Κώδικας Ηθικής

Code of Conduct

Introduction

Analytic

1. No forced labour
2. No child labour
3. No discrimination
4. No harsh or inhumane treatment
5. Respect for freedom of association and collective bargaining
6. Safe and hygienic working conditions
7. Wages are paid
8. Working hours are not excessive
9. Regular employment
10. Health and Safety of products
11. Environmental awareness
12. Confidentiality of information
13. Transparency
14. Reference to national legislation, Conventions and Agreements
15. Verification of compliance
16. Anti-Money Laundering

 

General Introduction

 

Social Code of Conduct

 

Management system, transparency and traceability:

As a company we ensure that:

1. all employment relationships are acknowledged and documented (in accordance with national laws, customs and practices and international employment standards) from the time of recruitment until the end of the employment contract;
2. all the company’s sales and management activities are carried out transparently and

correctly recorded in the company’s registers;

1. the principles set forth in this Code are circulated and applied consistently within our organisation;
2. we detect all acts which breach the principles of this Code, determine the

underlying causes of problems identified and implement measures to deal with such acts effectively in accordance with national laws, customs and practices and international employment standards;

1. the persons in charge of applying this Code and more generally the associated legal

aspects concerning employment law, security and the environment are informed and

trained;

1. action is taken against all forms of corruption, extortion, embezzlement and bribery;
2. its impact on the surrounding community, natural resources and the environment in

general is analysed so that the necessary procedures can be put in place to prevent and

minimise the negative effects connected with the partner’s operations;

 

 

Minimum age, forced labour regulations

As a company we ensure that:

1. Robinson SA complies with the national minimum age for admission to employment or work in any occupation. The national minimum age in Greece being 18 years old.
2. We neither recruit nor exploit children in any way.
3. We do not employ young workers under the age of 18 years old at night, or in conditions which could jeopardize their health, their safety or their moral integrity, and/or which could harm their physical, mental, spiritual, moral or social development in accordance with ILO Convention 182.
4. All work is conducted on a voluntary basis, and not under threat of any penalty or

sanctions.

5. The use of forced or compulsory or unpaid labour in all its forms and unpaid overtime work, is prohibited.
6. We shall not require workers to make unreasonable deposits/financial guarantees

and shall not confiscate identity documents off any worker (such as passports, identity cards, etc.). No abusive delayed payment of wages do occur.

7. Bonded labour is prohibited. We do not use any form of bonded labour nor permit

or encourage workers to incur debt through recruitment fees or other means.

8. Indentured labour is prohibited. We respect the right of workers to terminate their employment after legal notice. Moreover, we respect the right of workers to leave

the workplace and factory after their shift.

 

 

Non-Discrimination

As a company we ensure that:

1. We respect equal opportunities in terms of recruitment, compensation, access

to training, promotion, termination or retirement.

2. We shall not engage in, support or tolerate discrimination in employment including

recruitment, hiring, training, working conditions, job assignments, pay, benefits, promotions, discipline, termination or retirement on the basis of gender, age, religion, marital status, race, caste, social background, diseases, disability, pregnancy, ethnic and national origin, nationality, membership in worker organisations including unions, political affiliation, sexual orientation, or any other personal characteristics.

3. We base all terms and conditions of employment on an individual’s ability to do the

job, not on the basis of personal characteristics or beliefs.

 

 

Disciplinary practices, harassment and abuse

As a company we ensure that:

1. We treat all workers with respect and dignity.
2. We do not engage in or tolerate bullying, harassment or abuse of any kind.
3. We establish written disciplinary procedures and shall explain them in clear

and understandable terms to their workers. All disciplinary actions shall be recorded.

 

 

Freedom of association and grievance mechanisms

1. Workers have the right to join or form trade unions of their own choosing and to bargain collectively, without prior authorisation.
2. Where the right to freedom of association and collective bargaining is restricted or

prohibited under law, ROBINSON SA shall not hinder alternative forms of independent and free workers representation and negotiation, in accordance with ILO conventions.

3. ROBINSON SA does not discriminate against or otherwise penalise worker representatives or trade union members because of their membership in or affiliation with a trade union, or their legitimate trade union activity in accordance with ILO conventions.
4. ROBINSON SA gives internal worker representatives access to the workplace in order to carry out their representative functions in accordance with ILO conventions. Moreover, we make all possible efforts to maintain or participate in an effective information feedback and grievance mechanism at operational level to be able to respond to individuals and communities.

 

Working hours and overtime

As a company we ensure that:

1. We set working hours that comply with national laws and ILO conventions,

whichever affords greater protection to ensure the health, safety and welfare of workers.

2. We respect that the standard allowable working hours in a week are 48, excluding overtime. Workers shall not be required to work in excess of 48 hours per week on a regular basis.
3. Overtime shall be voluntary and shall not exceed 8 (eight) hours per week and shall not be requested on a regular basis.
4. We respect all workers’ right to at least one rest day in every 7 (seven) days period as well as annual paid leave period and public national and local holidays as per local regulations.

 

 

Remuneration and benefits

As a company we ensure that:

1. We compensate our workers by providing wages, overtime pay, benefits and paid leave which respectively meet or exceed legal minimum and/or industry benchmark standards and/or collective agreements, whichever is higher.
2. We acknowledg the fundamental nature of remuneration for workers and those who are dependent on them, ICS expects that the supplier shall not consider the legal minimum wage as an end in itself, but as a mere threshold not to be reached but to be exceeded, the goal sought being that this remuneration should be able to cover basic needs whilst guaranteeing a discretionary income.
3. We always compensate all workers for all overtime at a premium rate, as required by law and, where applicable, by contractual agreement.
4. We provide all legally required benefits, including paid leave, to all workers.
5. We do not make any deductions from wages which are unauthorised or not provided for by national law. We do not make any deduction from wages as a disciplinary measure.
6. We provide all workers with written and understandable information about

their employment conditions, including wages, before they enter into employment; and

about details of their wages for the pay period concerned each time they are paid.

7. Work performed must be on the basis of a recognised employment relationship established

in compliance with national legislation and ILO conventions, whichever affords the greater

protection.

 

 

 

Health& Safety principles:

RONINSON SA:

1. Provides safe and clean conditions in all work and residential facilities and

shall establish and follow a clear set of procedures regulating occupational health and safety.

2. Steps to prevent accidents and injury to health arising out

of, associated with, or occurring in the course of work, by minimising, so far as is reasonably practicable, the causes of hazards inherent in the working environment. Appropriate and effective personal protective equipment shall be provided as needed.

3. Provides access to adequate medical assistance and facilities.
4. Provides all workers with access to clean toilet facilities and to drinkable water and, if applicable, sanitary facilities for food preparation and storage.
   5. Ensures that residential facilities for workers, where provided, are clean and safe.
   6. Assigns the responsibility for health and safety to a senior management representative.
   7. Provides regular and recorded health and safety training to workers and management, and such training shall be repeated for all new or reassigned workers and management.
   8. Provides adequate safeguards against fire, and shall ensure the strength, stability and safety of buildings and equipment, including residential facilities where provided.
   9. Undertakes sufficient training of workers and management in waste management, handling and disposal of chemicals and other dangerous materials.

 

Analytic

 

1. No forced labour

Robinson SA shall not allow any form of forced or involuntary labour in their manufacturers and suppliers. They may not require their employees to make any kind of “deposits”, nor are they entitled to retain employees’ identity documents. Manufacturers shall acknowledge the right of their employees to leave their employer after reasonable notice.

2. No child labour

ROBINSON SA and suppliers shall not employ minors. ROBINSON SA defines minors as those persons who have not yet reached their 18th birthday. Young workers shall not work during night hours or in hazardous conditions.

3. No discrimination

ROBINSON SA and suppliers shall not apply any type of discriminatory practice with regards the recruitment, compensation, access to training, promotion, termination of the employment agreement or retirement, based on race, caste, creed,nationality, religion, age, physical or mental disability, gender, marital status, sexual orientation and/or union membership or political affiliation4 .

4. No harsh or inhumane treatment

ROBINSON SA treats their employees with dignity and respect. Under no circumstances shall physical punishment, sexual or racial harassment, verbal or power abuse or any other form of harassment or intimidation be permitted.

5. Respect for freedom of association and collective bargaining

ROBINSON SA and suppliers shall ensure that their employees, without distinction, have the right of association, union membership and collective bargaining. No retaliation may arise from the exercise of such right and no remuneration or payment whatsoever may be offered to the employees in order to hinder the exercise of such a right. Likewise, they shall adopt an open and collaborative attitude towards the activities of Trade Unions. Workers’ representatives shall be protected from any type of discrimination and shall be free to carry out their representative functions in their workplace. Where the rights to Freedom of Association and Collective Bargaining are restricted under law, the appropriate channels to ensure a reasonable and independent exercise of such rights must be designed.

6. Safe and hygienic working conditions

ROBINSON SA and suppliers shall provide a safe and healthy workplace to their employees, ensuring minimum conditions of light, ventilation, hygiene, fire prevention, safety measures and access to a drinking water supply. Workers shall have access to clean toilets facilities and drinking water. Where necessary, facilities for food storage shall be provided. Accommodation, where provided, shall be clean and safe. Manufacturers and suppliers shall take the required steps to prevent accidents and injuries to health of their workers, by minimizing as much as possible the risks inherent to work.

7. Wages are paid

ROBINSON SA ensures that wages paid meet at least the minimum legal or collective bargain agreement, should this latter be higher. In any event, wages should always be enough to meet at least the basic needs of workers and their families and any other which might be considered as reasonable additional needs. Manufacturers and suppliers shall not make any withholdings and/or deductions from wages for disciplinary purposes, nor for any reasons other than those provided in the applicable regulations, without the express authorization of workers. Likewise, they shall provide all workers with: written and understandable information about their wages conditions upon their recruitment, and detailed information about the particulars of their wages every time that these are paid.

8. Working hours are not excessive

ROBINSON SA and Manufacturers and suppliers shall adjust the length of the working day to the provisions of the applicable laws or of the collective bargain agreement applicable for the sector in question, if the latter affords greater protection for the workers. Manufacturers and suppliers shall not require their employees to work, as a rule of thumb, in excess of 48 hours a week and workers shall be granted at least one day off for every 7 calendar day period on average. Overtime shall be voluntary, shall not exceed 12 hours per week, shall not be demanded on a regular basis and shall always be compensated at a premium rate, pursuant to the provisions of the prevailing regulations in force.

9. Regular employment

ROBINSON SA undertakes that all the employment formulas they use are part of the applicable local laws. Thus, they shall not impair the rights of workers acknowledged under labour and social security laws and regulations by using schemes that have no real intention to promote regular employment in the framework of regular employment relationships.

 

10. Health and Safety of products

 

ROBINSON SA and suppliers are responsible for all products supplied to comply with health and safety product standards so that the commercialized products do not entail any risk to customers.

 

11. Environmental awareness

 

Manufacturers and suppliers shall be duly committed at all times to protect the environment and shall comply with the standards and requirements of the applicable local and international Laws and Regulations. Likewise, they commit to comply with environmental standards established by ROBINSON SA including, if applicable, the necessary measures to reduce and compensate such impact in order to apply said standards.

 

12. Confidentiality of information

 

ROBINSON SA and suppliers shall preserve the integrity and confidentiality of the information they may receive as a consequence of their commercial relationship. The obligation of confidentiality will remain once the relation with ROBINSON SA is terminated and it will include the obligation to return any material related to the company held by the manufacturer or supplier.

 

13. Transparency

 

ROBINSON SA and suppliers shall carry out their activities in an honest, upright and transparent way, keeping for these purposes an appropriate accounting records system that facilitates the traceability of their decisions, as a preventive measure versus any type of corruption, bribe and extortion that might arise. Manufacturers and suppliers shall not manipulate or influence their workers, nor shall they forge any files or records in order to alter the verification process regarding compliance with this Code. Manufacturers and suppliers shall neither offer nor accept remuneration of any kind which seeks, or may be perceived to seek, to affect the impartial judgment or the objectivity of such parties appointed by ROBINSON SA to carry out inspections and compliance audits in connection with this Code.

 

14. Reference to national legislation

 

Should national regulations or any other applicable Law or any other commitments undertaken or applicable, including collective bargaining agreements, govern the same issue, the provision which offers greater protection for workers shall apply.

 

15. Verification of compliance

 

Manufacturers and suppliers shall authorize ROBINSON SA and/or any third parties the former might appoint, to monitor the appropriate enforcement of the Code. For these purposes, they shall provide the required means and the appropriate access to the facilities and documentation required to ensure this verification.

 

16. Anti-Money Laundering

 

The Anti-Money Laundering and Terrorist Financing Policy (hereinafter, the “Policy” or the “AntiMoney Laundering Policy”) has been approved by the Board of Directors on 13 March 2018, following a favourable report of the Audit and Control Committee. Such Policy intertwines with the ethical values of ROBINSON SA defined in the Code of Conduct and Responsible Practices and in the Code of Conduct for Manufacturers and Suppliers. This Policy sets forth ROBINSON SA’s unbreakable commitment to anti-money laundering and the prevention of terrorist financing, and conveys its will to work with the competent authorities in the area. In this respect, this Policy seeks to lay down, in accordance with the prevailing international standards in the field, such yardsticks which aim at preventing that either ROBINSON SA or any company which is part of its corporate Group (as defined below), may be used upon carrying out any money laundering or terrorist financing proceedings. In this respect, all the provisions of this Policy are subject to the applicable regulations in each country, which shall always prevail. Considering the various business that ROBINSON SA conducts, the main effects of this Policy consist of (i) limiting cash payments at stores; and (ii) identifying and reviewing its business partners, its suppliers and other third parties.

 

For the purposes of this Policy, any of the following activities shall be deemed to be Money Laundering activities: a) The conversion or transfer of property, knowing that such property is derived from any offence or offences, or from an act of participation in such offence or offences, for the purpose of concealing or disguising the illicit origin of the property or of assisting any person who is involved in the commission of such an offence or offences to evade the legal consequences of his actions. b) The concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of property, knowing that such property is derived from ANTI-MONEY LAUNDERING AND TERRORIST FINANCING POLICY an offence or offences or from an act of participation in such an offence or offences. c) The acquisition, possession or use of property, knowing, at the time of receipt, that such property was derived from an offence or offences or from an act of participation in such offence or offences. d) Participation in, association or conspiracy to commit, attempt to commit and aiding, abetting, facilitating and counselling the commission of any of the offences established in accordance with the foregoing paragraphs. On the other hand, for the purposes of this Policy, Terrorist Financing shall be deemed to be the supply, deposit, distribution or collection of funds or goods, by any means, whether directly or indirectly, with the intention of using them or with the knowledge that they will be used, completely or in part, for the commission of any terrorism offences.

 

ROBINSON SA shall identify and get to know its business partners (franchisees, leftover dealers, suppliers and other business partners) pursuant to the due diligence measures provided in its internal regulations and, as the case may be, in the applicable laws and regulations. In this respect, before engaging in any business relationship, ROBINSON SA shall identify its business partner and the beneficial owner thereof, and establish that it is not subject to any system that imposes international sanctions to trade relationships. Therefore, ROBINSON SA shall abstain from engaging in any trade relationship with any potential business partner regarding which it is certain, or there are substantiated indications, that they are related to money laundering and/or terrorist financing activities. ROBINSON SA will implement, if appropriate, a Procedure to Identify and Get to know Business Partners, for the purposes of identifying its business partners and the beneficial owner thereof, as well as establishing that they are not subject to any system of international sanctions regarding trade relations. Additionally, ROBINSON SA shall regularly monitor its trade relationships with its business partners, in order to verify that the information available regarding any such partner has been duly updated. The Company shall not engage in any business relationship where it is not in a condition to apply the due diligence measures described above.

 

The Anti-Money Laundering and Terrorist Financing Policy will be reviewed and updated, where applicable, to bring it into line with any changes that the business model may undergo, or that may occur in the context where the Group operates, ensuring at all times the effective implementation thereof.