A. Introduction

En Route International Limited and its global subsidiaries (collectively referred to as “ER”) are committed to the highest standards of business integrity and will engage only with suppliers who approach and manage their business in an ethical, social, responsible and environmentally friendly manner, and in line with all legal requirements stipulated in their host country. Where these are not clear, international standards must apply.

To ensure that our suppliers, vendors, contractors and others with whom we conduct business (collectively referred to as “Supplier” or “Suppliers”) are fully aligned to our core values of: Customer focus, Professionalism, Innovation and Responsibility, we have stipulated this En Route International Supplier Code of Conduct (the “Code”) which is a mandatory requirement and all Suppliers, their subcontractors and members of their supply chain are expected to comply with this Code.

ER will not knowingly engage with any Suppliers that operate poor labour practices and do not comply with the minimum standards set out in this Code.

This Code is informed by fundamental principles such as those in the UN Universal Declaration of Human Rights, the International Labour Organisation’s (ILO) Declaration on Fundamental Principles and Rights at Work and the UK Modern Slavery Act 2015.

The provisions of this Code constitute minimum and not maximum standards, and this Code should not be used to prevent Suppliers from exceeding these standards. Suppliers applying this Code are expected to comply with national and other applicable law and, where the provisions of law and this Code address the same subject, to apply that provision which affords the greater protection.

B. Workers’ and Human Rights

1. Employment is freely chosen
   1. There is no forced, bonded or trafficked labour or involuntary prison labour and no employee is held in slavery or servitude. Any kind of modern slavery is strictly prohibited.
   2. Employees are not required to lodge “deposits” or their identity papers with their employer and are free to leave their employer after reasonable notice.
2. Freedom of association and the right to collective bargaining are respected
   1. Employees, without distinction, have the right to join or form trade unions of their own choosing and to bargain collectively.
   2. The employer adopts an open attitude towards the activities of trade unions and their organisational activities.
   3. Employees representatives are not discriminated against and have access to carry out their representative functions in the workplace.
   4. Where the right to freedom of association and collective bargaining is restricted under law, the employer facilitates, and does not hinder, the development of parallel means for independent and free association and bargaining.
3. Working conditions are safe and hygienic
   1. A safe and hygienic working environment shall be provided, bearing in mind the prevailing knowledge of the industry and of any specific hazards. Adequate steps shall be taken 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.
   2. Employees shall receive regular and recorded health and safety training, and such training shall be repeated for new or reassigned employees.
   3. Access to clean toilet facilities and to potable water, and, if appropriate, sanitary facilities for food storage shall be provided.
   4. Accommodation, where provided, shall be clean, safe, and meet the basic needs of the employees.
   5. The employer observing the code shall assign responsibility for health and safety to a senior management representative.
4. Child labour shall not be used
   1. There shall be no recruitment of child labour.
   2. Employers shall develop or participate in and contribute to policies and programmes which provide for the transition of any child found to be performing child labour to enable her or him to attend and remain in quality education until no longer a child.
   3. Children and young persons under 18 shall not be employed at night or in hazardous conditions.
   4. These policies and procedures shall conform to the provisions of the relevant ILO standards.
5. Living wages are paid
   1. Wages and benefits paid for a standard working week meet, at a minimum, national legal standards or industry benchmark standards, whichever is higher. In any event wages should always be enough to meet basic needs and to provide some discretionary income.
   2. All employees shall be provided with written and understandable information about their employment conditions in respect to wages before they enter employment and about the particulars of their wages for the pay period concerned each time that they are paid.
   3. Deductions from wages as a disciplinary measure shall not be permitted nor shall any deductions from wages not provided for by national law be permitted without the expressed permission of the worker concerned. All disciplinary measures should be recorded.
6. Working hours are not excessive
   1. Working hours must comply with national laws, collective agreements, and the provisions of 6.2 to 6.6 below, whichever affords the greater protection for employees. Sub-clauses 6.2 to 6.6 are based on international labour standards.
   2. Working hours, excluding overtime, shall be defined by contract, and shall not exceed 48 hours per week. *
   3. All overtime shall be voluntary. Overtime shall be used responsibly, taking into account all the following: the extent, frequency and hours worked by individual employees and the workforce as a whole. It shall not be used to replace regular employment. Overtime shall always be compensated at a premium rate, which is recommended to be not less than 125% of the regular rate of pay.
   4. The total hours worked in any seven-day period shall not exceed 60 hours, except where covered by clause 6.5 below.
   5. Working hours may exceed 60 hours in any seven-day period only in exceptional circumstances where all of the following are met:
      – this is allowed by national law;
      – this is allowed by a collective agreement freely negotiated with an employees’ organisation representing a significant portion of the workforce;
      – appropriate safeguards are taken to protect the employees’ health and safety; and
      – the employer can demonstrate that exceptional circumstances apply such as unexpected production peaks, accidents or emergencies.
   6. Employees shall be provided with at least one day off in every seven day period or, where allowed by national law, two days off in every 14 day period.
      *International standards recommend the progressive reduction of normal hours of work, when appropriate, to 40 hours per week, without any reduction in employees’ wages as hours are reduced.
7. No discrimination is practised
   1. There is no discrimination in hiring, compensation, access to training, promotion, termination or retirement based on race, caste, national origin, religion, age, disability, gender, marital status, sexual orientation, union membership or political affiliation.
8. Regular employment is provided
   1. To every extent possible work performed must be on the basis of recognised employment relationship established through national law and practice.
   2. Obligations to employees under labour or social security laws and regulations arising from the regular employment relationship shall not be avoided through the use of labour-only contracting, sub-contracting, or home-working arrangements, or through apprenticeship schemes where there is no real intent to impart skills or provide regular employment, nor shall any such obligations be avoided through the excessive use of fixed-term contracts of employment.
9. No harsh or inhumane treatment is allowed
   1. Employees shall be treated with respect and dignity.
   2. Physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation shall be prohibited.
10. Migrants are employed legally
    1. Migrant workers must be employed in accordance with the applicable immigration and labour laws.
    2. Effective systems must be in place to verify the employee’s entitlement to work and the employee’s status in the relevant country of employment.
    3. Copies of documentation must be kept which verify that the migrant can be legally employed.

C. Anti-Bribery and Corruption Policy

1. No bribery or corruption will be tolerated
   1. The offering, paying, soliciting or accepting of bribes or kickbacks, including facilitation payments (which are small payments or fees requested by government officials to speed up or facilitate the performance of routine government action, such as the provision of a visa or customs clearance) is strictly prohibited.
   2. A bribe may involve giving or offering any form of gift, consideration, reward or advantage to someone in business or government in order to obtain or retain a commercial advantage or to induce or reward the recipient for acting improperly or where it would be improper for the recipient to accept the benefit.
   3. Bribery can also take place where the offer or giving of a bribe is made by or through a third party, e.g. an agent, representative or intermediary.
      Some examples of bribes are as follows. This is not an exhaustive list:
      – lavish gifts, meals, entertainment or travel expenses, particularly where they are disproportionate, frequent or provided in the context of ongoing business negotiations;
      – the uncompensated use of company services, facilities or property;
      – cash payments, loans, loan guarantees or other credit;
      – the provision of a benefit, such as an educational scholarship or healthcare, to a member of the family of a potential customer, public or government official;
      – providing a subcontract to a person connected to someone involved in awarding the main contract; and
      – engaging a local company owned by a member of the family of a potential customer, public or government official.
   4. Suppliers, their subcontractors, representatives and employees must comply with all applicable anti-bribery and corruption laws. If no such anti-bribery or corruption laws apply or are of a lesser standard to that prescribed in the UK Bribery Act 2010, Suppliers, their representatives and employees must adhere to the UK Bribery Act 2010.
   5. Suppliers shall have in place anti-corruption and bribery procedures designed to prevent subcontractors, representatives, employees or persons associated with their business from committing offences of bribery or corruption.
   6. Suppliers will properly implement these procedures into their business and review them regularly to ensure that they are operating effectively.

D. Environmental Protection

1. Reduce environmental impact and provide sustainably sourced products
   1. Suppliers shall comply with all applicable current and future environmental laws, regulations and standards including compliance with industry best practice standards for the sourcing and manufacturing of products and materials.
   2. Suppliers shall reduce negative environmental impacts by using environmental friendly technologies and practices, also throughout their supply chains.
   3. ER strongly encourages Suppliers to develop a sustainable environmental policy or maintain and improve their existing sustainable environmental policies, which aim at reducing waste, water and energy, minimising the environmental impact of their operations and providing sustainably sourced and manufactured products.
   4. Suppliers shall provide ER with details of their environmental policies.

E. Implementation

1. Suppliers shall take all necessary steps to ensure that their employees, sub-contractors and members of their own supply chains comply with this Code to the extent applicable.
2. Suppliers shall establish processes or mechanisms where employees can raise issues of concern without fear of reprisals or negative repercussions.
3. ER reserves the right, upon reasonable notice, to carry out the controls that it deems necessary to ensure Suppliers’ compliance with this Code. These may be self-assessments, ER audits and third-party audits of Suppliers. Suppliers herewith expressly grant ER such right.
4. This Code might be updated from time to time.

F. Violation of the Code

1. This Supplier Code of Conduct is a mandatory requirement and all Suppliers are expected to adhere to these, with the ability to demonstrate compliance.
2. ER is committed to supporting Suppliers in this respect to meet the requirements and to explore solutions if a Suppliers sees problems to fully adhere to this Code.
3. However, failure to comply with this Code or with applicable laws and regulations is considered a material breach of contract by the Supplier and shall entitle ER to terminate any agreement with the Supplier.