Code of Conduct for Manufacturers and Suppliers
"The quality of our garments also relies on the quality of the relationships we build. The Code of Conduct is our promise of transparency: a concrete commitment to respecting people and the planet, at every stage of production."
PREAMBLE
1. LABOR
1.1. Child labor
1.2. Non-discrimination
1.3. Forced labor
1.4. Coercion and Harassment
1.5. Freedom of Association
1.6. Health and Safety
1.7. Wages
1.8. Working hours
2. PROHIBITION OF CORRUPT ACTS
3. ENVIRONMENTAL PROTECTION
3.1. Chemical management and product safety
3.2. Resource management
3.3. Waste and emissions
3.4. Deforestation, packaging, and animal welfare
3.5. Circular economy
4. COMPLIANCE WITH THE "CODE OF CONDUCT" AND MONITORING
5. PARTNER QUALIFICATION AND SUSTAINABILITY AND TRACEABILITY RATING
6. PUBLICATION
CONCLUSIONS
PREAMBLE
The Code of Conduct and the Social Responsibility Program of SORBINO UOMO S.P.A. constitute an integral and substantial part of all Agreements and, by signing this document, the Supplier accepts both the Code of Conduct and the Social Responsibility Program. The Supplier guarantees and declares that it accepts the terms and conditions contained herein and undertakes to strictly comply with them. Likewise, the Supplier guarantees and declares that it complies with all applicable labor laws, in particular those relating to the minimum age of workers. The Code applies to all operating units, subsidiaries, affiliates, suppliers, and subcontractors.
The "Supplier Code of Conduct" applies to the entire supply and/or production process that our Partners carry out in their operating facilities.
Should any of the provisions contained in the "Code of Conduct" conflict with the national laws in force in the supplier's country, the latter shall prevail.
1. LABOR
1.1 Child labor
“Child labor” means the work of a person under 15 years of age (or 14 years, where such limit is provided for by local laws) or, if older:
a) the minimum age provided by local law for employment purposes;
b) the age at which compulsory education is completed under local laws.
Suppliers employing young minors who do not fall under the aforementioned definition of “child labor” shall observe all laws, collective bargaining agreements, and any regulations applicable to the employment relationships in place with such workers.
Regardless of the above, the minimum age for performing work considered hazardous or during night hours is 18 years.
1.2. Non-discrimination
Suppliers shall not adopt any form of discrimination in hiring practices, including salary determination, health care, social security treatment, career opportunities, disciplinary measures, or termination of employment, based on race, religion, age, nationality, social or ethnic origin, sexual orientation, gender, political opinion, or any handicaps that are not incompatible with the role to be performed.
The only criterion allowed for the classification of workers consists of their skills and willingness to perform the work for which they are candidates.
To ensure the application of the above criterion, Suppliers must formalize clear job descriptions for their employees and define every aspect related to workers' rights, including the drafting of professional and behavioral conduct regulations.
1.3. Forced labor
Suppliers shall not subject any worker to forced labor. It is forbidden to interfere with the worker's freedom by requesting money deposits, withholding identity documents, or withholding wages.
Suppliers must allow workers to terminate their employment contracts after the notice periods provided for by law and/or collective bargaining agreements.
1.4. Coercion and harassment
Suppliers shall treat all workers with dignity and respect and shall not adopt corporal punishment, nor threats of violence or other forms of physical, sexual, psychological, or verbal harassment or abuse, etc.
They must establish written disciplinary procedures in compliance with applicable laws, clearly explaining the terms to workers and maintaining a record of disciplinary actions taken. Furthermore, they must establish a communication channel that allows workers to report any abuse suffered within the company, guaranteeing the protection and safety of the whistleblower through a predefined procedure that allows the veracity of the reports received to be verified within predefined times.
1.5. Freedom of association
Suppliers shall respect the right of their workers to associate, organize, and freely bargain their working conditions without suffering penalties and without any kind of conditioning. When the right to freedom of association and collective bargaining is prohibited by law, Suppliers must take action so that workers can establish alternative forms of representation and negotiation.
1.6. Health and safety
Suppliers shall provide workers with a safe and healthy workplace from a structural point of view that meets all applicable laws and regulations, ensuring access to drinking water and sanitary facilities, the safety of fire protection systems and equipment, the safety of machinery and electrical systems, emergency exits, lighting, ventilation, and an adequate ambient temperature with respect to the work performed in such places.
Furthermore, they shall ensure that health and safety standards are applied to any dormitories and canteens provided by them to workers. Separate dormitories, changing rooms, and restrooms must be made available for men and women.
Suppliers must take precautions to prevent accidents or damage to health caused by work, ensuring that the handling and storage of chemicals, machinery, equipment, and electrical systems are managed in a professionally safe manner and, where present, in line with legal regulations. They must regularly train workers with courses regarding health and safety in the workplace and the use of protective equipment, which must be delivered to workers and constantly replenished as needed, where prescribed.
1.7. Wages
Suppliers must pay their workers at least the minimum wage provided for by national law or the collective bargaining agreement, should it be more favorable than the minimum wage provided for by national law. Wages must correspond to the experience, qualification, and ability of the worker to perform the assigned work.
They are mandatory required to comply with laws, collective bargaining agreements, and regulations in force regarding working hours and wages. In particular, they must respect current regulations regarding minimum wage, overtime, permitted working hours, rates, and other elements of remuneration such as holidays, rest days, maternity leave, sick leave, and health care provided by law.
Wages must be paid regularly, in accordance with the times provided for by law or by the agreements in force.
No unfair deduction is permitted, and the worker has the right to receive a written specification regarding how their salary was calculated.
To ensure the application of the above criterion, Suppliers must formalize clear job descriptions for their employees and define every aspect related to workers' rights, including the drafting of professional and behavioral conduct regulations. They must inform and train their workers on what is specified in this paragraph so that people can know the reason for any promotion or penalty and the possibilities for career advancement.
Where provided by local laws, workers must receive a copy of the contract, written in the local language, duly signed.
1.8. Working hours
Except in extraordinary circumstances, Suppliers shall not require workers to work for a number of hours exceeding the limits on regular and overtime hours provided for by local laws. Should the laws in force not limit working hours, regular hours shall correspond to the typical regular work week of the supplier's country of residence, plus 12 hours of weekly overtime, if permitted by local laws.
Furthermore, they must define working hours by contract in a number in line with national law or collective bargaining agreements, with a maximum of 48 hours per week excluding overtime.
The Supplier must grant workers the breaks provided for by law and, when the law does not provide for them, must grant a minimum of 15 minutes of break for every 4 working hours.
Except in extraordinary circumstances, workers shall be entitled to at least 1 day of rest every 7 days or, when the law of certain countries provides for a different count of rest days, two days every 14; they must allow workers to be able to use the holidays provided for by law.
For overtime hours, they shall grant workers the increase provided for by the applicable law based on the normal hourly wage or, in the event that no increase is provided for by law, a wage of not less than 125% of the base pay. Where local industry standards are higher than those provided for by law, Partners must observe the former.
To minimize unsolicited overtime, the supplier shall create an overtime program on a voluntary basis for workers that allows the supplier to turn primarily to workers who want to work overtime.
2. PROHIBITION OF CORRUPT ACTS
SORBINO UOMO S.P.A. is aware that corruption represents one of the harmful phenomena for our society and it is for this reason that it firmly condemns it and has a zero-tolerance policy regarding corruption practices, therefore all business decisions that involve us must be based on meritocratic principles.
We call upon Suppliers to:
• refrain from giving rise to corrupt phenomena of any kind;
• exhibit behaviors inspired by full respect for the law and the deontological principles contained in their own Code of Ethics.
It is therefore forbidden to promise and/or pay and/or offer and/or solicit the receipt and/or receive, directly or indirectly, compensation of any kind, gifts, economic advantages, or other utilities that:
• exceed a modest value and the limits of reasonable courtesy practices;
• are likely to be interpreted as aimed at unduly influencing the relationships between the parties and the professionalism of SORBINO UOMO S.P.A. employees in the exercise of their activities, responsibilities, and decisions.
In the event that there is corruption or an attempted corruption in any relationship with SORBINO UOMO S.P.A., you are asked to report it by writing to the e-mail address info@sorbino.com or by any other means preferred by the whistleblower.
The Reports must be detailed regarding specific events and based on precise and consistent factual elements.
SORBINO UOMO S.P.A. ensures confidentiality regarding the identity of the whistleblower and the protection of the rights of the Supplier or of the persons who may be accused erroneously and/or in bad faith.
3. ENVIRONMENTAL PROTECTION
At SORBINO UOMO S.P.A. we know that to guarantee future generations the availability of the same resources we have today, we must ensure that the impact our activity generates on the environment is increasingly contained. To do this, we must control and continuously improve those processes in our supply chain that could have a negative impact on the environment.
3.1. Chemical management and product safety
Suppliers must obtain all environmental permits necessary to operate and keep them in force. They must ensure compliance with all international regulations regarding product safety and the environment such as, but not limited to, the EU-REACH regulations/standards, OEKO-TEX, EN standards, ISO standards, ZDHC.
Chemical substances must be adequately stored in safe, compliant environments and must bear indications for use and danger using appropriate labels. Each chemical product must have the relevant technical data sheet, and the ability to access the inventory of chemical substances must be guaranteed. People with adequate training for their management must be identified.
Suppliers must ensure that the products they provide to SORBINO UOMO S.P.A. comply with the latest version of the Manufacturing Restricted Substances List (RSL).
SORBINO UOMO S.P.A. requires its suppliers to ensure that the actors in their distribution chain integrate these provisions into their commercial policies and practices.
Suppliers of products and raw materials are recommended to define an environmental management system (e.g., ISO 14001) to meet environmental compliance obligations and limit their impact on the environment. Suppliers must provide an environmental action plan and monitor their environmental impact.
3.2. Resource management
As minimum measures to be adopted, Suppliers must measure energy consumption (in kWh of electricity, m3 of gas, or liters of fuel) and water (in m3), the volume of liquid waste (in m3), and solid waste (in tons) on a monthly or quarterly basis. This information must be disclosed to SORBINO UOMO S.P.A. whenever requested.
Should the Supplier have an environmental impact reduction program with defined objectives and timelines, or intends to do so, the supplier must inform us of the achievement of the established objectives.
Suppliers that have "wet" processes (e.g., laundries) must adopt adequate measures to monitor water consumption; it must be used as efficiently as possible. The greatest impact that the textile-clothing industry has on the environment is precisely on water, and it is for this reason that at SORBINO UOMO S.P.A. we are interested in optimizing the use of water as well as decreasing the inefficient impact that our supply chain can have on it.
3.3. Waste and emissions
Suppliers must adopt adequate measures to reduce waste through reuse and recycling actions when possible. They must make every effort to improve energy efficiency in buildings, transport, and production activities, to use renewable energy sources when possible, and to decrease, conversely, those based on coal. We will support the efforts that will be made to decrease waste and emissions. For this reason, we ask Suppliers to communicate to us the programs and investments they intend to make in this area and to keep us constantly updated regarding the achievement of the established objectives. This will allow us to proactively participate in possible initiatives aimed at fostering the achievement of the objectives.
3.4. Deforestation, packaging, and animal welfare
Suppliers must make every possible effort to ensure that their materials of plant or animal origin (e.g., viscose, paper, or leather) derive from supply chains that do not contribute to deforestation. Packaging must also favor recycled and/or certified materials (e.g., Forest Stewardship Council – FSC, etc.).
All procurement of materials composed of animal fibers (e.g., leather, wool, etc.) must facilitate those Suppliers that do not adopt cruel practices against animals or have adverse impacts on ecosystems or protected animal species.
3.5. Circular economy
SORBINO UOMO S.P.A. constantly verifies the impact that the raw materials (used for the manufacture of its products) have on the environment, committing itself to improving their efficiency.
The commitment is to make the textile-clothing industry as circular as possible, and to do this we favor initiatives such as:
• reuse of our customers' used garments;
• packaging of products obtained with fabric waste;
• packaging of products with organic, biodegradable, and/or recycled materials;
• packaging of products with high consumption optimization and, therefore, low material waste;
• promotion of creative ideas for the reuse of garments that are no longer used.
4. COMPLIANCE WITH THE “CODE OF CONDUCT” AND MONITORING
Suppliers shall authorize SORBINO UOMO S.P.A. and its designated delegates (including third parties) to carry out any monitoring activity necessary to confirm compliance with this “Code of Conduct”, including, but not limited to:
• unannounced inspections of the facility and of the housing provided by the supplier to its workers; such audits are carried out by our team or by third parties;
• the review of books and records related to the workers’ employment status;
• private interviews with workers.
Suppliers shall keep on the premises all documentation that may be necessary to demonstrate compliance with this “Code of Conduct”, which may include, by way of example and not limitation:
• copy of the contractual documents in place between the Supplier and the workers;
• copy of documents evidencing the amount and payment of workers’ wages;
• copy of documents evidencing compliance with social security obligations in relation to the workers;
• copy of documents evidencing the compliance of the workplaces and any housing made available to workers with the requirements indicated above;
• copy of documents evidencing the procedures implemented by the Suppliers to allow workers adequate representation and freedom of collective bargaining;
• copy of documents evidencing the compliance of the activities carried out by the Suppliers with environmental laws and the requirements indicated above.
Since, in the context of the aforementioned monitoring activities, we may need to process the personal data of third parties in relation to the Suppliers, we declare and warrant that all obligations and formalities provided for by the applicable European legislation on personal data protection are and will be complied with. In this regard and in particular, we declare that we possess the experience, technical skills, and resources that allow us to implement all appropriate technical and organizational measures to ensure compliance with legislation on the protection of personal data and the protection of the data subjects. Conversely, where necessary under the regulations in force from time to time in the countries where the Suppliers operate, the latter undertake from now on to obtain the consent of the data subject to whom the data, documents, and/or information refer, or, alternatively, of the subject entitled to authorize or deny its communication, for the processing and communication of the aforementioned data, documents, and/or information by SORBINO UOMO S.P.A. or by the specialized third-party companies that SORBINO UOMO S.P.A. decides to use.
5. PARTNER QUALIFICATION AND SUSTAINABILITY RATING AND TRACEABILITY
SORBINO UOMO S.P.A. adopts a rating system for each production unit based on the analysis and evaluation of every single non-conformity detected during inspections.
The evaluation considers the risk that the non-conformity poses to workers and the environment, as well as its duration over time.
Suppliers of raw materials and components must actively increase the transparency of their supply chain. SORBINO UOMO S.P.A. considers transparency to be the ability to identify the name and location of all actors in the supply chain upstream to the origin of the raw material. Whenever possible, suppliers must identify and trace the history, distribution, location, and application of products, parts, and materials.
In the context of sustainability, traceability is a tool to ensure and verify sustainability claims associated with goods and products, guaranteeing good practices throughout the supply chain. Traceability must be robust and verifiable.
Suppliers must provide reports and information on traceability when requested. Any change regarding the name and location of supply chain actors must be notified to SORBINO UOMO S.P.A.
Traceability information may be verified by a third-party auditing company.
6. PUBLICATION
Suppliers shall take the necessary measures to ensure that the terms of this “Code of Conduct” are communicated to workers and fully understood by them.
As a minimum measure to be adopted, everyone must make it accessible and available, translated into the workers’ language, posted on company notice boards and in all main workspaces, and must instruct workers regarding their rights and obligations defined therein.
For any clarification that the supplier and/or its employees may require, a written request can be sent to the e-mail address info@sorbino.com
CONCLUSIONS
SORBINO UOMO S.P.A. will pursue the aforementioned objective gradually, by activating a work program that will be established from year to year, depending on the supply markets and the economic sustainability of the project.
This “Code of Conduct” applies to every supplier wherever they may operate in the world, unless the provisions of the Code itself conflict with mandatory Italian and/or EU legislation. In such a case, the aforementioned legislation will prevail over the Code of Conduct. This Code is published and constantly updated on the website www.sorbino.com. Every Supplier belonging to the supply chain of SORBINO UOMO S.P.A. must act diligently to constantly check the updated version of the “Code of Conduct”, both by visiting the aforementioned website and by asking SORBINO UOMO S.P.A. directly via the e-mail address info@sorbino.com. Any alleged or actual violation of the provisions of this “Code of Conduct” must be reported to SORBINO UOMO S.P.A. by writing to the e-mail address info@sorbino.com.
SORBINO UOMO S.P.A. may open an investigative inquiry to understand the reported facts and subsequently decide on the adoption of any corrective actions to be required from the Suppliers.