Ethical Trading Policy

Draft for review. Items in [square brackets] need confirming before this policy is signed off.

Our approach

LaunchPad Manufacturing is committed to treating everyone who works for us fairly and with respect, and to running the business honestly and within the law.

Our standards follow the Ethical Trading Initiative (ETI) Base Code and UK law. Where the two differ, we apply whichever gives workers the greater protection. We organise our ethical practices around the four pillars of a Sedex Members Ethical Trade Audit (SMETA): labour standards, health and safety, environment and business ethics, so clients who use Sedex can assess us easily. [Sedex reference, if registered: ZC…]

Who this policy covers

Employees, agency and temporary workers, contractors, and the labour providers and suppliers who work with us.

Labour standards

We apply each clause of the ETI Base Code:

• Employment is freely chosen. There is no forced, bonded or involuntary labour. Workers can leave after giving reasonable notice. We never hold workers’ identity documents or charge them fees for work. See our Modern Slavery Policy.
• Freedom of association and collective bargaining are respected. Workers may join or form a trade union and bargain collectively, and worker representatives are not discriminated against.
• Working conditions are safe and hygienic. See our Health & Safety Policy.
• Child labour is not used. We do not employ anyone under [16/18]. Young workers under 18 are not employed at night or on hazardous work. If we ever found child labour, we would act in the child’s best interests, including support to stay in education.
• Fair wages are paid. Everyone is paid at least the National Minimum Wage or National Living Wage, on time, with a clear payslip. Deductions are never used as a punishment.
• Working hours are not excessive. We follow the Working Time Regulations 1998: an average maximum of 48 hours a week unless a worker chooses in writing to opt out, overtime that is voluntary, rest breaks, and at least one day off in every seven.
• No discrimination. See our Equality, Diversity & Dignity at Work Policy.
• Regular employment is provided. Everyone receives written terms from their first day. We do not use labour-only subcontracting, sham self-employment or repeated temporary contracts to avoid our obligations to workers.
• No harsh or inhumane treatment. Physical abuse, threats, intimidation and harassment are not tolerated, and discipline follows a fair, written procedure.

Health and safety

We provide a safe and healthy workplace, assess risks, train our people and consult them on safety. The details are in our Health & Safety Policy.

Environment

We meet our legal environmental obligations as a filling and packing site, including:

• Waste duty of care (Environmental Protection Act 1990): waste is stored securely, passed only to registered waste carriers, and waste transfer notes are kept for at least two years.
• The waste hierarchy (Waste (England and Wales) Regulations 2011): we separate cardboard, plastics and other materials for recycling where practicable.
• Hazardous waste, such as flammable fragrance or alcohol residues, is handled and consigned under the Hazardous Waste Regulations, with consignment records kept for at least three years.
• Preventing pollution: liquids are stored and handled so spills cannot reach drains, and spill kits are kept where liquids are used.
• Client materials: surplus free-issue product and components are returned to the client or disposed of as they instruct, and lawfully.

Business ethics

• We do not offer, pay or accept bribes. See our Anti-Bribery & Corruption Policy.
• Conflicts of interest are declared and managed.
• Client formulations, artwork, pricing and other confidential information are protected and used only for the client’s work.
• We compete fairly, keep accurate business records and protect personal data in line with our Privacy Policy.

Labour providers and suppliers

We expect the labour providers, contractors and suppliers we use to meet the same standards. Labour providers are vetted and checked under our Responsible Recruitment Policy, and we may ask to see evidence or carry out checks.

Raising concerns

Anyone can raise a concern about a breach of this policy, in confidence and without fear of retaliation, through our confidential reporting system, which is run independently by a third party. See our Whistleblowing & Grievance Policy.

Checking we meet it

We check our own practices [annually], [keep our Sedex self-assessment questionnaire up to date,] welcome client and third-party ethical audits such as SMETA, and act on any corrective actions within the agreed time.

Responsibility and review

This policy applies to everyone who works for or on behalf of LaunchPad Manufacturing: employees, agency and temporary workers, contractors and visitors. It is owned by [name, role] and has the full support of the directors.

We review it at least once a year, and sooner if the law or the way we work changes. Everyone it applies to is told about it at induction and when it changes.

Signed: [name], [director], LaunchPad Manufacturing. Date: [date].