Ethical Policy

The Board of FKA Brands Ltd. are committed to ensuring that the people and communities providing the products and services we buy and sell are treated fairly and that their fundamental human rights are protected and respected. We expect our suppliers to share our commitment to ensuring fair treatment and respect for human rights of the people and communities in our supply chains and our understanding of the fundamental rights they are entitled to.

FKA conducts its own audits of potential suppliers and may conduct 3rd party SMETA 2 Pillar Ethical and Social audits using audit companies appointed by FKA, prior to appointing a new supplier and periodically on existing suppliers. At FKA’s discretion non-compliances for Reasonable Overtime and Employee non-participation in Social Insurance may be waivered. The current minimum standard is:

  • Up to 16 minors corrected within 28 days with objective evidence
    Or
  • 1 major and up to 10 minors corrected within 28 days with objective evidence

Factory and Labour Standards
The following minimum standards shall be met or exceeded by the Supplier.

  • Forced Labour: There shall not be any use of forced labour, whether in the form of prison labour, indentured labour, bonded labour or otherwise. Nor shall employee’s original personal documentation, including but not limited to ID cards, passports, nationality records, be retained by the employer or any agency for any reason except where permitted by local law and then only for the time permitted by local law.
  • Child Labour: Consumers expect that the products they purchase have been manufactured without the use of child labour at any point in the supply chain, from mining to distributing the finished product.
    ○ FKA define child labour as the employment of people under the age of 18. Anyone under the age of 18 must not be employed in roles which may jeopardise the health, safety or morals of that young person. Young people between the age of 15 and 18 can be employed in appropriate roles.
    ○ It is generally accepted that children are required to attend compulsory schooling until at least the age of 15. Children under 15 must not be employed anywhere in the supply chain. Where the local law permits the employment of children aged under 15 this is allowed provided the local requirements are met in full and they must not be employed in roles which may jeopardise the health, safety or morals of that young person.
  • Harassment or Abuse: Workers shall be treated with respect and dignity. Workers shall not be subject to any physical, verbal, sexual or psychological harassment or abuse in connection with their employment.
    ○ Employees must be free to associate with others, join or not join labour unions, seek representation and join workers' councils in accordance with local laws and regulations.
  • Non-discrimination: Workers should be employed and compensated based upon their ability to perform their job, rather than based on gender, race, religious or cultural beliefs.
  • Whistleblowing: Employees should be encouraged to bring to the attention of managers any violations of company policies. When an employee(s) brings forward, in good faith, a report of any violations of company policies there must be no retaliation against that employee(s) and where local laws permit their anonymity must be protected.
  • The supplier shall not engage in or support the use of corporal punishment, mental or physical coercion or verbal abuse
  • The supplier shall not allow behaviour, including gestures, language and physical contact that is sexually coercive, threatening, abusive or exploitative.
  • On site accommodation: Where provided, dormitories shall be well maintained, clean and safe, and equipped with appropriate emergency exits, hot water for showering, adequate heat and ventilation and personal space, all according to applicable local standards.
  • Wages and Benefits: Suppliers should recognize that wages are essential to meeting their workers’ basic needs. Suppliers shall pay workers for all work completed and shall pay at least the minimum wage required by local governing law or prevailing industry wage (whichever is higher) including legally mandated benefits. Wage deductions can only be made if legally approved. Wages shall be paid on time as required by local governing laws and not unreasonably withheld where no such law exists.
  • Overtime: Overtime or any work over the basic working hours included in the worker’s contract is accepted as part of the manufacturing process. In addition to compensation over basic hours of work, workers shall be compensated for overtime hours at a premium rate as legally required, or in countries where there is no legal standard, then at local industry standards. In no event shall this be at a rate less than the regular hourly rate. Factories shall carry out operations in ways that limit overtime to a level that ensures productive and humane working conditions.
  • Work Hours: As part of normal business operations, workers shall be entitled to one full day off work out of each seven-day week. Suppliers should not require in excess of a 48-hour work week on a regular scheduled basis, and any such work week shall be subject to the laws regarding the payment of overtime. In the case of those countries where laws do not limit the hours of work, workers should not be required to work on a regular basis in excess of a regular workweek plus 12 hours overtime. Workers shall not be asked or required to take work home or off premises.
  • SEDEX: suppliers are required to register and maintain a registration with SEDEX. The supplier shall complete the SEDEX SAQs within 2 months of being appointed.
  • Health and Safety: Suppliers shall provide a safe and sanitary working environment to avoid preventable work-related accidents, illnesses and injuries. Also ensuring adequate First Aid facilities and responders are readily available.
    ○ A senior manager will have direct responsibility for H&S on each site
    ○ Training will be given to all appropriate employees to ensure standards are maintained, issues reported and quickly addressed.
  • Fire Alarms: A Supplier’s site shall have the minimum of a manually-operated fire alarm supported by individual smoke detectors and ideally an integrated smoke/heat detecting automatic alarm.
  • Fire Exits: All Fire Exits at the Supplier’s premises must be approved to local governing laws, with Exits clearly signed and kept clear of obstructions at all times. Fire Exits MUST NOT be locked when the building is occupied.

 Anti Bribery

  • Bribery Act: As used the term “Anti-Bribery Laws” includes the UK Bribery Act 2010, or any similar law or regulation. Supplier must not act in any fashion or take any action that will render FKA or any of its affiliates liable for a violation of the Anti-Bribery Laws, which prohibit the offering, giving or promising to offer or give, directly or indirectly, money or anything of value to any official of a government, political party or instrumentality to any other third party to assist the Supplier or FKA in obtaining or retaining business or in carrying out Supplier’s duties and activities under the Order. Additionally, Supplier agrees not to receive or accept any payments or other benefits from any parties associated with the performance of its duties and payments or other benefits from any parties associated with the performance of its duties and activities under the Order.
  • Supplier agrees that failure to comply with the Anti-Bribery Laws, or receipt of payment or other benefits could compromise the integrity of the work performed and, therefore, FKA would have the right to terminate the Order immediately.
  • Supplier agrees that if any developments cause a representation or certification previously provided to FKA, whether in a due diligence questionnaire or other document, regarding Anti-Bribery Laws to no longer be accurate or complete, it will promptly inform FKA, in writing, of the causes and extent of the changes.

 

Management System to implement these Principles
FKA Brands shall appoint a senior manager responsible for implementation of its policy
FKA Brands shall give training to relevant employees with respect to compliance with its policy
FKA Brands shall perform periodic auditing to ensure conformity with these Principles; and,
FKA Brands shall correct in a timely fashion any deficiencies identified by periodic audits or other means.

Who we are
FKA Brands Ltd. is a wholly owned subsidiary of FKA Distributing Co LLC (FKA) a US limited liability partnership. FKA Brands Ltd. currently sells products in Europe, the Middle East and Africa under the following brands and licences:

  • Homedics
  • The House of Marley
  • Revamp Professional
  • Ellia
  • Sol Republic
  • HMDX

 

Swarup Banerjee
C.E.O and Vice President Europe

January 2023