Code of Conduct

According to the principles of amfori BSCI (as of January 2014)


FOREWORD

ELTEN GmbH is a leading company in the sector of safety footwear with more than 100 years of traditionand know-how.
The combination of tradition, the use of the latest production technologies and our professional approach makes us strong. We focus on the needs of the people and our products contribute on a daily basis to make the work environment a safer place.

Our high quality products are manufactured under strict environmental protection requirements and decent working conditions. Only that way we can meet the high standards placed on ourselves and on our products.

Our successful existence for generations is only possible because of the economic, ecological and social aspects that have always been a part of our corporate policy. Our long-term relationships to customers, suppliers and other business partners are based on mutual trust and require that all involved parties respect the principles of honesty, reliability and professionalism.

This document is an adoption of the amfori BSCI Code of Conduct in the version of January 2014 which was extended by ELTEN-specific requirements.
As a company that has agreed to the amfori BSCI Code of Conduct, we have adapted the document to our own layout to better contribute to the amfori BSCI cascade effect.


1. SCOPE

The standards and requirements set out in this Code of Conduct apply to all locations and business units of ELTEN GmbH, to all our contractors, their sub-suppliers and subcontractors within the footwear and leather goods manufacturing chain. All applicable local laws and regulations, industry minimum standards and conventions of the International Labour Organization (ILO), the United Nations (UN) Global Compact, the OECD Guidelines for Multinational Enterprises as well as all internationally recognized environmental standards are valid.
Obeying domestic laws is the first obligation of the ELTEN business partners. In countries where domestic laws and regulations are in conflict with, or set a different standard of protection than the amfori BSCI Code of Conduct, ELTEN GmbH and our contractual partners will seek ways to abide by the principles that provide the highest protection to the workers and environment.


2. ETHICAL BUSINESS BEHAVIOUR

ELTEN GmbH pursues legally irreproachable and accepted business practices and fair competition. In particular, it will not participate in any collusion or behave in a way that contradicts the German or European anti-trust laws or those of any other State in which the ELTEN GmbH operates.
ELTEN business partners observe this principle when, and without prejudice to the goals and expectations set out in this chapter, they are not involved in any act of corruption, extortion or embezzlement, nor in any form of bribery – including but not limited to – the promising, offering, giving or accepting of any improper monetary or other incentive.
ELTEN business partners are expected to keep accurate information regarding their activities, structure and performance, and should disclose these in accordance with applicable regulations and industry benchmark practices.
ELTEN business partners should neither participate in falsifying such information, nor in any act of misrepresentation in the supply chain.
Furthermore, ELTEN business partners should collect, use and otherwise process personal information (including that from workers, business partners, customers and consumers in their sphere of influence) with reasonable care. The collection, use and other processing of personal information is to comply with privacy and information security laws and regulatory requirements.


3. WORKERS INVOLVEMENT AND PROTECTION

ELTEN business partners should establish good management practices that involve workers and their representatives in sound information exchange on workplace issues, and allow for appropriate measures for protecting workers in line with the aspirations of the amfori BSCI Code of Conduct. ELTEN business partners should take specific steps to make workers aware of their rights and responsibilities.
In addition, ELTEN business partners are required to build sufficient competence among employers, managers, workers and workers representatives in order to embed these practices in the business operation successfully. Continuous education and training at each level of work is essential, particularly with regard to Occupational Health and Safety.
ELTEN business partners should establish or participate in effective operational-level grievance mechanisms for individuals and communities who may be adversely impacted. Even where judicial systems are effective and well-resourced, grievance mechanisms may offer particular advantages such as speed of access and remediation, reduced costs and transnational reach.


4. NO CHILD LABOUR

ELTEN business partners observe this principle when they do not employ directly or indirectly, children below the minimum age of completion of compulsory schooling as defined by law, which shall not be less than 15 years, unless the exceptions recognised by the ILO apply.
ELTEN business partners must establish robust age-verification mechanisms as part of the recruitment process, which may not be in any way degrading or disrespectful to the worker. This principle aims to protect children from any form of exploitation. Special care is to be taken on the occasion of the dismissal of children, as they can move into more hazardous employment, such as prostitution or drug trafficking. In removing children from the workplace, ELTEN business partners should identify in a proactive manner, measures to ensure the protection of affected children. When appropriate, ELTEN business partners shall pursue the possibility to provide decent work for adult household members of the affected children’s family.


5. SPECIAL PROTECTION FOR YOUNG WORKERS

ELTEN business partners observe this principle when they ensure that young persons do not work at night and that they are protected against conditions of work which are prejudicial to their health, safety, morals and development, without prejudice to the specific expectations set out in this principle.
Where young workers are employed, ELTEN business partners should ensure that (a) the kind of work is not likely to be harmful to their health or development; (b) their working hours do not prejudice their attendance at school, their participation in vocational orientation approved by the competent authority or their capacity to benefit from training or instruction programs.
ELTEN business partners shall set the necessary mechanisms to prevent, identify and mitigate harm to young workers; with special attention to the access young workers shall have to effective grievance mechanisms and to Occupational Health and Safety trainings schemes and programmes.


6. NO BONDED LABOUR

ELTEN business partners shall not engage in any form of servitude, forced, bonded, indentured, trafficked or non-voluntary labour. The protection of human dignity and respect must always be ensured.
ELTEN business partners will risk allegations of complicity if they benefit from the use of such forms of labour by their business partners.
ELTEN business partners shall act with special diligence when engaging and recruiting migrant workers both directly and indirectly.
ELTEN business partners shall allow their workers the right to leave work and freely terminate their employment provided that workers give reasonable notice to the employer.
ELTEN business partners shall ensure that workers are not subject to inhumane or degrading treatment, corporal punishment, mental or physical coercion and/or verbal abuse.
The hiring process must not require the employees to deposit money or personal documents.


7. DISCIPLINARY ACTION

All disciplinary procedures must be established in writing, and are to be explained verbally to workers in clear and understandable terms by all ELTEN business partners.
Any form of disciplinary action such as verbal or physical abuse and violence, psychological or sexual abuse, coercion and other forms of intimidation are prohibited. The system of rules and their consequences must be known by the employees.
In case of unacceptable disciplinary action exerted by managers, this behaviour must have appropriate consequences for them. The workers must be given an opportunity to complain (anonymously) about disciplinary actions and abuse.


8. THE RIGHTS OF FREEDOM OF ASSOCIATION AN COLLECTIVE BARGAINING

ELTEN business partners shall: (a) respect the right of workers to form unions in a free and democratic way; (b) not discriminate against workers because of trade union membership and (c) respect workers’ right to bargain collectively.
ELTEN business partners shall not prevent workers’ representatives from having access to workers in the workplace or from interacting with them.
When operating in countries where trade union activity is unlawful or where free and democratic trade union activity is not allowed, business partners shall respect this principle by allowing workers to freely elect their own representatives with whom the ELTEN business partner can enter into dialogue about workplace issues.


9. NO DISCRIMINATION

ELTEN business partners shall not discriminate, exclude or have a certain preference for persons on the basis of gender, age, religion, race, caste, birth, social background, disability, ethnic and national origin, nationality, membership in unions or any other legitimated organisations, political affiliation or opinions, sexual orientation, family responsibilities, marital status, diseases or any other condition that could give rise to discrimination. In particular, workers shall not be harassed or disciplined on any of the grounds listed above. Concerning hiring, compensation, training, promotion, termination or retirement, the equality principle is to be followed.


10. DECENT WORKING HOURS

ELTEN business partners observe this principle when they ensure that workers are not required to work more than 48 regular hours per week, without prejudice to the specific expectations set out hereunder. However, the amfori BSCI recognizes the exceptions specified by the ILO.
Applicable national laws, industry benchmark standards or collective agreements are to be interpreted within the international framework set out by the ILO.
In exceptional cases defined by the ILO, the limit of hours of work prescribed above may be exceeded, in which case overtime is permitted.
The use of overtime is meant to be exceptional, voluntary, paid at a premium rate of not less than one and one-quarter times the regular rate and shall not represent a significantly higher likelihood of occupational hazards. Furthermore, Business Partners shall grant their workers with the right to resting breaks in every working day and the right to at least one day off in every seven days, unless exceptions defined by collective agreements apply.


11. FAIR REMUNERATION

ELTEN business partners observe this principle when they respect the right of the workers to receive fair remuneration that is sufficient to provide them with a decent living for themselves and their families, as well as the social benefits legally granted, without prejudice to the specific expectations set out hereunder.
ELTEN business partners shall comply, as a minimum, with wages mandated by governments’ minimum wage legislation, or industry standards approved on the basis of collective bargaining, whichever is higher.
Wages are to be paid in a timely manner, regularly, and fully in legal tender. Partial payment in the form of allowance “in kind” is accepted in line with ILO specifications. The level of wages is to reflect the skills and education of workers and shall refer to regular working hours.
Deductions will be permitted only under the conditions and to the extent prescribed by law or fixed by collective agreement.
The legally required social security contributions must be implemented. In countries where continued payin case of illness is not regulated, the employees must be adequately remunerated in sickness absence days. In the event that the employees do not have access to free medical care, the company has to bear the costs of medical care for the employees.
Illegal deductions from wages (e.g. as unlawful disciplinary action) are not allowed. All employees shall receive full and comprehensible information on the composition of their compensation at regular intervals.


12. NO PRECARIOUS EMPLOYMENT

ELTEN business partners observe this principle when, without prejudice to the specific expectations set out in this chapter, (a) they ensure that their employment relationships do not cause insecurity and social or economic vulnerability for their workers; (b) work is performed on the basis of a recognised and documented employment relationship, established in compliance with national legislation, custom or practice and international labour standards, whichever provides greater protection.
Before entering into employment, ELTEN business partners are to provide workers with understandable information about their rights, responsibilities and employment conditions, including working hours, remuneration and terms of payment.
Workers have the right to a written employment contract at the beginning of the employment relationship. The following topics must be included: position, start of work, working hours, remuneration, leave entitlements, notice periods and conditions, payment date, probationary period and signatures of the contractor including date. Each employee will receive a copy of the employment contract after signing. Consecutive temporary employment contracts are not tolerated.
ELTEN business partners should aim at providing decent working conditions that also support workers, both women and men, in their roles as parents or caregivers, especially with regard to migrant and seasonal workers whose children may be left in the migrants’ home towns.
ELTEN business partners shall not use employment arrangements in a way that deliberately does not correspond to the genuine purpose of the law. This includes – but is not limited to – (a) apprenticeship schemes where there is no intent to impart skills or provide regular employment, (b) seasonality or contingency work when used to undermine workers’ protection, and (c) labour-only contracting. Furthermore, the use of sub-contracting may not serve to undermine the rights of workers.


13. OCCUPATIONAL HEALTH AND SAFETY

ELTEN business partners observe this principle when they respect the right to healthy working and living conditions of workers and local communities, without prejudice to the specific expectations set out hereunder. Vulnerable individuals such as – but not limited to – young workers, new and expecting mothers and persons with disabilities, shall receive special protection.
ELTEN business partners shall comply with occupational health and safety regulations, or with international standards where domestic legislation is weak or poorly enforced.
The active co-operation between management and workers, and/or their representatives is essential in order to develop and implement systems towards ensuring a safe and healthy work environment. This may be achieved through the establishment of Occupational Health and Safety Committees.
ELTEN business partners shall ensure that there are systems in place to detect, assess, avoid and respond to potential threats to the health and safety of workers. They shall take effective measures to prevent workers from having accidents, injuries or illnesses, arising from, associated with, or occurring during work. These measures should aim at minimizing so far as is reasonable the causes of hazards inherent within the workplace.
ELTEN business partners will seek improving workers protection in case of accident including through compulsory insurance schemes.
ELTEN business partners shall take all appropriate measures within their sphere of influence, to see to the stability and safety of the equipment and buildings they use, including residential facilities to workers when these are provided by the employer as well as to protect against any foreseeable emergency. ELTEN business partners shall respect the workers’ right to exit the premises from imminent danger without seeking permission.
ELTEN business partners shall ensure adequate occupational medical assistance and related facilities.
ELTEN business partners shall ensure access to drinking water, safe and clean eating and resting areas as well as clean and safe cooking and food storage areas. Furthermore, ELTEN business partners shall always provide effective Personal Protective Equipment (PPE) to all workers free of charge.


14. PROTECTION OF THE ENVIROMENT

ELTEN business partners observe this principle when they take the necessary measures to avoid environmental degradation, without prejudice to the specific expectations set out in this chapter.
They assess significant environmental impact of operations, and establish effective policies and procedures that reflect their environmental responsibility. They will see to implement adequate measures to prevent or minimise adverse effects on the community, natural resources and the overall environment.
Environmental protection is an integral part of our corporate policy. An environmentally and socially sustainable production is to be sought by all business partners. The effects on the environment must be minimized, and preventive measures have to be taken. Legal regulations, environmental standards, internationally established standards and industry standards must be adhered to. A steady and longterm improvement of the environmental impacts by appropriate technologies and production processes, which allow efficient use of natural resources and energy as well as minimization of emissions, must be promoted. The chemicals used must be selected by taking into account environmental, occupational health and safety aspects. In doing so, efforts must be made to replace particularly polluting chemicals as far as this is possible. A proper disposal of waste as well as a possible re-use of substances in the context of the cycle management are important, if this is possible due to local conditions.


15. ANIMAL WELFARE

ELTEN business partners do not use leather of exotic animals and no materials derived from species that are endangered or threatened with extinction, as specified on the Red List of the International Union for Conservation of Nature and Natural Resources (IUCN). As sentient beings, all free-living or farmed animals shall be treated and kept according to their species-specific needs.


16. CONSUMER INTERESTS

The needs and interests of consumers are important to us. We will therefore ensure that the products for a specific purpose are safe and secure. All business partners must adhere to the statutory emission standards as well as to further Restricted Substances applicable to the products of ELTEN GmbH.


17. MANAGEMENT PRACTICE

The standards required by this Code of Conduct are binding and contractual part of the cooperation with the ELTEN GmbH. All employees must be informed of the rights and duties this Code of Conduct entails. In the process of integrating the defined standards in the corporate policy, the requirements must be implemented sustainably through systematic management. The tasks must be affiliated to leaders who have the necessary knowledge and authority. Continuous monitoring of the implementation is required. All relevant processes must be adequate, transparent, comprehensible and truthfully documented.