ETHICAL SOURCING
& ENVIRONMENTAL
POLICY

1 Ethical Sourcing & Environmental Policy

Impact Promotional Products (Impact) is committed to integrating ethical and socially responsible business practices into all aspects of operations, and in doing so meeting the expectations of its valued stakeholders.
This Ethical Sourcing & Environmental Policy (Policy) embodies Impact’s commitment to both the ethical manufacture and supply of merchandise, working with suppliers to improve their social and environmental practices and reducing Impact’s environmental effect. The Policy is based on internationally accepted ethical sourcing and labour standards and environmental legislative and regulatory requirements. Impact has the expectation that its suppliers will also share and demonstrate the same commitment.

2 Our Expectations

This Policy outlines the minimum ethical standards that all suppliers, including sub-contractors engaged by suppliers, must comply with when producing and supplying merchandise for Impact. Impact expects its suppliers to:
Commit to complying with the minimum ethical standards outlined in the Policy, with regard to employment practices, safety and environmental compliance.
Demonstrate commitment to the Policy through implementing monitoring systems to assess ethical sourcing compliance, with a focus on continual improvement;
Fully co-operate with any external audit process conducted by or on behalf of Impact; and Ensure that corrective action is taken as a priority to rectify any breach of this Policy.
Impact recognises that some suppliers may not be fully compliant with the ethical standards, and is committed to working with suppliers to develop and implement continual improvement plans
and achieve compliance over time.
Impact reserves the right to cease business with suppliers that do not meet these minimum ethical standards. In particular, Impact regards the exploitation of children as unacceptable, and has a zero tolerance policy with regard to the use of child labour.

3 Ethical Standards

Impact expects its suppliers to comply with the following ethical standards, and any associated laws and regulations in the supplier’s country of operation and manufacture. Where there is a conflict between the ethical standard and local laws, whichever affords greater protection applies.

3.1 Freely Chosen Employment

Suppliers shall not use forced, bonded (or debt) or involuntary labour. Workers will not be required to lodge ‘deposits’ or their identity papers with the supplier, and must be free to leave once their shift ends, or to cease their employment after giving their employer reasonable notice.

3.2 Freedom of Association

Suppliers shall respect that workers have the right to join a union or a worker’s organisation of their own choosing and to bargain collectively. Suppliers are required to recognise the rights of trade unions and their organisational activities, including as provided for by relevant legislation.
Where the right to freedom of association and collective bargaining is restricted under the local laws, suppliers will facilitate and not hinder the development of alternative means of independent and free association and bargaining.

3.3 Working Conditions

Suppliers will provide workers with a safe and clean working environment, taking into account the prevailing knowledge of the industry, any specific hazards and any applicable laws and standards. Adequate steps shall be taken to prevent accidents and injury to health occurring during the course of work, by actively minimising the causes of hazards in the work environment.
Suppliers will also provide plant and systems of work that are safe and without risks to health. This will include (but is not limited to) an adequate number of unlocked, freely accessible and clearly marked exits for emergency evacuations, and properly maintained fire fighting equipment.
Workers must be appropriately supervised and trained to perform their jobs safely, and such training shall be repeated for new or reassigned workers, with records of training maintained by the supplier. Suppliers will also ensure that personal protective safety equipment is available, and workers are trained in its use. Safeguards on machinery must meet or exceed local laws.
Suppliers will provide workers with access to clean toilet facilities, clean and drinkable water and, if appropriate, sanitary facilities for food storage and preparation. Where suppliers provide worker accommodation, it shall be clean, safe and meet the basic needs of the workers.

3.4 Child Labour

Suppliers shall not use child labour, and must only employ workers who meet the local minimum age requirement. Suppliers must verify the age of their workers and maintain evidence of workers’ proof of age.

3.5 Wages and Benefits

Wages and benefits paid for a standard working week must meet, as a minimum, any applicable local laws or benchmark industry standards, whichever is the higher. In any event wages should always be enough to meet basic needs and provide some discretionary income.
All workers must be provided with written and understandable information about their employment conditions with respect to wages before they enter employment, and about the particulars of their wages for each pay period. Deductions from wages as a disciplinary measure shall not be permitted, nor shall any deductions from wages not provided for by local laws without the express permission of workers.

3.6 Working Hours

Working hours shall comply with local laws and benchmark industry standards, whichever affords greater protection. In any event, workers shall not on a regular basis be required to work in excess of 48 hours per week and shall be provided with at least one day off for every 7-day period on average.
Overtime shall be voluntary, shall not be excessive, shall not be demanded on a regular basis and shall always be compensated at a premium rate.

3.7 Discrimination

Suppliers shall not discriminate in hiring, promotion, compensation, access to training,termination or retirement, based on personal characteristics, such as race, caste, national origin, religion, age, disability, gender, 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 discrimination, harassment, or any other inappropriate workplace behavior.

3.8 Regular Employment

To every extent possible work performed must be on the basis of a recognised employment relationship established through national law and practice. Obligations to employees under local laws and regulations arising from the regular employment relationship shall not be avoided through the use of labor-only contracting, subcontracting, 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 use of fixed-term contracts of employment.

3.9 Discipline

Workers shall be treated with dignity and respect. Suppliers will not use (either directly or indirectly) any physical abuse or discipline, the threat of physical abuse, sexual or other harassment, verbal abuse or other forms of intimidation. All employee performance management measures should be recorded.

3.10 Illegal Labour

Suppliers shall not use illegal labour, and must be able to verify the right of their workers’ (including sub-contractors’) legal eligibility and entitlement to work in the country of employment by reviewing original documentation.

3.11 Bribery and Corruption

Suppliers shall not engage in acts of bribery or corruption and shall not falsify documents or records, during, or as a part of, the audit process.

4 Environment

Suppliers shall comply with local environmental protection laws and regulations, and ensure that key environment impacts of facilities are identified, and controls implemented to minimise the impact of the suppliers operations on the environment.
The supplier shall dispose of its production waste in accordance with local environmental laws and regulations.
Must have identified and documented its key environmental impacts and implemented controls to minimise its impact on the environment with respect to solid waste disposal, hazardous chemicals storage and management, air and water emissions.
Seek and use emerging best management practices and technological advances in improved environmental performance and pollution prevention.
Operate a purchasing policy by selecting wherever practical, materials and services which are less damaging to the environment and continue to promote an open dialogue with Impact to promote the use of recycled materials and sustainable practices.

5 Compliance With This Policy

Impact expects its suppliers to comply with all aspects of this Policy, and will be extending its
coverage of audited facilities and compliance monitoring processes to include these standards.
Impact is committed to working in partnership with its suppliers to help achieve compliance with this Policy. In the event where any supplier is unwilling or unable to demonstrate continuous improvement towards full compliance with our standards, the trading agreement between Impact and the supplier will be terminated.