Ethical Policies

Table of Contents

• Anti-Bribery Policy
• Data Protection Policy
• Ethical Sourcing Policy
• Modern Slavery Statement 2017
• Quality Policy Statement

Anti-Bribery Policy

1. Purpose

The purpose of this policy is to establish controls to ensure compliance with all applicable anti-bribery and corruption regulations, and to ensure that the Company’s business is conducted in a socially responsible manner.

2. Policy statement

Bribery is the offering, promising, giving, accepting or soliciting of an advantage as an inducement for action which is illegal or a breach of trust. A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.

It is our policy to conduct all of our business in an honest and ethical manner. We take a zero- tolerance approach to bribery and corruption. We are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery.

We will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate.

However, we remain bound by the laws of the UK, including the Bribery Act 2010, in respect of our conduct both at home and abroad.

Bribery and corruption are punishable for individuals by up to ten years’ imprisonment and a fine. If we are found to have taken part in corruption, we could face an unlimited fine, be excluded from tendering for public contracts and face damage to our reputation. We therefore take our legal responsibilities very seriously.

3. Scope

3.1 Who is covered by the policy?

In this policy, third party means any individual or organization you come into contact with during the course of your work for us, and includes actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisors, representatives and officials, politicians and political parties.

This policy applies to all individuals working at all levels and grades, including senior managers, officers, directors, employees (whether permanent, fixed-term or temporary), consultants, contractors, trainees, seconded staff, homeworkers, casual workers and agency staff, volunteers, interns, agents, sponsors, or any other person associated with us, or any of our subsidiaries or their employees, wherever located (collectively referred to as employees in this policy).

This policy covers:

• Bribes;
• Gifts and hospitality;
• Facilitation payments;
• Political contributions;
• Charitable contributions.

3.2 Bribes

Employees must not engage in any form of bribery, either directly or through any third party (such as an agent or distributor). Specifically, employees must not bribe a foreign public official anywhere in the world.

3.3 Gifts and hospitality

Employees must not offer or give any gift or hospitality:

• which could be regarded as illegal or improper, or which violates the recipient’s policies; or
• to any public employee or government officials or representatives, or politicians or political parties; or
• which exceeds £5,000 in value for each individual gift or £500,000 in value for each hospitality event (not to exceed a total value of £1,000,000 in any financial year), unless approved in writing by the employee’s manager.

Employees may not accept any gift or hospitality from our business partners if:

• it exceeds £10,000 in value for each individual gift or £1,000,000 in value for each hospitality event (not to exceed a total of £5,000,000 in any financial year), unless approved in writing by the employee’s manager; or
• it is in cash; or
• there is any suggestion that a return favor will be expected or implied.

Where a manager’s approval is required above, if the manager is below Director level then approval must be sought from an appropriate Director.

If it is not appropriate to decline the offer of a gift, the gift may be accepted, provided it is then declared to the employee’s manager and donated to charity.

We appreciate that the practice of giving business gifts varies between countries and regions and what may be normal and acceptable in one region may not be in another. The test to be applied is whether in all the circumstances the gift or hospitality is reasonable and justifiable. The intention behind the gift should always be considered.

Within these parameters, local management may define specific guidelines and policies to reflect local professional and industry standards. Where this policy requires written approval to be given, the Operations Director shall put in place a process to maintain a register of all such approvals.

3.4 Facilitation payments and kickbacks

Facilitation payments are a form of bribery made for the purpose of expediting or facilitating the performance of a public official for a routine governmental action, and not to obtain or retain business or any improper business advantage. Facilitation payments tend to be demanded by low level officials to obtain a level of service which one would normally be entitled to.

Our strict policy is that facilitation payments must not be paid. We recognize, however, that our employees may be faced with situations where there is a risk to the personal security of an employee or his/her family and where a facilitation payment is unavoidable, in which case the following steps must be taken:

• Keep any amount to the minimum;
• Create a record concerning the payment; and
• Report it to your line manager.

In order to achieve our aim of not making any facilitation payments, each business of the Company will keep a record of all payments made, which must be reported to the Operations Director, in order to evaluate the business risk and to develop a strategy to minimize such payments in the future.

3.5 Political Contributions

We do not make donations, whether in cash or kind, in support of any political parties or candidates, as this can be perceived as an attempt to gain an improper business advantage.

3.6 Charitable contributions

Charitable support and donations are acceptable (and indeed are encouraged), whether of in- kind services, knowledge, time, or direct financial contributions. However, employees must be careful to ensure that charitable contributions are not used as a scheme to conceal bribery. We only make charitable donations that are legal and ethical under local laws and practices]. No donation must be offered or made without the prior approval of [the compliance manager.

All charitable contributions should be publicly disclosed.

4. Your responsibilities

You must ensure that you read, understand and comply with this policy.

The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for us or under our control. All employees are required to avoid any activity that might lead to, or suggest, a breach of this policy.

You must notify your manager OR the Operations Director or the confidential helpline as soon as possible if you believe or suspect that a conflict with or breach of this policy has occurred, or may occur in the future.

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. We reserve our right to terminate our contractual relationship with other workers if they breach this policy.

5. Record-keeping

We must keep financial records and have appropriate internal controls in place which will evidence the business reason for making payments to third parties.

You must declare and keep a written record of all hospitality or gifts accepted or offered, which will be subject to managerial review.

You must ensure all expenses claims relating to hospitality, gifts or expenses incurred to third parties are submitted in accordance with our expenses policy and specifically record the reason for the expenditure.

All accounts, invoices, memoranda and other documents and records relating to dealings with third parties, such as clients, suppliers and business contacts, should be prepared and maintained with strict accuracy and completeness. No accounts must be kept “off-book” to facilitate or conceal improper payments.

6. How to raise a concern

You are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. If you are unsure whether a particular act constitutes bribery or corruption, or if you have any other queries or concerns, these should be raised with your line manager OR the Operations Director or through the confidential helpline.

7. What to do if you are a victim of bribery or corruption

It is important that you tell the Operations Director or the confidential helpline as soon as possible if you are offered a bribe by a third party, are asked to make one, suspect that this may happen in the future, or believe that you are a victim of another form of unlawful activity.

8. Protection

Employees who refuse to accept or offer a bribe, or those who raise concerns or report another’s wrongdoing, are sometimes worried about possible repercussions. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.

We are committed to ensuring no one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place, or may take place in the future. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavorable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform [the compliance manager] immediately. If the matter is not remedied, and you are an employee, you should raise it formally using the company’s Grievance Procedure.

9. Training and communication

Training on this policy forms part of the induction process for all new employees. All existing employees will receive regular, relevant training on how to implement and adhere to this policy. In addition, all employees will be asked to formally accept conformance to this policy on an annual basis.

Our zero-tolerance approach to bribery and corruption must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and as appropriate thereafter.

10. Who is responsible for the policy?

The board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

Company Director’s have primary and day-to-day responsibility for implementing this policy, and for monitoring its use and effectiveness and dealing with any queries on its interpretation. Management at all levels are responsible for ensuring those reporting to them are made aware of and understand this policy and are given adequate and regular training on it.

11. Monitoring and review

The Operations Director will monitor the effectiveness and review the implementation of this policy, regularly considering its suitability, adequacy and effectiveness. Any improvements identified will be made as soon as possible. Internal control systems and procedures will be subject to regular audits to provide assurance that they are effective in countering bribery and corruption.

All employees are responsible for the success of this policy and should ensure they use it to disclose any suspected danger or wrongdoing.

Employees are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries should be addressed to the Operations Director.

This policy does not form part of any employee’s contract of employment and it may be amended at any time.

Chris Carr
Operations Director
1st January 2017
Chris.Carr@bilko.tv

Data Protection Policy

Introduction

Sometimes Bilko need to gather and use certain information about individuals.

These can include customers, suppliers, business contacts, employees and other people the organization has a relationship with or may need to contact.

This policy describes how this personal data must be collected, handled and stored to meet the company’s data protection standards — and to comply with the law.

Why this policy exists

This data protection policy ensures how the company:

• Complies with data protection law and follow good practice
• Protects the rights of staff, customers and partners
• Is open about how it stores and processes individuals’ data
• Protects itself from the risks of a data breach

Data protection law

The Data Protection Act 1998 describes how organisations must collect, handle and store personal information.

These rules apply regardless of whether data is stored electronically, on paper or on other materials.

To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.

The Data Protection Act is underpinned by eight important principles. These say that personal data must:

1. Be processed fairly and lawfully
2. Be obtained only for specific, lawful purposes
3. Be adequate, relevant and not excessive
4. Be accurate and kept up to date
5. Not be held for any longer than necessary
6. Processed in accordance with the rights of data subjects
7. Be protected in appropriate ways
8. Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection

Why this policy exists

Policy scope

This policy applies to:

• The head office of Bilko
• All offices
• All staff and volunteers of the company
• All contractors, suppliers and other people working on behalf of the company

It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the Data Protection Act 1998. This can include:

• Names of individuals
• Postal addresses
• Email addresses
• Telephone numbers
• …plus any other information relating to individuals

Data protection risks

This policy helps to protect Bilko from some very real data security risks, including:

• Breaches of confidentiality. For instance, information being given out inappropriately.
• Failing to offer choice.For instance, all individuals should be free to choose how the company uses data relating to them.
• Reputational damage.For instance, the company could suffer if hackers successfully gained access to sensitive data.

Responsibilities

Everyone who works for or with us has some responsibility for ensuring data is collected, stored and handled appropriately.

Each team that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles.

However, these people have key areas of responsibility:

• The board of directors is ultimately responsible for ensuring that the company meets its legal obligations.

The data protection officer is responsible for:

• Keeping the board updated about data protection responsibilities, risks and issues.
• Reviewing all data protection procedures and related policies, in line with an agreed schedule.
• Arranging data protection training and advice for the people covered by this policy.
• Handling data protection questions from staff and anyone else covered by this policy.
• Dealing with requests from individuals to see the data that the company holds about them (also called ‘subject access requests’).
• Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.

The IT manager is responsible for:

• Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
• Performing regular checks and scans to ensure security hardware and software is functioning properly.
• Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing services.

The operations director is responsible for:

• Approving any data protection statements attached to communications such as emails and letters.
• Addressing any data protection queries from journalists or media outlets like newspapers.
• Where necessary, working with other staff to ensure marketing initiatives abide by data protection principles.

General staff guidelines

• The only people able to access data covered by this policy should be those who need it for their work.
• Data should not be shared informally. When access to confidential information is required, employees can request it from their line managers.
• The company will provide training to all employees to help them understand their responsibilities when handling data.
• Employees should keep all data secure, by taking sensible precautions and following the guidelines below.
• In particular, strong passwords must be used and they should never be shared.
• Personal data should not be disclosed to unauthorised people, either within the company or externally.
• Data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of.
• Employees should request help from their line manager or the data protection officer if they are unsure about any aspect of data protection.

Data storage

These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the IT manager or data controller.

When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it.

These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:

• When not required, the paper or files should be kept in a locked drawer or filing cabinet.
• Employees should make sure paper and printouts are not left where unauthorised people could see them, like on a printer.
• Data printouts should be shredded and disposed of securely when no longer required.

When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:

• Data should be protected by strong passwords that are changed regularly and never shared between employees.
• If data is stored on removable media (like a CD or DVD), these should be kept locked away securely when not being used.
• Data should only be stored on designated drives and servers, and should only be uploaded to an approved cloud computing services.
• Servers containing personal data should be sited in a secure location, away from general office space.
• Data should be backed up frequently. Those backups should be tested regularly, in line with the company’s standard backup procedures.
• Data should never be saved directly to laptops or other mobile devices like tablets or smart phones.
• All servers and computers containing data should be protected by approved security software and a firewall.

Data use

Personal data is of no value to the company unless the business can make use of it. However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft:

• When working with personal data, employees should ensure the screens of their computers are always locked when left unattended.
• Personal data should not be shared informally. In particular, it should never be sent by email, as this form of communication is not secure.
• Data must be encrypted before being transferred electronically. The IT manager can explain how to send data to authorised external contacts.
• Personal data should never be transferred outside of the European Economic Area.
• Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.

Data accuracy

The law requires us to take reasonable steps to ensure data is kept accurate and up to date.

The more important it is that the personal data is accurate, the greater the effort the company should put into ensuring its accuracy.

It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.

• Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets.
• Staff should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.
• The company will make it easy for data subjects to update the information we hold about them. For instance, via the company website.
• Data should be updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on their stored telephone number, it should be removed from the database.
• It is the marketing manager’s responsibility to ensure marketing databases are checked against industry suppression files every six months.

Subject access requests

All individuals who are the subject of personal data held by the company are entitled to:

• Ask what information the company holds about them and why.
• Ask how to gain access to it.
• Be informed how to keep it up to date.
• Be informed how the company is meeting its data protection obligations.

If an individual contacts the company requesting this information, this is called a subject access request. Subject access requests from individuals should be made by email, addressed to the data controller at Chris.Carr@bilko.tv. The data controller can supply a standard request form, although individuals do not have to use this.

Individuals will be charged £10 per subject access request. The data controller will aim to provide the relevant data within 14 days.

The data controller will always verify the identity of anyone making a subject access request before handing over any information.

Disclosing data for other reasons

In certain circumstances, the Data Protection Act allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.

Under these circumstances, the company will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.

Providing information

The company aims to ensure that individuals are aware that their data is being processed, and that they understand:

• How the data is being used
• How to exercise their rights

To these ends, the company has a privacy statement, setting out how data relating to individuals is used by the company.

Ethical Sourcing Policy

For many years Bilko has worked to ensure that our suppliers’ employees, producing our products, are provided with good working conditions. This drive supports our core brand value of integrity – our customers expect high standards and trust us to work ethically.

In addition, we understand that when people are treated with respect, work in decent conditions and earn fair rates of pay, both they and their companies benefit from increased commitment and productivity. Ultimately, our customers benefit too, from better quality, better value products and peace of mind.

We achieve these objectives by developing agreed standards with our suppliers, supported by regular site visits and a policy of continual improvement. Strict sanctions are applied when standards are not met, or where there is no commitment to improve standards.

Because our suppliers often have their own complex supply chains, it would be impossible for us to monitor or control the working conditions of each individual who contributes to what ultimately becomes a Bilko product. We will not under any circumstances accept production from non-approved factories or goods supplied from sites that differ from our contracts system for each specific contract. However, we are determined to do everything we can to bring fair sourcing principles to all stages of our supply chain. We have therefore published our Ethical Sourcing Policy to set out our beliefs and standards and guide our suppliers.

The policy sets out what is required and expected from our suppliers – i.e. those with whom we have a direct contract for goods or services – to ensure their facilities meet acceptable standards, and are continually improving.

At Bilko, we take great care selecting the companies who supply us directly with products and services. Our Ethical Sourcing Policy establishes the standards for suppliers working with us.

As our business relationship develops, we expect suppliers to raise their standards and improve working conditions, taking account of internationally recognised codes of practice. We have adopted several elements of international codes as well as the Ethical Trading Initiative (ETI) Base Code into the Principles.

Providing information

We have a clear set of standards appropriate to the industries and countries manufacturing our products. It is the supplier’s responsibility to achieve and maintain these standards and to enforce these standards with their own supply chain.

Transparency

In today’s increasingly transparent world there is a greater need than ever to make these standards and management systems part of our suppliers’ everyday business and for them to be able to demonstrate they are doing so. In this spirit Bilko is committed to working with our suppliers in an open, constructive and transparent manner and we request our suppliers do the same.

Workforce and Human Rights

The people working for our suppliers are to be treated with respect, and their health, safety and basic human rights must be protected and promoted. Each supplier must strive to comply with all relevant local and national laws and regulations particularly with regard to:

• HR Management Systems and Processes
• Labour Standards and Human Rights
• No Discrimination and Equal Opportunities
• Decent Working Conditions
• Health and Safety
• Terms of Employment
• Working Hours and Wages
• Avoidance of Modern Slavery and Forced Labour

Modern Slavery Act 2015

Bilko prohibits the use of all forms of forced labour, including prison labour, child labour, indentured labour, bonded labour, military labour, slave labour and any form of human trafficking.

Bilko comply with all regulations at set out in the Modern Slavery Act 2015 and expect our suppliers to demonstrate compliance.

Production sites and labelling

Suppliers must agree with us in advance the production site or sites to be used for each order: no subcontracting of our orders from these agreed locations is allowed.

All products sold by Bilko must be labelled with their country of origin.

Regular assessment

All product production sites are visited and assessed regularly by our suppliers and by our own people. Together we strive for continual improvement.

Environmental responsibility

At the very least, suppliers must meet all relevant local and national regulations. In addition, we expect them to meet all the relevant Bilko standards relating to the environment.

Extending these principles throughout the supply chain

We expect our suppliers to adopt similar principles in dealing with their own suppliers.

Our commitment to suppliers

Bilko acknowledge that it has responsibilities to its suppliers, and we will support to continually improve.

Signed: Chris Carr
Operations Director
January 1st 2017

Suppliers must apply to this policy at all times, and must also be able to demonstrate that they are doing so. We will work with suppliers to support any necessary improvements but we will also take action, which may involve cancelling contracts and ceasing to trade, if suppliers are not prepared to make appropriate changes.

Ethical Sourcing Policy Principles

General

This table sets out the standards that we expect our suppliers to comply with and the processes and systems that we expect them to implement in order to promote respect for human rights, sustainability and decent working conditions. Each supplier must strive to comply at a minimum with the following standards, and apply the following processes. They do not preclude adopting higher standards or more stringent processes.

In compiling these standards we have drawn from the UN Universal Declaration of Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, the UN Guiding Principles on Business and Human Rights, the UN Women’s Empowerment Principles, the UN Human Right to Water and Sanitation, the Children’s Rights and Business Principles and the UN Global Compact as well as a number of internationally recognised collaborative codes, including the Ethical Trading Initiative Base Code and the Global Social Compliance Programme Reference Code. In doing so, we aim to align our requirements with international standards and to promote comparability between the standards of different buying companies, thus reducing excessive compliance burden on suppliers.

Management systems and processes
Compliance with national law	In addition to these principles, suppliers must comply with all relevant local and national laws and regulations. Unless there is conflict between national law and any supplier obligation in these Principles, the supplier must adhere to the standard that promotes the higher level of protection for workers, communities and other rights holders.
Human resource policies	Suppliers must adopt and implement human resources policies and procedures appropriate to their size and workforce, which are consistent with the requirements of national law and these principles.
Information about employment & employee relationship	Work performed must be on the basis of a recognised employment relationship established in compliance with national legislation and practice and international labour standards. Suppliers must ensure all workers on their sites are provided with written and understandable information about their employment conditions, including wages, hours, and holidays, before they enter into employment; and about details of their wages for the pay period concerned each time that they are paid.
Temporary workers rights	Temporary labour arrangements must not be used to avoid obligations to workers under labour or social security laws and regulations arising from the regular employment relationship. For example: excessive use of fixed- term contracts, labour-only contracting, sub-contracting, home-working or apprenticeship schemes.
Worker consultation	Suppliers must develop processes for communicating and consulting with workers and their democratically elected representatives to share information on the business and to gather feedback. Where relevant a gender committee should be considered to ensure women’s health and rights are considered and their voice heard by management. Workers, without distinction, have the right to join or form trade unions of their own choosing and to bargain collectively, without prior authorisation from suppliers’ management, according to national law. Suppliers must not interfere with, obstruct or prevent such legitimate activities. Where the right to freedom of association and collective bargaining is restricted or prohibited under law, suppliers must not hinder workers from developing alternative mechanisms to express their grievances and protect their rights regarding working conditions and terms of employment. Suppliers must not seek to influence or control these mechanisms. Suppliers must adopt an open attitude towards worker representation and the activities of trade unions. Suppliers must not discriminate against or otherwise penalise worker representatives or trade union members because of their membership of, or affiliation with, a trade union, or their legitimate trade union activity, in accordance with international labour standards. Suppliers must give worker representatives access to the workplace in order to carry out their representative functions, in accordance with national law and international labour standards.
Forced labour	All work must be conducted on a voluntary basis, and not under threat of any penalty or sanctions. Suppliers must ensure that workers are not required to make deposits/financial guarantees/payments to employers, labour providers or agencies to obtain work, and must not retain original copies of identity documents (such as passports, identity cards, etc.) Bonded/indentured labour is prohibited. Suppliers must respect the right of workers to terminate their employment after reasonable notice and to receive all owed salary. Suppliers must respect the right of workers to leave the workplace after their shift. There must be no forced, bonded or involuntary prison labour.
Child labour	Suppliers must not employ workers who are younger than: the legal minimum age for employment applicable to the supplier; or the age of completion of compulsory education; In any event, a supplier must not employ a person under the age of 15 in any circumstances and must implement robust age verification checks at all times to ensure this policy is upheld. Suppliers must not recruit child labour nor exploit children in any way. If children are found working directly or indirectly for the supplier, the supplier must implement a remediation plan, develop or participate in and contribute to policies and programmes that put the best interests of the child first, and enables the child to access appropriate Young workers under 18 years of age must not be employed to work at night, or in conditions which compromise their health, their safety or their moral integrity, and/or which harm their physical, mental, spiritual, moral or social development. All work of persons under the age of 18 must be subject to an appropriate risk assessment and regular monitoring of health, working conditions, and hours of work. education until no longer a child.
Discrimination and Equal Opportunities	Suppliers must treat all workers with respect and dignity. Suppliers must base the employment relationship on the principle of equal opportunity and fair treatment. They must not engage in, support or tolerate discrimination in any area of employment. Suppliers must not discriminate against any worker based on race, color, age, gender, sexual orientation, ethnicity, disability, religion, political affiliation, union membership, national origin, or marital status in hiring and employment practices such as applications for employment, promotions, rewards, access to training, job assignments, wages, benefits, discipline, and termination. Suppliers must not require a pregnancy test or discriminate against pregnant workers except where required by applicable laws or regulations or prudent for workplace safety. In addition, suppliers must not require workers or potential workers to undergo medical tests that could be used in a discriminatory way except where required by applicable laws or regulations or prudent for workplace or food safety. Suppliers should have an equal opportunity employment policy that promotes gender equity in employment practices, and states maternity leave provision and support for child care where appropriate.
Harassment and abuse	Suppliers must commit to a workplace free of harassment. Suppliers must prohibit and must not tolerate all forms of physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse, corporal punishment, mental coercion, physical coercion or other forms of intimidation. Suppliers must not place unreasonable restrictions on entering or exiting the company facilities. Suppliers must prohibit harassment and unlawful discrimination in the workplace. Suppliers should provide training on non-discrimination and harassment where possible.
Disciplinary procedures	Suppliers must establish written disciplinary procedures and must explain them in clear and understandable terms to their workers. All disciplinary actions and performance management actions must be recorded and explained to workers. Workers must have the right to trade union or other appropriate representation at disciplinary action which may lead to significant disciplinary penalties or dismissal.
Workplace grievances	Suppliers must provide a grievance mechanism for workers (and their organisations, where they exist) to raise workplace concerns. This grievance mechanism must involve an appropriate level of management and address concerns promptly, using an understandable and transparent process that provides timely feedback to those concerned, without any retribution. The mechanism must also allow for anonymous complaints to be raised and addressed. The existence and scope of this mechanism must be clearly communicated to all workers and their representatives, and all workers must have equal access.
Healthy and safe working conditions	Suppliers must provide safe and clean conditions for all workers on site in all work and residential facilities and must establish and must follow a clear set of procedures regulating occupational health and safety. Suppliers must take adequate steps to prevent accidents and injury to health arising out of, associated with, or occurring in the course of work, by minimising the causes of hazards inherent in the working environment. Appropriate and effective personal protective equipment must be provided as needed. Suppliers must provide all workers with access to clean toilet facilities which respect worker dignity and to safe and clean drinking water and, if applicable, sanitary facilities for food preparation and storage. Suppliers must provide regular and recorded health and safety training to workers and management, and such training must be repeated for all new or reassigned workers and management. Suppliers must assign the responsibility for health and safety to a senior management representative and must carry out regular risk assessments. Suppliers must provide adequate safeguards against fire, and must ensure the strength, stability and safety of buildings and equipment, including residential facilities where provided. All sites must have an effective fire safety management system in place. This must include but not limited to: Responsibility of general manager for overall fire safety Ongoing risk assessments Training for fire safety personnel Appropriate and reliable equipment Clear and safe evacuation systems Regular fire drills for all shifts and all types of workers (site must keep a list of trained personnel) All systems must be reviewed on a frequent basis. Suppliers must provide access to adequate medical assistance and facilities.
Worker accommodation	Suppliers must ensure that residential facilities for workers, where provided, are clean and safe and meet the needs of workers. Workers’ accommodation arrangements must not restrict workers’ freedom of movement or of association. Suppliers must provide accommodation in a manner consistent with the principles of non-discrimination and equal opportunity.
Wages and benefits	Suppliers must pay workers a fair wage and benefits and have a transparent process to ensure that workers fully understand the wages that they receive. Suppliers must compensate all their workers by providing wages, overtime pay, all legally required benefits and paid leave which respectively meet or exceed the national legal minimum wage, and all applicable laws and regulations. (If industry benchmark standards and/or collective agreements are in place, provided they are higher than the minimum wage, these must be followed). Wages should be paid regularly and on-time. Suppliers should work towards paying workers a fair living wage. Suppliers must not make any deduction from wages as a disciplinary measure. Suppliers must not make any deductions from wages which are unauthorised and not provided for by national law. Workers must be fully informed of any deductions made to their pay. All deductions must be recorded. Suppliers must ensure that men and women receive equal pay and conditions for the same jobs.
Working hours	Suppliers must ensure that working hours comply with national laws or benchmark industry standards or relevant international standards, whichever affords greater protection to ensure the health, safety and welfare of workers. Working hours, excluding overtime, must not exceed 48 hours per week. The total hours worked (including overtime) in any week must not regularly exceed 60 hours in a single week. Working hours may exceed 60 hours in a single week only in exceptional circumstances where any of the following are met: this is allowed by national law; this is allowed by a collective agreement freely negotiated with a workers’ organisation representing a significant portion of the workforce; appropriate safeguards are taken to protect the workers’ health and safety; and the employer can demonstrate that exceptional circumstances apply such as seasonal work, accidents or emergencies. All overtime must be voluntary and must not be requested on a regular basis. Suppliers must ensure that all workers receive on average two days off in fourteen, as well as annual holidays.
Agency⁄Indirectly Employed Workers	Suppliers should have due diligence processes in place to ensure that workers on their site do not pay any form of recruitment fees to any agents to gain employment. Suppliers are responsible for the rights of all workers on their site whether they are directly employed or employed or engaged through a labour provider, agent or a contractor. Suppliers must have a process to ensure that they have a record of all workers working at their site including those engaged through an agency, labour provider or contractor within three days of beginning employment or being on site. Suppliers must meet any local laws relating to the use of agency ⁄labour provider workers including to workers at their own suppliers and sub- contractors, and to workers supplied by agencies, for example by including these standards in contractual or procedural agreements with third party employers. Suppliers must have a clear written agreement with their labour provider to ensure that the welfare of workers is safeguarded (including their health and safety, payment and benefits terms, accommodation, non- discrimination), and must monitor adherence to this agreement.
Right to work	Suppliers must have a process that enables them to ensure that all workers working on their premises are documented and have a right to work legally.
Factory Closure⁄Reorganisation⁄Restructuring	Prior to implementing any restructuring / re-organisation or closure involving dismissal of workers, suppliers must implement a process involving reviewing viable alternatives and setting out a retrenchment plan to reduce the adverse impacts of retrenchment on workers. The retrenchment plan will be based on the principle of non-discrimination and will reflect consultation with workers and their organisations. The suppliers will comply with all legal and contractual requirements. Workers must be paid all owed salary and paid for their notice period.
Subcontracting	Sub-contracting to other suppliers, sites, or units is not permitted without pre-authorised permission from Bilko.
Bribery and corruption	Suppliers must not offer/ give to, or receive from, Bilko staff or agents or contractors working on our behalf, any gift or other benefit that could be considered a bribe. Bilko employees are, in turn, required to refuse to accept, and not offer, any gift or service that could be construed as a bribe. Suppliers must uphold fair business standards in advertising, sales, and competition.
Engagement	Suppliers must accurately record and disclose information regarding their business activities, structure, financial situation, and performance in accordance with applicable laws and regulations and prevailing industry practices. Suppliers are expected to engage with the BILKO ethical trading programme and be open to audits, visits and training programmes, including worker interviews.
Environment	At the very least, suppliers must comply with all local and national environmental regulations and completed a supply chain risk assessment to understand their impact on the environment. In addition, they must meet all relevant Bilko standards relating to the environment.
Land rights	We expect all suppliers to adhere to the practice of Free and Prior informed consent for land rights and suppliers must conform to local, national and international standards of land tenure when working in communities. Where applicable this may include evidence of a due diligence process within communities to understand where established rights to property and land lie.
Supply chain monitoring	It is our supplier&aps responsibility to enforce these standards with their own supply chain. As part of their supply chain risk assessment they must be aware of more vulnerable groups like women, migrant workers, indigenous peoples, smallholders and homeworkers, and subcontracting and have adequate measures in place to ensure the rights of these groups are upheld.

Our commitments to suppliers

Setting expectations	We work with suppliers to set standards and expectations appropriate to their industry, country and business.
Due diligence	We undertake due diligence assessments of human rights and sustainability impacts of our business and set ambitious targets to mitigate our negative impacts and improve performance.
Guidance	We will provide guidance to suppliers to help them understand our requirements and to implement policies and procedures to enable them to comply with our standards.
Support	We provide suppliers with practical support, advice and assistance so that they develop their own policies and processes to enable them to implement high standards.
Dialogue	We will provide agreed dialogue mechanisms to maintain open communication with suppliers and to receive feedback about our own standards and behavior where appropriate.
Grievances and complaints	We will provide a process so that all complaints from suppliers about our standards and behavior are dealt with fairly and transparently.
Purchasing practices	We will keep our buying practices under review and ensure that our behavior supports suppliers in complying with our standards.
Allegations	Bilko will investigate all allegations about suppliers in a thorough and diligent manner with clear communications to all parties involved.
Assessment	We ensure that all production sites are visited and assessed regularly and that we provide advice and feedback on improvements. We will facilitate assessment methods that focus on underlying issues. We may commission third parties to audit and inspect production sites.
Termination	Should suppliers consistently fail to live up to these standards, and be unwilling to institute improvements or prepared to make appropriate changes, we will take action, which may involve cancelling contracts and ceasing to trade.
Stakeholder engagement	We will regularly consult stakeholders to understand their perspectives on the impacts of our supply chain, and we will, where appropriate, involve stakeholders in our programmes and projects to improve working conditions and respect for human rights.

Modern Slavery Statement 2017

This statement has been published in accordance with the Modern Slavery Act 2015. It sets out the steps taken by Bilko during year ending 31st December 2016 to prevent modern slavery and human trafficking in our business and supply chains.

Introduction

We know that slavery, servitude, forced labour and human trafficking (Modern Slavery) is a global and growing issue given the rapid rise in global migration, existing in every region in the world and in every type of economy, whether industrialised, developing or in transition. No sector or industry can be considered immune or untainted. Bilko has a zero-tolerance approach to Modern Slavery of any kind within our operations and supply chain. We all have a responsibility to be alert to the risks, however small, in our business and in the wider supply chain. Staff are expected to report concerns, using the appropriate reporting channels, and management are expected to act upon them.

Our business and supply chains

Our business depends on a reliable, global network of suppliers and subcontractors - more than 30 companies provide us with services and products.

We expect all suppliers to demonstrate responsible business practices, including ethical sourcing and protecting human rights. We aim to fulfil this commitment by seeking relationships with suppliers who share a common commitment to:

• Conduct business in an ethical manner and abide by all legal and regulatory requirements
• Comply with the international labour practice standards with specific focus on the ILO Conventions including conventions pertaining to;
• freedom of association and the right to collective bargaining
• elimination of all forms of forced or compulsory labour
• effective abolition of child labour
• elimination of discrimination with respect to employment and occupation
• Respect the human rights of all stakeholders in the supply chain
• Provide a safe and healthy workplace to its employees and other partners
• Demonstrate commitment to protect the environment by conserving natural resources, preventing pollution, implementing waste reduction and management programs and minimising its impact on the climate
• Promote diversity and inclusivity
• Maintain transparency and disclose sustainability performance and practices in line with regulations or international practices
• Demonstrate leadership by propagating the sustainability agenda upstream to its own supply chain

A system and process driven approach based on our management system principles ensures compliance with these standards and demonstrates continual improvement.

Bilko looks forward to building sustainable and mutually rewarding partnerships with its supply chain with a view to contribute to its own business governance and that of the people & planet.

Policies and contractual controls

Bilko’s internal policies cover human rights and ethical and safe working practices.

We are a UN Global Compact signatory, and confirm that we will not tolerate or condone abuse of human rights within any part of our business or supply chains and will take seriously any allegations that human rights are not properly respected. We also operate a whistleblowing policy, aimed principally at our employees but also available to others working in our supply chains which encourages staff to report any wrongdoing which extends to human rights violations like Modern Slavery. All reports will be fully investigated and appropriate remedial actions taken.

All of our policies are developed by subject matter experts, and signed off at Director-level.

All suppliers are required to comply with our Bilko’s Terms and Conditions and code’s of conduct, and with business-area specific ethical policies, which require them to:participate in audit assessments. We will only deal with suppliers and subcontractors that;

• Provide employees with good working conditions, fair treatment and reasonable rates of pay; and
• Respect workers’ human rights and comply fully with all applicable laws.

The above policies also require that:

All work must be voluntary, and not done under any threat of penalties or sanctions

• Workers must not pay any deposits for work, and employers – whether labour users or recruiters – must not keep original copies of identity documents.
• Indentured labour is prohibited, and workers must be free to leave work at any time, with all salary owed to be paid.

Due Diligence and audits of suppliers and supply chain

We understand that our biggest exposure to Modern Slavery could lie within our subcontractor network.

Within these areas, new suppliers are subject to due diligence checks in the form of subcontractor and supplier audits which are conducted by, or on behalf of the Bilko’s Operations Director. Such audits are also regularly conducted for existing suppliers. These audits assess compliance with legal requirements, health & safety, ethical and sustainable business practices and are, amongst other things, intended to identify any Modern Slavery practices.

Supplier standards

We expect our suppliers to uphold the same standards for business conduct we ask of our own employees, building capacity amongst suppliers to live these values improves environmental and social conditions worldwide.

Supplier diversity

We are strongly committed to using and developing local and small business suppliers including promoting women in the manufacturing industry.

Progress towards a sustainable supply chain

We pursue sustainable supply chain management by engaging and doing business with subcontractors and suppliers in ways that drive affordability and innovation through responsible sourcing and environmental stewardship.

The goal is to align our supplier base’s social, ethical, environmental, safety and health responsibilities with our own ethical goals and objectives.

Assessment of Modern Slavery risk within our supply chain

In the past year we have increased our focus on Modern Slavery within our wider business operations, we have mapped our supply chains to assess particular industry⁄sector and geographical risk, these assessments cover the entire scope of our business.

Modern Slavery training

We have trained our key staff in Modern Slavery and human rights using information provided by HM Government and the Home Office.

Assessment of effectiveness in preventing Modern Slavery

We understand that Modern Slavery risk is not static, and we will continue to improve our approach to mitigating this risk in the year ahead.

In order to assess the effectiveness of the measures taken by Bilko we will be reviewing the following key performance indicators and reporting on them in future Modern Slavery Statements:

• staff training levels;
• actions taken to strengthen supply chain auditing and verification;
• steps taken to upskill our high-risk suppliers, and assessing their ability to detect and mitigate modern slavery risk in supply chains; and
• investigations undertaken into reports of Modern Slavery and remedial actions taken in response.

Signed

Chris Carr
Operations Director
Date: 1st February 2017

Quality Policy Statement

Bilko recognises the importance of ensuring that quality remains paramount, not only to comply with our Clients needs but also to act as a recommendation for future contracts.

Our Policy is as follows:

• To always look closely at the Clients needs and requirements.
• To ensure that all Company Employees are made aware of their own responsibility towards the quality of their own work.
• To give all Employees adequate information and training to achieve the best possible results in their works.
• To understand and manage any risk associated with the quality offered.
• To work with and assist others when needed to implement this policy.
• To openly admit when mistakes are made so that they can be investigated to ensure that the shortfall does not happen again.
• To attempt to continually improve quality and performance.
• For the Management to review at least annually business quality objectives and discuss any targets for the next period.
• To perform regular independent audits on contracts with regards to quality and performance which will then be brought to the attention of the Director.
• To work with suppliers who comply with the requirements of the Modern Slavery Act, and work in an ethical and transparent way.

This policy will be regularly monitored and reviewed by Chris Carr.

Chris Carr
Operations Director
Date: 1st February 2017