Column Radiators Ltd Ethical Sourcing Policy

Statement of Compliance

This Ethical Sourcing policy applies to Column Radiators Ltd, Period Style Limited, Cast Iron Radiators Limited, our subsidiaries and affiliates.

Our Colrads Column Radiators and Cast Iron Radiators are assembled and finished at our factory in North Yorkshire. Ethical sourcing and community engagement is as important to the success of our business as our industry leading standards of quality control.

Column Radiators are committed to taking a leadership role in subscribing to high standards of ethical conduct by working with our suppliers to positively influence our social, ethical and environmental performance. We recognise our corporate and social responsibilities reside as much in our supply chain as in our own activities. We continually seek to ensure that the products and services we source are produced using traditional techniques and subscribe to the highest possible ethical standards.

Craftsmen and suppliers who respect, comply with or interpret at the organisational level relevant laws, regulations treaties, covenants or other agreements are preferred. We look for suppliers that demonstrate a commitment to implementing policies and practices consistent with and complementary to, our own. We believe these considerations to be the platform from which responsible behaviours can build.

A. Employment Standards 
Column Radiators Ltd expects suppliers to adopt sound labour practices and to treat their employees fairly in accordance with local laws and regulations regarding labour and employment. Column Radiators Ltd expects its suppliers to adhere to the following requirements:
Employment is freely chosen - Suppliers will not use forced, bonded or involuntary prison labour. Workers are not required to lodge `deposits' or their identity papers with the employer and are free to leave once their shift ends or after giving their employer reasonable notice.
Child Labour - Suppliers shall not use child labour. “Child” is defined as a person who is younger than the local legal age for completing compulsory education. Suppliers shall verify the age of their workers and maintain copies of their workers’ proof of age. Suppliers shall follow all applicable laws, regulations and the ILO standards regarding working hours and conditions for all employees.
Involuntary Labour - Suppliers shall not use involuntary labour. “Involuntary Labour” is defined as work or services which are extracted from any person under threat or penalty for its non-performance and for which the worker does not offer himself or herself voluntarily, and includes all manner of prison, bonded, indentured and forced labour. Workers must be free to leave once their shift ends and free to leave their employment after reasonable notice.
Immigration Law Compliance - Suppliers shall only employ workers with a legal right to work, including workers obtained through an employment agency. Workers’ legal right to work must be validated by reviewing original documentation prior to commencement of work.
Non Discrimination or Harassment - Suppliers shall employ workers solely on the basis of their ability to do the job and shall not discriminate on the basis of age, gender, racial characteristics, maternity or material status, pregnancy, sexual orientation, disability, national, cultural, religious or personal beliefs in relation to hiring, wages, benefits, termination or retirement. There shall be no inappropriate medical testing used in determining employment. Physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation shall be prohibited.
Working conditions are safe and hygienic - Suppliers shall provide a safe and hygienic working environment, including monitoring of compliance with applicable legislation, regulations and the ILO standards. Suppliers shall ensure that personal protective safety equipment is available and workers are adequately trained in its use. Safeguards on machinery must meet or exceed local laws, and workers shall be provided with all appropriate protective equipment.
Working Hours - All working hours will comply with national laws and benchmark industry standards, whichever affords greater protection. Overtime work should be voluntary, and overtime should not be requested on a regular basis. Suppliers shall guarantee workers breaks and days off in compliance with applicable law.
Wages and Benefits - Suppliers shall provide wages and benefits that comply with all local laws and regulations or match prevailing local manufacturing or industry rates, whichever is higher. Overtime pay shall be calculated at the legally required rate, regardless of whether workers are compensated hourly or by piece rate. Regular employment is provided

To every extent possible suppliers must ensure work performed must be on the basis of a recognised employment relationship 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 imposed use of labour-only contracting or 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 and prevalent use of fixed-term contracts of employment.

B. Environmental Standards 
Suppliers shall as a minimum comply with all applicable laws and regulations relating to the environmental impacts of their business, and maintain procedures for notifying local authorities in the event of an environment accident resulting from the supplier’s operation. Supplier compliance with environmental law shall include any international or applicable local laws affecting the source of materials and processes used to manufacture products. Detailed performance standards are a matter for suppliers, but should address at least the following:
Waste Management: - Waste is minimised and items recycled whenever this is practicable. Effective controls of waste in respect of ground, air, and water pollution must be adopted. In the case of hazardous materials, emergency response plans must be put in place.
Packaging and Paper: - Undue and unnecessary use of materials shall be avoided, and recycled materials should be used whenever 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 in certain situations.
Energy Use: - All production and delivery processes, including the use of heating, ventilation, lighting, IT systems and transportation, must be based on the need to maximise efficient energy use and to minimise harmful emissions.
Product Selection: - Proactively work with and provide assistance to Column Radiators in selecting products which are environmentally beneficial.

C. Confidentiality
Suppliers and contractors must protect Column Radiators Limited information, not disclose it to any third party, and use it only for the business of Column Radiators Ltd.

D. Monitoring and Compliance 
Generally, suppliers will not be engaged by Column Radiators Ltd unless the Ethical Sourcing Policy can be complied with and Column Radiators Ltd considers performance is acceptable, or genuine attempts are being made to address violations of this policy. Column Radiators Ltd reserves the right to audit compliance with this policy or appoint a third party to conduct an audit. Any violations will be reported to the supplier’s management for their attention and, if appropriate corrective action. Regardless of corrective action required, Column Radiators Ltd may terminate its relationship with any supplier who does not comply with the Ethical Sourcing Policy, without liability to the supplier for damages resulting from termination.