Supplier Code of Conduct
At Turtle Fur, we conduct business at a very high standard around corporate and social responsibility. These standards apply to all employees, as well as all vendors & suppliers, including those for raw materials and purchased finished goods. Along with compliance to all applicable regulations and laws, Turtle Fur strives to sustain its operations by creating a positive impact on the local community and the community at large.
This Supplier Code of Conduct defines standards meant to reinforce our collective role as global citizens. It also identifies labor standards that aim to achieve decent and humane working conditions. This Code’s standards are based on International Labor Organization standards and internationally accepted good labor practices.
Companies working with Turtle Fur are expected to comply with all relevant and applicable laws and regulations of the country in which workers are employed and to implement the Code of Conduct in their applicable facilities. Any agents or sub-contractors working on behalf of Vendor are also expected to adhere to these same standards. When differences or conflicts in standards arise, affiliated companies are expected to apply the highest standard.
Companies working together with Turtle Fur should allow for a transparent supply chain for all aspects of this policy. First, it is important that companies are transparent regarding their suppliers, agents, and sub-contractors. Next, it is important for these tiers of a supply chain to have an open discussion on where there is difficulty in complying to the policies outlined here. It’s through this transparency that all sides can find ways to improve.
Employers shall adopt and adhere to rules and conditions of employment that respect workers and, at a minimum, safeguard their rights under national and international labor and social security laws and regulations.
There shall be no use of forced labor, including prison labor, indentured labor, bonded labor, or other forms of forced labor. There shall be no unreasonable restrictions on workers’ freedom of movement in the facility in addition to unreasonable restrictions on entering or exiting company- provided facilities including, if applicable, workers’ dormitories or living quarters. As part of the hiring process, all workers must be provided with a written employment agreement in their native language that contains a description of terms and conditions of employment.
Foreign migrant workers must receive the employment agreement prior to the worker departing from his or her country of origin and there shall be no substitution or change(s) allowed in the employment agreement upon arrival in the receiving country unless these changes are made to meet local law and provide equal or better terms. All work must be voluntary, and workers shall be free to leave work at any time or terminate their employment without penalty if reasonable notice is given as per worker’s contract. Employers, agents, and sub-agents’ may not hold or otherwise destroy, conceal, or confiscate identity or immigration documents, such as government-issued identification, passports, or work permits. Employers can only hold documentation if such holdings are required by law. In this case, at no time should workers be denied access to their documents.
Workers shall not be required to pay employers’ agents or sub-agents’ recruitment fees or other related fees for their employment. If any such fees are found to have been paid by workers, such fees shall be repaid to the worker.
Freedom of Association and Collective Bargaining
Employers shall recognize and respect the right of employees to freedom of association and collective bargaining. In conformance with local law, suppliers shall respect the right of all workers to form and join trade unions of their own choosing, to bargain collectively, and to engage in peaceful assembly as well as respect the right of workers to refrain from such activities.
Workers and/or their representatives shall be able to openly communicate and share ideas and concerns with management regarding working conditions and management practices without fear of discrimination, reprisal, intimidation, or harassment.
No person shall be employed under the age of 15 or under the age for completion of compulsory education, whichever is higher. Suppliers shall implement an appropriate mechanism to verify the age of workers.
The use of legitimate workplace learning programs, which comply with all laws and regulations, is supported. Workers under the age of 18 (young workers) shall not perform work that is likely to jeopardize their health or safety, including night shifts and overtime. Suppliers shall provide appropriate support and training to all student workers. In the absence of local law, the wage rate for student workers, interns, and apprentices shall be at least the same wage rate as other entry-level workers performing equal or similar tasks.
Nondiscrimination, Harassment and Abuse
No person shall be subject to any discrimination in employment whether direct or indirect, including hiring, daily workplace environment, compensation, advancement, discipline, termination, or retirement, based on gender, race, religion, age, disability, sexual orientation, nationality, political opinion, social group, union membership, marital status, veteran status, or ethnic origin.
Every employee shall be treated with respect and dignity. No employee shall be subject to any physical, sexual, psychological, or verbal harassment or abuse.
Workers shall be provided with reasonable accommodation for religious practices.
In addition, workers or potential workers should not be subjected to medical tests, including pregnancy or virginity tests, or physical exams that could be used in a discriminatory way.
Hours of Work
Employers shall not require workers to work more than the regular and overtime hours allowed by the law of the country where the workers are employed. The regular work week shall not exceed 48 hours. Employers shall allow workers at least 24 consecutive hours of rest in every seven-day period.
All overtime work shall be consensual. Employers shall not request overtime on a regular basis and shall compensate all overtime work at a premium rate. Other than in exceptional circumstances, the sum of regular and overtime hours in a week shall not exceed 60 hours.
Every worker has a right to compensation for a regular work week that is sufficient to meet the worker’s basic needs and provide some discretionary income. Employers shall pay at least the minimum wage or the appropriate prevailing wage, whichever is higher, comply with all legal requirements on wages, and provide any fringe benefits required by law or contract.
Deductions from wages as a disciplinary measure shall not be permitted. For each pay period, workers shall be provided with a timely and understandable wage statement that includes sufficient information to verify accurate compensation for work performed.
All use of temporary, dispatch and outsourced labor will be within the limits of the local law.
Health & Safety
Employers shall provide a safe and healthy workplace setting to prevent accidents and inju ry to health arising out of, linked with, or occurring in the course of work or because of the operation of employers’ facilities.
Worker exposure to the hazards of physically demanding tasks, including manual material handling and heavy or repetitive lifting, prolonged standing, and highly repetitive or forceful assembly tasks is to be identified, evaluated, and controlled. Production and other machinery shall be evaluated for safety hazards. Physical guards, interlocks, and barriers are to be provided and properly maintained where machinery presents an injury hazard to workers.
Procedures and systems are to be in place to prevent, manage, track, and report occupational injury and illness, including provisions to encourage worker reporting, classify and record injury and illness cases, provide necessary medical treatment, investigate cases, and implement corrective actions to eliminate their causes, and facilitate the return of workers to work.
Worker exposure to chemical, biological, and physical agents is to be identified, evaluated, and controlled. Products, as well as any other shipping materials, must not include any chemicals or materials from common Restricted Substance Lists (RSL). Turtle Fur follows the AAFA RSL List most directly. The list can be found here…https://www.aafaglobal.org/AAFA/Solutions_Pages/Restricted_Substance_List.aspx
Emergency plans should be prepared that include appropriate fire detection and suppression equipment, clear and unobstructed egress, adequate exit facilities, contact information for emergency responders, and recovery plans. Such plans and procedures shall focus on minimizing harm to life, the environment, and property.
Reasonable steps must also be taken to remove pregnant women and nursing mothers from working conditions with high hazards, remove or reduce any workplace health and safety risks to pregnant women and nursing mothers, including those associated with their work assignments, and provide reasonable accommodations for nursing mothers.
Vendors shall adopt responsible measures to mitigate negative environmental impacts that the workplace has on both its community and its employees.
The generation of waste is to be minimized or eliminated at the source or by practices such as adding pollution control equipment; modifying production, maintenance, and facility processes; or by other means. The use of natural resources is to be conserved by practices such as modifying production, maintenance and facility processes, re-use, conservation, recycling, or other means.
All required environmental permits (e.g., discharge monitoring), approvals, and registrations are to be obtained and maintained.
Suppliers are encouraged to establish a company-wide greenhouse gas reduction goal and the tools to track this for goods produced for Turtle Fur ~ this will become a requirement in 2023. Energy consumption and all relevant Scopes 1 & 2 greenhouse gas emissions are to be tracked and documented against the greenhouse gas reduction goal. Suppliers are to look for methods to improve energy efficiency and to minimize their energy consumption and greenhouse gas emissions. Follow the link here to learn more about Scope 1 & 2.
Vendors should be taking the reasonable steps to move towards a closed loop supply chain; this may include, but is not limited to:
- Manufacturing to high quality standards which deliver a long-lasting durable product.
- Reducing waste in the production of products
- Environmentally conscious dying and washing of yarns & textiles
- Using Turtle Fur approved recycled or sustainable materials in the composition of products.
- Minimizing packing materials of finished product.
- Using packing materials first of recycled materials, and, if not, those that can be recycled or composted. The packaging needs to be labeled accordingly to facilitate recycling or composting.
- Make transportation decisions considering environmental impact, cost & meeting timelines.
If selecting a polybag that is recyclable, Turtle Fur’s minimum acceptable standard is for one made of low-density polyethylene and marked with a #4 per the image on the right.
If planning on utilizing a bag that is not LDPE #4, please advise Turtle Fur what you have found that is a better option in terms of sustainability.
The highest standards of integrity are to be upheld in all business interactions. Suppliers must have a zero-tolerance policy prohibiting all forms of bribery, corruption, extortion, and embezzlement.
Intellectual property rights are to be respected. Transfer of technology and know-how is to be done in a manner that protects intellectual property rights, and customer and supplier information is to be safeguarded. Suppliers are to commit to protecting the reasonable privacy expectations of personal information for everyone they do business with, including suppliers, customers, consumers, and employees.
Suppliers shall adopt or establish management policies with a scope that is related to the content of this Code of Conduct.
The management system shall be designed to ensure:
- Compliance with applicable laws, regulations and customer requirements related to the participant’s operations and products
- Conformance with this code
- Identification and mitigation of operational risks related to this code.
- It should also facilitate continual improvement.
If you have questions, please contact email@example.com