KACS Responsible Sourcing Policy

Business is conducted lawfully and with Integrity

Compliance with Laws – All laws and regulations are complied with by the Suppliers.

Bribery – There is a prohibition on any and all forms of bribery, corruption, extortion or embezzlement and there are adequate procedures in place to prevent bribery in all commercial dealings undertaken by the supplier.

Conflicts of Interest – All and any conflict of interest in any business dealings with KACS, of which the supplier is aware, will be declared to KACS to allow KACS the opportunity to take appropriate action. Any ownership or beneficial interest in a supplier’s business by a government official, representative of a political party or a KACS worker are declared to KACS prior to any business relationship with KACS being entered into.

Gifts and Hospitality – Any business entertaining or hospitality with KACS is kept reasonable in nature, entirely for the purpose of maintaining good business relations and not intended to influence in any way KACS’s decisions about how KACS awards future business. Gift giving should occur sparingly and always be legitimate and aligned with company policies.

Confidential and Competitor Information – All competitor information is obtained and used legitimately and in compliance with all applicable laws and regulations. No attempt is made to divulge to KACS any information about its competitors. Likewise, KACS’s confidential information must not be shared with any third party unless expressly permitted by KACS.

Financial Records, Money Laundering and Insider Trading – All business and commercial dealings are transparently performed and accurately recorded in the supplier’s books and records. There is no actual or attempted participation in money laundering. No confidential information in the supplier’s possession regarding Unilever is used to either engage in or support insider trading.

Safeguarding Information and Property – KACS’s confidential information, know-how and intellectual property is respected and safeguarded. All information provided by Unilever that is not in the public domain is deemed confidential and it is only used for its intended and designated purpose. All and any personal information about individuals, such as KACS’s consumers or employees, is handled with full respect for the protection of their privacy and for all relevant privacy laws and regulations.

Product Quality and Responsible Innovation – Products and services are delivered to meet the specifications and quality and safety criteria specified in the relevant contract documents and are safe for their intended use.

Reporting Concerns and Non-retaliation – All workers (whether directly employed or not) are provided with means by which to raise their concerns about any of these requirements and processes are in place to ensure that workers who raise concerns and speak up in good faith are protected from retaliation.

Work is conducted on the basis of freely agreed and documented terms of employment.

All workers, both permanent and casual, are provided with employment documents that are freely agreed and which respect their legal and contractual rights.

All workers are treated equally and with respect and dignity

All workers are treated with respect and dignity. No worker is subject to any physical, sexual, psychological or verbal harassment, abuse or other form of intimidation. There is no discrimination in employment, including hiring, compensation, advancement, discipline, termination or retirement. Discrimination based on race, ethnicity, age, role, gender, gender identity, colour, religion, country of origin, sexual orientation, marital status, pregnancy, dependants, disability, social class, union membership or political views is prevented. In particular, attention is paid to the rights of workers most vulnerable to discrimination.

Work is conducted on a voluntary basis

Under no circumstances will a supplier use forced labour, whether in the form of compulsory or trafficked labour, indentured labour, bonded labour or other forms. Mental and physical coercion, slavery and human trafficking are prohibited.

All workers are of an appropriate age

Under no circumstances will a supplier employ individuals under the age of 18 for work or mandatory schooling, whichever is higher.

All workers are paid fair wages

All workers are provided with a total compensation package that includes wages, overtime pay, benefits and paid leave which meets or exceeds the legal minimum standards or appropriate prevailing industry standards, whichever is higher, and compensation terms established by legally binding collective bargaining agreements are implemented and adhered to.

Working hours for all workers are reasonable

Workers are not required to work more than the regular and overtime hours allowed by the law of the land where the workers are employed. All overtime work by workers is on a voluntary basis.

All workers are free to exercise their right to form and/or join trade unions or to refrain from doing so and to bargain collectively

The rights of workers to freedom of association and collective bargaining are recognized and respected. Workers are not intimidated or harassed in the exercise of their right to join or refrain from joining any organisation.

All workers’ health and safety are protected at work

A healthy and safe workplace is provided to prevent accidents and injury arising out of, linked with, or occurring in the course of work or as a result of the employer’s operations.

All workers have access to fair procedures and remedies

All workers are provided with transparent, fair and confidential procedures that result in swift, unbiased and fair resolution of difficulties which may arise as part of their working relationship

Land rights of communities, including indigenous peoples, will be protected and promoted

The rights and title to property and land of the individual, indigenous people and local communities are respected. All negotiations with regard to their property or land, including the use of and transfers of it, adhere to the principles of free, prior and informed consent, contract transparency and disclosure.

Business is conducted in a manner which embraces sustainability and reduces environmental impact

Operations, sourcing, manufacture, distribution of products and the supply of services are conducted with the aim of protecting and preserving the environment.

Reporting on Breaches

1. Any failure to comply with this Policy (including any failure by a worker of KACS or anyone acting on behalf of KACS) of which the supplier is aware should be reported to KACS as soon as possible. Failure to do so will be a breach of this RSP.

2. We strongly support a culture of speaking up for both suppliers and their workers without fear of retaliation against those who report actual or suspected breaches.

3. Suppliers, their employees, workers or contractors may report actual or suspected breaches of this RSP to KACS by phone or online. Reports can be submitted confidentially and anonymously (where permitted by law).

4. KACS will investigate any concern raised and discuss findings with the supplier. The supplier shall assist with any such investigation and provide access to any information reasonably requested.

5. If remediation is required, the supplier will devise and inform KACS of their corrective action and implementation plans and timeline to effectively and promptly resolve the breach.

Continuous Improvement Guidelines and Tips

This section contains guidelines and tips relating to all the Fundamental Principles encompassed in the RSP for Mandatory, Good and Best Practice to assist suppliers as their organisations move up the continuous improvement ladder.

• Guidelines are our recommendations for the implementation of a comprehensive and robust process to help meet our Mandatory Requirements for compliance.

• These Guidelines can also help suppliers achieve Good and Best Practice within a reasonable timeframe. We will continue to share best practices and updated guidance with our suppliers to help them reach this level. Likewise, we always value receiving suppliers’ collaborative input.

• These Guidelines are comprehensive but not exhaustive. They comprise the critical elements of what is generally advisable to reach Mandatory Requirements and to progress toward Good and Best Practice.

Throughout this section, the implementation tips are provided as additional information and recommendations to help KACS’s suppliers comply with the RSP. Independent input from suitable professionals should be obtained where assistance is required. In particular, the tips do not constitute legal advice and do not relieve suppliers of their obligations to consult legal professionals, as appropriate, on contractual terms and obligations, and on how to comply with all laws and regulations relevant to them in the countries where they operate. In addition, the tips do not preclude the supplier from going beyond what is suggested.

BUSINESS IS CONDUCTED LAWFULLY AND WITH INTEGRITY

Guidelines towards implementation of mandatory requirements

  • Procedures to ensure that all applicable laws and regulations are complied with by the supplier and its workers are tailored to the size and risk profile of the business.
  • Senior management are engaged and have oversight of the content and implementation of their compliance framework.
  • There is a clear commitment to zero tolerance of bribery or corruption in all forms.
  • A regular risk assessment is undertaken to identify key compliance risks.
  • Clear and effective internal training and/or guidelines are in place to embed a culture of integrity and mitigate key risks, for example; on gifts and hospitality, conflicts of interest, handling competitor information and anti-competitive behaviour. Such guidelines are readily available to the supplier’s workers.
  • Appropriate due diligence checks are conducted in respect of third party relationships, whether new or ongoing, to ensure they meet equivalent standards.
  • Non-compliance by the supplier’s workers with any applicable law, regulation or policy is subject to appropriate sanctioning and remedial procedures.
  • Financial procedures ensure the proper recording of all financial transactions, and facilitate the identification of any suspected money laundering activities. They ensure that no undisclosed or unrecorded account, fund or asset is established or maintained.
  • Procedures and mechanisms are in place to ensure that all confidential information, whether business or product related, is safely stored with limited access rights on a need-to-know basis only.
  • Procedures are in place to ensure that any product quality or safety concerns originating from the supplier or its supply chain are notified to KACS without delay.
  • As part of a culture of promoting speaking up, there is zero tolerance for retaliation and the anonymity of persons wishing to raise concerns is protected to the extent permitted by law.

Advancing to good practice

  • A Code of Conduct, guidelines, policies and/or training covering each of the elements of this RSP are in place and readily available to workers.
  • There are procedures to communicate, monitor and measure the effectiveness of the Code of Conduct, guidelines, policies and/or training.
  • Preventive and remedial measures are taken to address adverse impacts that are directly linked to the supplier’s operations, products or through business relationships.
  • The supplier has in place a code of conduct or responsible sourcing policy for its direct suppliers, consistent with the requirements of this RSP. In addition, there is a process to communicate this to all of its direct suppliers and to monitor compliance by these direct suppliers.
  • Suppliers’ executive management and leaders are held accountable for compliance and conducting business with integrity, with individual sanctions applied as appropriate to a fair and consistent standard.
  • Workers have multiple grievance channels available to them.
  • Procedures have been developed to investigate grievances.

Achieving and maintaining best practice

  • Additional steps are taken to continuously improve the effectiveness of relevant policies and processes, in consultation with key stakeholders, and thereby: i. ensure all relevant risks of non-compliance with laws are addressed; ii. affirm the responsibility for the implementation of such policies by the board of directors or equivalent body; iii. extend training to contractors and suppliers as appropriate; and iv. enable independent assurance.
  • Suppliers’ third party business partners are able to raise concerns anonymously.
  • The supplier is prepared to take a public position on ethical issues and engage in collective action where appropriate.

WORK IS CONDUCTED ON THE BASIS OF FREELY AGREED AND DOCUMENTED TERMS OF EMPLOYMENT

Guidelines towards implementation of mandatory requirements

  • The key components of the employer/worker relationship such as hours, overtime, pay, benefits, leave, disciplinary and grievance systems are: (i) freely agreed by both parties; (ii) documented in writing; and (iii) signed by the employer and worker.
  • Suppliers shall ensure that the terms and conditions of employment contracts are in a language understood by the worker and are explained verbally if required.
  • Changes are agreed in writing by both employer and worker.

Advancing to good practice

  • Key management functions such as hiring, grievances, discipline, promotion and termination have clear policy frameworks, procedures for implementation and trained staff responsible for implementing them. Appropriate documentation is kept.
  • These policies and procedures are explained to workers upon hiring and contained in a workers’ manual, and workers are trained to understand and use them.
  • Ongoing training practices are provided for all categories of workers to raise and broaden their skills to enable them to advance in their employment.

Achieving and maintaining best practice

  • There is a clear and transparent system of worker and management communication that enables workers to consult and have an effective dialogue with management.
  • Short-term, casual or agency workers are regularized where the work involved is clearly of a regular nature and is required all year round.
  • These employment relation policies and procedures are reviewed periodically and any necessary improvements are made to ensure that all categories of workers, regardless of contract status, have the same rights and entitlements at work. Special attention is paid to short-term, casual and agency workers and to vulnerable groups such as women, migrants, the disabled, legal young workers and interns/trainees to ensure such workers have exactly the same entitlements as full-time local workers.
  • The Human Resources function ensures legal compliance throughout the employment relationship and develops, motivates, recognizes and rewards workers and engages in social dialogue.

ALL WORKERS ARE TREATED EQUALLY AND WITH RESPECT AND DIGNITY

Guidelines towards implementation of mandatory requirements

  • Policies that prohibit discrimination of any form on the basis of race, ethnicity, age, role, gender, gender identity, colour, religion, country of origin, sexual orientation, marital status, pregnancy, dependants, disability, social class, union membership or political views are in place, and there are procedures to implement them.
  • These policies highlight actions to protect the rights of any worker considered vulnerable to discrimination.
  • Pregnancy testing or other forms of health screening that might result in discrimination are not tolerated (except when such health tests are mandated under local laws).

Advancing to good practice

  • Selection criteria for all human resource decisions are objective and transparent and controls are in place to prevent arbitrary decisions.
  • Staff members responsible for hiring, paying, training, promoting, disciplining and terminating workers are trained to avoid discrimination in the exercise of their duties.
  • All workers and their managers are trained to recognise and prevent harassment, abuse and other forms of intimidation.
  • Managers, frontline supervisors, production staff, quality controllers and guards are trained to avoid discrimination.

Achieving and maintaining best practice

  • Human Resources records are kept and data analysed to ensure that equality is achieved in practice.
  • Regular assessments are conducted and any gaps or shortcomings identified are addressed through an action plan with measurable outcomes.
  • Specific and measurable targets for achieving equality between women and men are set and affirmative action is taken to attain them.
  • Programmes addressing the needs of the most vulnerable workers, such as flexible time options, child and dependant care, and mentoring programmes are in place.

WORK IS CONDUCTED ON A VOLUNTARY BASIS

GUIDELINES TOWARDS IMPLEMENTATION OF MANDATORY REQUIREMENTS

  • There are hiring policies, procedures and trained staff to ensure that workers are entering into employment freely and equally and that they are never prevented from leaving if they so wish.
  • Workers have freedom of movement and are not confined to the supplier’s premises, including dormitories or provided housing.
  • Workers are not required to surrender their identification papers. Where the retention of identification papers is legally required, arrangements are made to ensure that workers can access their identification papers, are not prevented from leaving the workplace and that their papers are returned immediately upon cessation of employment.
  • Workers should not be required to pay a fee in connection with obtaining employment (including migrant workers or recruited workers supplied through an agency). Suppliers should be responsible for payment of all fees and expenses. Workers are not required to pay deposits in relation to their employment.

Advancing to good practice

  • To the extent possible, workers are hired directly and transparently, or only through recruitment agencies that have developed policies and strategies to combat trafficking and forced labour.
  • Voluntary prison labour may be used when prisoners are being rehabilitated or trained in preparation for release and where their terms and conditions of employment are similar to those in the open labour market.

Achieving and maintaining best practice

  • Recruitment of migrants includes full transparency about terms, conditions and any employment costs, and the migrants are informed about the labour laws applicable in the place of work prior to granting their written consent.
  • Policies, procedures and training are regularly reviewed to ensure that they are effective in preventing forced labour.

ALL WORKERS ARE OF AN APPROPRIATE AGE

Guidelines towards implementation of mandatory requirements

  • An employment policy is in place specifying the minimum age for employment, together with effective procedures and means of age verification to implement this policy.
  • Responsible remedial measures are immediately implemented whenever any breach of that policy is identified.
  • In all circumstances the health and safety of young workers are considered and protected. This protection should preclude them from certain types of work such as hazardous or night work and requires extra care and commitment.
  • The goals and requirements set out in the International Labour Organization Worst Forms of Child Labour Convention are met.
  • The goals and requirements set out in the International Labour Organization Minimum Age Convention are met, including those regarding minimum age, appropriate types of work for young workers, hours of work, health and education concerns.
  • Policies clearly state that individuals under the age of 15 are not allowed on work premises where hazards may exist.

Advancing to good practice

  • All relevant supervisors are trained to respect the provisions for young workers, apprentices and interns, especially with respect to hours of work, night shifts, weekend work and heavy or dangerous work.
  • Periodic health screening of juvenile workers, apprentices and interns is provided.

Achieving and maintaining best practice

  • For any adverse impact on children’s rights beyond those stipulated by law (such as but not limited to children’s rights to care, protection, education and development) which are caused or contributed to by the supplier directly or indirectly through labour agencies, remedial action shall be provided by the supplier, through legitimate processes, or the supplier shall co-operate with such action.
  • The effectiveness of the supplier’s system is regularly monitored to prevent the hiring of minors and to check the adequacy of efforts to protect children’s rights.

ALL WORKERS ARE PAID FAIR WAGES

Guidelines towards implementation of mandatory requirements

  • Workers receive a payslip for each pay period, clearly indicating the components of the compensation, including exact amounts for wages, benefits, incentives/bonuses and any deductions.
  • Wages are paid on time and in full.
  • All work is compensated according to at least the legal minimum standards or the appropriate prevailing industry standards, whichever is the higher, including that of interns/students receiving academic credit for their work.
  • All legally mandated deductions, such as taxes or social insurance, are deposited each pay period to the legally stipulated accounts or agencies and as required by law.
  • Other than legally mandated deductions, all other deductions from wages are made only with the express and written consent of the workers.
  • Migrant workers’ remittances are authorized in writing.

Advancing to good practice

  • There is a system of periodic assessment in place to ensure equal pay for equal work.
  • There is a living wage approach to fair compensation which encompasses a system to periodically assess that wages are sufficient to meet the basic needs of the worker and to provide some discretionary income.

Achieving and maintaining best practice

  • A best practice fair compensation system is in place for all workers. This system categorises workers according to qualifications, skill and experience; recognises and rewards them for performance through wage and non-wage benefits/incentives; regularly assesses and adjusts their pay according to the cost of living, basic needs, discretionary income, relevant market benchmarks and enterprise performance; and engages in regular social dialogue on compensation questions.

WORKING HOURS FOR ALL WORKERS ARE REASONABLE

Guidelines towards implementation of mandatory requirements

  • Clear policies are implemented regarding regular and overtime hours of work, with defined procedures for deciding on overtime and securing worker consent.
  • In the absence of law, the supplier will over time implement steps to meet the goals and requirements set out in the International Labour Organization Convention on hours of work and overtime so that the regular working week does not exceed 48 hours and other than in exceptional circumstances, the sum of regular and overtime hours in a week does not exceed 60 hours. Where the sum of regular and overtime hours in a week exceeds 60 hours under normal conditions, a plan to implement a step-wise and sustainable reduction toward this goal must be in place.
  • Workers are entitled to at least 24 consecutive hours of rest in every seven day period. If workers are required to work on a rest day due to a genuine need for continuity of production or service, workers must receive an equivalent period of compensatory rest immediately following.
  • If the employment contract allows for contractual overtime, workers expressly agree to it. All overtime work by workers is on a voluntary basis.
  • All overtime work is paid at least to the rate defined by law.

Advancing to good practice

  • The goals and requirements set out in the International Labour Organization Convention on hours of work and overtime are met so that the regular working week does not exceed 48 hours, and overtime does not exceed 12 hours. Other than in exceptional circumstances, the sum of regular and overtime hours in a week does not exceed 60 hours.
  • All overtime work is paid at the appropriate premium rate according to law or to prevailing industry standards, whichever is the higher, and there is an effective mechanism to monitor hours of work.
  • Peak periods are planned in such a way as to avoid excessive overtime. Overtime is not used for extended periods as a means of making up for labour shortages or increased order volumes.
  • If sufficient workers cannot be hired, new working time arrangements are explored to ensure that overtime is the exception rather than the rule.

Achieving and maintaining best practice

  • Work-study, costing and scheduling systems are in place that plan production in such a way as to avoid overtime, except in exceptional circumstances.
  • Working time arrangements allow for a work–life balance.

ALL WORKERS ARE FREE TO EXERCISE THEIR RIGHT TO FORM AND/OR JOIN TRADE UNIONS OR TO REFRAIN FROM DOING SO AND TO BARGAIN COLLECTIVELY

Guidelines towards implementation of mandatory requirements

  • Clear policies, procedures and training of workers and managers to ensure freedom of association in day-to-day operations are in place.
  • Managers, supervisors and guards are trained to respect each worker’s right to associate freely.
  • Collective bargaining negotiations are entered into when requested by legally recognized representative agents and collective agreements concluded.
  • Workers know and understand their rights and feel confident to exercise them, and that no other worker or manager will impede them in the enjoyment of that right.

Advancing to good practice

  • Policies covering hiring, discipline, promotion, wages, hours, grievances and termination all clarify that a worker’s choice to form or join a trade union will not compromise their equal treatment at work.
  • Clear rules governing the activities of recognized trade unions in the workplace are in place.

Achieving and maintaining best practice

  • The goals and requirements set out in the International Labour Organization Convention on freedom of association and collective bargaining are met.
  • Social dialogue on all aspects of work is established with workers.

ALL WORKERS’ HEALTH AND SAFETY ARE PROTECTED AT WORK

Guidelines towards implementation of mandatory requirements

  • Clear and effective policies and procedures are in place for occupational health and safety and are updated periodically.
  • Occupational health and safety policies and procedures are widely communicated.
  • Ongoing safety training is provided to all personnel, including managers, supervisors, workers and security guards.
  • All workers and other people who enter business premises are properly informed about the inherent dangers of the workplace and are provided with adequate knowledge and personal protective equipment to avoid such dangers.
  • All personnel who enter the premises or deal with products are properly informed about the appropriate actions to take should a health and safety incident occur.

Advancing to good practice

  • Occupational health and safety policies and procedures are included in the workers’ manual.
  • The structural integrity and fire safety of worksites are specifically assessed and updated periodically.
  • Occupational health and safety committees are created and their roles are clearly understood by all workers and managers.

Achieving and maintaining best practice

  • Regular assessments are conducted to ensure the meaningful operation of the health and safety committees.
  • Risk assessments are conducted regularly and systems updated to reflect the changing risk profile of the workplace.
  • Regular assessments are conducted of the risk to the surrounding ecosystem of exposure to hazardous substances and steps are taken to manage any risks identified.

ALL WORKERS HAVE ACCESS TO FAIR PROCEDURES AND REMEDIES

Guidelines towards implementation of mandatory requirements

  • Procedures (i) provide effective, accessible channels for workers to complain, make suggestions and lodge grievances; and (ii) require the matter to be fully investigated and result in swift, unbiased and fair resolution.
  • Grievance mechanisms channels are widely communicated and guarantee the confidentiality of any complainant (if so desired) and prohibit retaliation.

Advancing to good practice

  • Grievance mechanisms are included in the workers’ manual.
  • All workers and managers are trained on the policy and procedures for the handling of complaints and grievances. Workers are confident that any complaint is handled objectively and fairly.
  • Specific measures exist to protect complainants against victimization. All managers are trained to avoid recriminations.
  • Remedies are timely and open to appeal.

Achieving and maintaining best practice

  • Data on the receipt and handling of grievances is maintained and analysed to ensure the efficacy of the grievance mechanisms.
  • Where there are recognized trade unions, the role of shop stewards and union officials in handling the grievances of their members is clearly specified.
  • Distinct procedures managed by trained personnel are available for cases involving sexual harassment or assault. Those procedures take account of the potential trauma and risks involved and make provision for counselling and other support to victims, as needed.

LAND RIGHTS OF COMMUNITIES, INCLUDING INDIGENOUS PEOPLES, WILL BE PROTECTED AND PROMOTED

Guidelines towards implementation of mandatory requirements

  • A zero land grabbing policy is implemented.
  • Where applicable, due diligence is undertaken to uphold individual or indigenous peoples’ established rights to property and land.
  • Where applicable, periodic training on Free, Prior and Informed Consent (FPIC) is provided to all relevant staff members.
  • There is zero tolerance of land grabbing within the supply chain and this is stated in the suppliers’ code of conduct (or equivalent).

Advancing to good practice

  • A system for due diligence is in place to uncover and disclose risks and impacts to communities related to land issues.
  • The right of women to land ownership and access to land is recognized.

Achieving and maintaining best practice

  • Impact assessments are conducted with full participation of affected communities and published in a format and language accessible to those affected communities. The assessment data is disaggregated by gender, national origin, tribe or caste.
  • A public commitment is made to actively support responsible agricultural investments, the UN Voluntary Guidelines on the Responsible Governance of Tenure and full traceability.

BUSINESS IS CONDUCTED IN A MANNER WHICH EMBRACES SUSTAINABILITY AND REDUCES ENVIRONMENTAL IMPACT

Guidelines towards implementation of mandatory requirements

  • All necessary current and valid legal permits are held for its operations.
  • Training is provided to all relevant personnel to ensure knowledge of and compliance with all necessary legal permits.
  • Environmental management policies and procedures are in place regarding water, energy, hazardous materials, air quality and emissions, deforestation, waste and other significant risks.

Advancing to good practice

  • Training is provided to all personnel on environmental policies and procedures to ensure effective implementation and compliance.
  • Transparency is ensured on environmental performance.

Achieving and maintaining best practice

  • Sustainability practices are embedded across the supplier’s operations and activities which aim to (i) reduce the generation of waste and achieve zero landfill; (ii) reduce greenhouse gas emissions and achieve carbon neutral solutions; (iii) reduce the consumption of water; (v) protect and enhance nature and biodiversity; and (vi) halt deforestation.
  • A systematic review of the supplier’s sustainability practices and environmental management systems is undertaken regularly with support from experienced conservationists and with the involvement of local communities to determine whether appropriate policies and procedures are in place and are functioning to achieve the aims outlined in this topic.
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