as stipulated by local law.
  • Any commissions and other fees in connection with employment of migrant workers must be covered by the employer.
  • The employer must not require the worker to surrender identification documents.
  • Workers employed through a third-party agent or contractors are the responsibility of the suppliers and are thus subject to and must comply with this Policy.


Respect land rights of communities

  • Conduct due diligence and tracing to ensure that sites are not party to land encroachment. 


Structural safety of all supplier buildings and manufacturing sites

  • Premises must be structurally safe.
  • Accommodation provided to workers must be structurally safe. 


Animal Welfare

  • Suppliers must not conduct or commission any animal tests on ingredients, formulations or finished products.
  • Suppliers must ensure animals are treated humanely and with respect


Environmental Standards

The Supplier shall, as a minimum, comply with all applicable laws and regulations relating to the environmental impact of their business.  They will maintain procedures for notifying local authorities in the event of an accident or incident which may adversely affect the environment as a result of their operations. 

Supplier compliance with environmental law includes any international or applicable local laws affecting the source of materials and processes used to manufacture products.  Detailed performance standards are a matter for the Supplier but should at least address the following: 

  • Environmental Permits and Reporting - all required environmental permits (e.g. discharge monitoring), approvals and registrations are to be obtained, maintained and kept current and their operational and reporting requirements are to be followed.
  • Waste management – waste of all types, including water and energy, shall be reduced or eliminated at the source or by practices such as modifying production, maintenance and facility processes, materials substitution, conservation, recycling and re-using materials. Effective controls of waste in respect of ground, air and water pollution shall be adopted.  In the case of hazardous materials, emergency response plans shall be in place.  Air emissions, wastewater and solid waste generated from operations, industrial processes and sanitation facilities are to be characterised, monitored, controlled and treated as required prior to discharge or disposal.
  • Hazardous Substances - chemical and other materials posing a hazard if released to the environment are to be identified and managed to ensure their safe handling, movement, storage, use, recycling or reuse and disposal.
  • Packaging and paper – unnecessary use of materials shall be avoided and recycled materials shall be used wherever appropriate.
  • Conservation – processes and activities shall be monitored and modified as necessary to ensure conservation of scarce resources, including water, flora and fauna and productive land.
  • Energy use – all production and delivery processes shall be based on maximising efficient energy use and minimising harmful emissions.
  • Product Content Restrictions – the Supplier shall adhere to all applicable laws, regulations and customer requirements regarding prohibition or restriction of specific substances, including labelling for recycling and disposal.
  • Product selection – the Supplier shall work with and aid Generation-e in selecting products which are environmentally beneficial. 


Social Procurement Objectives

Generation-e’s priority objectives include:

  • Opportunities for indigenous people

  • Opportunities for those living with disability

  • Gender equality and safety

  • Opportunities for disadvantaged

  • Supporting safe and fair workplaces

  • Sustainable social enterprises and indigenous business sectors

  • Support for regions

  • Environmentally sustainable outputs and business practices

  • Implementation of environmental objectives


Generation-e is committed to social procurement and makes the following commitments:

  • Procurement is a core business and strategic function.

  • The organisation is committed to advancing social and sustainable objectives through procurement.

  • Social procurement is embedded throughout the procurement process (e.g. in procurement related systems, policies, and processes for planning, sourcing and contract management).

  • Our management of supplier and stakeholder relations is focussed on and capable of accommodating our social procurement commitments.