Ethical Trading and Environment Policy

Last Updated: March 2026

Policy Statement

Deserve believes in the principles of ethical trading and the importance of a transparent approach to provide a constantly improving working environment throughout the supply chain. The Ethical Trading Policy is based upon internationally recognised standards including the Ethical Trading Initiative (ETI) Base Code, the United Nations Universal Declaration on Human Rights (UDHR) and subsequent International Labour Organisation (ILO) conventions, and the United Nations Sustainable Development Goals (SDGs)

The policy sets out the standards expected of all suppliers and manufacturing sites in Deserve’s supply chain including all organisations that manufacture or procure products or services for Deserve, including outsourced processes, Goods Not for Resale (GNFR) suppliers, service providers, labour providers and homeworkers. This includes products that are wholly or partly owned, directly or indirectly, including Deserve branded and, where applicable, third-party/wholesale products. 

Deserve will use this policy as a tool to assist us in selecting and retaining business partners who follow business practices that are consistent with our policies and values. This policy will also help our partners to identify potential problems in their business and supply chains and, in the event issues are identified, Deserve will work collaboratively to address these. The policies constitute minimum and not maximum standards, and the requirements should not be used to prevent suppliers from exceeding these standards. Companies applying this policy are expected to comply with national and other applicable law and, where the provisions of law and policy requirements address the same subject, to apply the provision which affords the greater protection.

The following policies are included within the scope of the following Ethical Trading Policy:

  • Code of Conduct

  • Unapproved Subcontracting Policy

  • Child Labour, Remediation and Young Worker Policy

  • Homeworking Policy

  • Forced Labour and Modern Slavery Policy

  • Cotton Sourcing Policy

  • Sandblasting Policy

  • Animal Welfare Policy


Deserve’s CSR team can be contacted with any queries, concerns or updates by emailing steve@deserveclothing.com


Statement of Requirements

Supplier Expectations

  • Ensure all areas of the business operations and wider supply chain are compliant with national and local laws and keep up to date on all legal and industry standards. 

  • Ensure compliance with the Ethical Trading Policy and Code of Conduct, the ETI Base Code and accepted industry standards, deferring to whichever afford the workers the greater protection. The ETI Base Code should be displayed prominently for workers in a language they can understand. 

  • Communicate the Ethical Trading Policy to all stakeholders and all tiers of the supply chain where Deserve products are made, including but not limited to suppliers of raw materials, subcontractors and labour providers, and establish management systems to ensure the requirements are embedded into business practices. Where appropriate, suppliers should consider providing training for managers and workers in the supply chain to implement the requirements.

  • Work to achieve the parameters of the additional policies included within the scope of the Ethical Trading Policy, such as the Unapproved Subcontracting, Homeworking and Animal Welfare Policy.

  • Seek to continually improve the sustainable and ethical performance of your supply chain and establish a risk management process to identify the environmental, health, safety, and ethical risks associated with operational and labour practices.

  • Work with Deserve to develop an action plan for improving labour conditions throughout the supply chain where these are found to be below those set out in international labour standards and Deserve’s Code of Conduct. Maintain a complete and up to date Manufacturing Portfolio and update Deserve when any site locations, contacts or usage changes occur to allow full transparency of all manufacturing sites where product assembly and any additional outsourced processes (such as laundry, embroidery, printing etc) takes place, including declaration of any subcontracting and homework. If you intend on using any new manufacturing sites, these must be declared (using the Factory Set Up Form) and approved by Deserve prior to any production taking place. 

  • If required, allow access to all Deserve personnel, their appointed representatives and any third-party auditors to manufacturing site(s), and provide documents when requested. This included visits that are unannounced. 

  • Ensure that factory audits meet the following requirements:

    • Audited to one of the following standards: SMETA, BSCI or Fast Forward (UK)

    • Audited by a recognised body e.g. SGS, BV, Qima, The Reassurance Network, TUV

    • Conducted within the last 24 months and unannounced (or at a minimum, a semi-announced audit within a 4-week window)

  • Inform Deserve immediately if any critical risks are identified in any part of the supply chain (see Critical Risks, Concerns and Zero Tolerance Indicators) and collaborate on corrective actions and engage with any third parties nominated by Deserve if required.

  • Communicate progress on non-compliances that have been remedied through corrective actions, and provide details and request support where needed. 


Commitments from Deserve

  • Communicate clear standards and requirements of suppliers.

  • Inform and discuss any changes with our suppliers and agree feasible timeframes for implementation.

  • Consider our purchasing practices and implement improvement actions where the need for improvement is identified.

  • Approach matters of ethical trading as a constant improvement programme, focusing on supplier interactions to support suppliers to grow and improve efficiency and sustainability in the business relationship.

  • Provide suppliers and manufacturers with access to points of contact within Deserve to allow them to raise concerns or queries. Deserve’s CSR team can be contacted any time by emailing steve@deserveclothing.com

  • Demonstrate loyalty to suppliers who are open and transparent about business practices and who are themselves committed to improve. Deserve will provide support and guidance where this is requested by a supplier/manufacturer.

  • Keep all commercially sensitive information confidential, except where disclosure is required under legal obligations.

  • Only disengage with suppliers due to a breach of this policy as an absolute last resort, where suppliers have been offered a path for remediation and continually decided against this route or have not been cooperative.


 

Code of Conduct


Deserve’s Code of Conduct is based on the ETI Base Code and United Nations Guiding Principles on Business and Human Rights, and represents the minimum standards expected of all elements of the Deserve supply chain. The full Code of Conduct can be found below and the ETI Base Code can be found via the following link and translated into several languages to allow distribution throughout your supply chain.

ETI Base Code: http://www.ethicaltrade.org/resources/eti-base-code

Within each area of the Code of Conduct, the establishment of management systems to demonstrate that labour rights and ethical trading are embedded into business practices is key to ongoing success and improvement.


  1. Employment is freely chosen 


  1. There is no forced, bonded or involuntary prison labour (including state-imposed forced labour).  

  2. Workers are not required to lodge “deposits” or their identity papers with their employer and are free to leave their employer after reasonable notice. 

  3. Workers are not expected to pay any fees in regard to their recruitment - where finders fees are paid these must be viewed as a business expense to be covered by the employer. Workers must not be bonded through loans or fees they have paid to obtain work.

  4. There must be no restriction on workers ability to leave the worksite or accommodation.

  5. All migrant workers must have a legal right to work in the destination country. Workers in the UK must be covered by thorough documentation and Right to Work Checks (in the UK this should take the form of establishment of a 3-step excuse and completion of the Home Office Right to Work Checklist prior to commencement of employment).



  1. Freedom of association and the right to collective bargaining are respected 


  1. Workers, 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. Workers’ 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.  Wherever possible under local law, this should include freely elected worker representatives and includes making adequate facilities and time available.

  5. All workers to be afforded independent access to remedy. Sites in the UK must display details of the ACAS helpline.

 

  1. 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. As a minimum this should include:

    1. Company/Site Health and Safety Policy, detailing roles and responsibilities for all on site.

    2. Full risk assessments for all processes on site, any risk of harm from hazardous substances / activities is minimised through the provision of safety equipment, signage, training and a safe factory infrastructure.  

    3. Machinery (including but not limited to; production machinery, electrical and gas installations and lifting/handling machinery) subject to routine internal safety inspections and at least annual services.  Fixed guards and isolations switches must be provided where machinery presents a hazard.

    4. PPE is made available without charge to any employee where there is a risk to their health and safety that cannot be controlled by an alternative method.

    5. The working atmosphere to have adequate lighting, temperature control, noise monitoring and air quality levels.

    6. Specific risk assessments for pregnant or nursing women, to include job suitability assessments and reassignment details where this is deemed necessary.

    7. Documented chemical safety policy including a list of all chemicals on site. In the UK, COSHH risk assessments are required and across all territories the MSDS for each chemical should be available to workers.

    8. Workers health should be safeguarded with the provision of adequate access to first aid and medical facilities.

    9. Emergency responses and plans must be in place, with assessments of relevant risk conducted (such as Fire/Explosion/Severe Weather Risk Assessments). Sufficient emergency exits must always be available and fire-fighting, and detection equipment in place. Documented emergency drills/simulations should be conducted on regular basis. 

  2. Workers shall receive regular and recorded health and safety training, and such training shall be repeated for new or reassigned workers. 

  3. Access to clean toilet facilities and to potable water, and, if appropriate, sanitary facilities for food storage shall be provided. 

  4. Local and/or national laws and regulations related to public health must be adhered to, for example natural disasters and pandemics, and workers must be protected in this regard. Where appropriate, risk assessments must be conducted and communicated to workers with any relevant emergency procedures.

  5. Accommodation and transport, where provided, shall be clean, safe, secure and meet the basic needs of the workers, with standards and emergency equipment meeting the at least the minimum standards detailed under 3.1. Dormitories should be separated from the workplace and should always have a separate entrance with evacuation plan and adequate firefighting equipment with free access.

  6. The company observing the code shall assign responsibility for health and safety to a senior management representative with an effective reporting mechanism for workers to voice concerns on Health and Safety issues. Documented methods must be in place for these to be investigated and recorded, usually by way of a Health and Safety Committee

  7. All mandatory insurance is in place - in the UK this will include Employers Liability Insurance.

  8. Building safety inspections, certificates and approved layout plans required under local and national law must be in place. If not required by law, plans must be approved by an independent certified structural engineering body. 


  1. Child labour shall not be used* 


  1. There shall be no new recruitment of child labour. 

  2. Companies 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; “child” and “child labour” being defined in the appendices. 

  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. 

*refer to the Child Labour, Remediation and Young Worker Policy 


  1. 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. Wage levels must comply with any collective bargaining agreements that may be in place. In any event wages should always be enough to meet basic needs and to provide some discretionary income. 

  2. All workers 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. This includes hours worked, hourly wages, piece rate wages if applicable, gross pay, overtime pay ,any itemised deduction and net pay.

  3. Deductions from wages as a disciplinary measure shall not be permitted and 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.

  4. Workers must be provided with all statutory benefits to which they are entitled under national or local law e.g. paid leave, paid parental leave, sick pay.

  5. Statutory deductions which entitle workers to state benefits must be made and passed on by the employer to the state.

  6. Where workers are paid according to output (piece work), their wage must still meet the legal minimum wage standard. A formal, agreed piece rate calculation must be in place which ensures that workers are paid fairly and are able to meet the legal minimum wage standard, or above, within normal working hours.

  7. All wage payments must be made in a traceable manner. In UK sites, the required method is by BACs payment into the workers own bank account.

  8. There should be no deductions from wages for any clothing and protective equipment required to perform work safely. This must be paid in full by the employer.


  1. 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 workers. Sub-clauses 6.2 to 6.6 are based on international labour standards. 

  2. Working hours, excluding overtime, shall be defined by contract (including all scheduled breaktimes and relevant details of pay), 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 workers 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: 

  1. This is allowed by national law; 

  2. This is allowed by a collective agreement freely negotiated with a workers’ organisation representing a significant portion of the workforce; 

  3. Appropriate safeguards are taken to protect the workers’ health and safety; and 

  4. The employer can demonstrate that exceptional circumstances apply such as unexpected production peaks, accidents or emergencies. 

  1. Workers 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. 

  2. There must be robust method in place for the recording of working hours.  In the UK this needs to be either by punch card clocking machines or biometric time record systems, hand written working hours are not acceptable. 

  3. Where workers hours of work are restricted under law (in the case of young workers or those workers who have time restrictions associated with their visa) the employer must have a proactive time management/rota system in place to ensure that the maximum allowed working house are not exceeded.

  4. Clearly communicate details on the site overtime policy to workers through contracts/employee handbooks.  Policy to cover at minimum:

    1. Overtime rates of pay

    2. Voluntary nature of overtime, and that there will be no penalties for refusal.  Where transport is provided this should be available at the end of the standard shift as well as the overtime shift.

    3. Notice that will be provided to workers when overtime is on offer, usually no less than 24 hours.

    4. Details of any relevant collective bargaining agreement, if one is in place.

    5. Commitment that payment of overtime will be made alongside regular salary payments for the same period of work.

    6. Details of grievance mechanism to report concerns over overtime including workers right to refusal and any unsafe situations caused by additional working hours.

* International standards recommend the progressive reduction of normal hours of work, when appropriate, to 40 hours per week, without any reduction in workers’ wages as hours are reduced. 


  1. 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, familial circumstances, sexual orientation, union membership or political affiliation. 

  2. Suppliers must clearly communicate to all workers and management details of the discrimination policy and outline reporting mechanisms for any grievances to be raised under this policy, maintaining records of any concerns that may be raised.

  3. Employers must maintain up-to-date records on recruitment, training and promotion.


  1. Regular employment is provided 


  1. To every extent possible work performed must be on the basis of a 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. 

  3. Workers are not to be employed on ‘zero hours’ contracts.

  4. Workers receive written terms of employment and contracts signed in advance of employment commencing, in a language which they understand. Both the worker and employer must retain a signed copy of the contract. 

  5. Full details on additional policies and procedures should be available to workers through employee handbooks which are available for them to take away and guidance provided on worker notice boards all in a language understood by the workers.


  1. No harsh or inhumane treatment is allowed 


  1. Physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation shall be prohibited.  

  2. Employers must follow a published disciplinary procedure, with details available to all workers in a language they understand.


  1. Labour Providers


  1. Labour providers should only supply workers registered with them.

  2. Relationships with labour providers should be covered by a Service Level Agreement which meets all national legal requirements.

  3. Labour providers should be audited on a regular basis to ensure compliance with all local and national legal requirements.

  4. A clear written agreement should be provided with labour providers to ensure that worker welfare is safeguarded, including but not limited to their health and safety, payment and benefits, accommodation and non-discrimination. 

  5. Labour providers should check that adequate health and safety training is given to workers prior to commencement of employment, and provide training if the employer does not do so. Labour providers should not charge workers for finding them a job or for services that are integral to the work finding process.

  6. If a recruitment agent is used, then there should be a written agreement with the agent that fully explains the hiring practice.

  7. Recruitment agents should provide suppliers to provide written details of all their labour sources and provide evidence of due diligence.

  8. Commercial contracts with recruitment agencies/Labour Providers must include adequate clauses covering a zero-tolerance approach to exploitation, forced or compulsory labour and underpayment of minimum wage and statutory payments (such as holiday pay and sickness pay).


  1. Business Practice


  1. Allow access to all Deserve personnel, their appointed representatives and any third-party auditors to the site, including on an unannounced basis and ensure any documents requested are provided accurately, in full and in a timely fashion.

  2. Maintenance of records (personnel, pay, working hours) for no less than 3 years.

  3. Not assign any kind manufacturing work to any third parties without written approval from Deserve.


  1. Integrity 


  1. The offering, paying, soliciting or accepting of bribes or kick-backs, including facilitation payments, is strictly prohibited. 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. 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:

  • Gifts or travel expenses;

  • 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 sub-contract 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.

  1. Facilitation payments 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). Such payments are strictly prohibited.

  2. Suppliers, representatives and their 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, representatives and their employees must adhere to the UK Bribery Act 2010.

  3. Suppliers and representatives must have in place anti-corruption and bribery procedures to prevent employees or persons associated with its business from committing offences of bribery or corruption. Suppliers and representatives will properly implement these procedures into their business and review them regularly to ensure that they are operating effectively.



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

Definitions:


  • Child: any person less than 15 years of age unless local minimum age law stipulates a higher age for work or mandatory schooling, in which case the higher age shall apply.  If however, local minimum age law is set at 14 years of age in accordance with developing country exceptions under ILO Convention No. 138, the lower will apply.

  • Young Person: any worker over the age of a child as defined above and under the age of 18.

  • Child Labour: any work by a child or young person younger than the age(s) specified in the above definitions, which does not comply with the provisions of the relevant ILO standards, and any work that is likely to be hazardous or to interfere with the child’s or young person’s education, or to be harmful to the child’s or young person’s health or physical, mental, spiritual, moral or social development.

  • Forced Labour: any work or services which people are not doing voluntarily and which is exacted under a threat of some form of punishment, including the loss of rights or privileges.

  • Bonded Labour: labour which is demanded as a means of repayment of a debt or a loan and can apply to a whole family and be inherited through generations.

  • Involuntary Prison Labour: includes situations where prisoners are required to work for the benefit of a private company or an individual.  



Critical Risks, Concerns and Zero Tolerance Indicators


Within the Code of Conduct outlined above, there are certain instances and zero tolerance indicators that will highlight a supplier as a critical risk. Where critical risks are identified, the details will be escalated to Executive level at Deserve and they will remain appraised of the progress against the agreed remediation plan – in some cases unannounced spot checks may be necessary. In the most extreme circumstance, and where there has been a refusal of the supplier/site to cooperate and engage in remediation, then termination of the trading relationship would be actioned. If this is the case the supplier would be notified in writing and provided with detailed reasoning. The below details what would be considered as critical concerns, however please note that the list is not exhaustive but to provide indication only.

  • Concealed instances of child labour with no remediation

  • Concealed instances of forced or bonded labour

  • Refusal of site disclosure

  • Refusal of site access, or failure to present required documentation

  • Incidents of threatening, intimidating behaviour or violence to Deserve personnel, their appointed representatives or any third-party auditors

  • Any breach of the Deserve anti-bribery and corruption policy

  • Health and Safety breaches potentially resulting in critical/fatal illness/injury

  • Denial to the right of collective bargaining

  • Evidence of harsh or inhumane treatment

  • Systemic discrimination in recruitment and in the workplace

  • Employment of those who have no legal right to work in accordance with national immigration law 

  • Failure to comply with local and national legal requirements

  • Exposure of the Deserve brand to any disrepute

  • Refusing or deliberate non-transparency during audits conducted by Deserve or any other third-party.

Unapproved Subcontracting Policy


Monitoring our supply chain is essential to ensure that working conditions across sites manufacturing for Deserve meet our Ethical Code of Conduct. An important aspect of being able to do this is having confidence in the supply chain information provided by our suppliers. Unapproved subcontracting puts workers at increased risk of exploitation as we cannot monitor conditions at unapproved sites.

While we recognise the complexity of fashion supply chains and the need for approved subcontracting, we expect all suppliers to guarantee that Deserve products are only manufactured in sites that have been declared and approved by Deserve. For the purposes of this policy, manufacturing sites include any subcontractor involved in the production (e.g. CMT, knitting) and processing (e.g. printing, embroidery, laundry, packaging) of Deserve products. 

This policy sets out the consequence to suppliers where unapproved subcontracting is found in Deserve’s supply chain. As an Deserve supplier, it is your responsibility to have full visibility, oversight and to keep detailed records relating to every site involved in the manufacture of Deserve products. It is also the supplier’s responsibility to ensure that all manufacturing sites involved in the manufacture of Deserve products are aware of and uphold the Deserve Ethical Code of Conduct. 

All manufacturing sites must be declared to and approved by Deserve before any production and/or manufacture of Deserve products takes place. If manufacturing sites are not declared and approved by Deserve this will be considered to be “Unapproved Subcontracting”. Any supplier found to have unapproved subcontracting within their Deserve supply chain will face the following consequences:

1st finding of unapproved subcontracting:

  • A deduction of £5,000* to be immediately debited against your Deserve supplier account

2nd finding of unapproved subcontracting:

  • A deduction of £10,000 to be immediately debited against your Deserve supplier account

Deserve will also be entitled to:

  • Conduct an immediate ethical assessment at the unapproved site at the Suppliers’ cost, resulting in a

  • worker remediation and corrective action plan

  • Suspend all orders until ethical issues are resolved and trust in the management of the supply chain is

  • regained

  • Insist all goods (finished or unfinished) are moved to an approved site at the Suppliers’ cost

  • Cancel orders; and/or

  • Review the business relationship

Suppliers are actively encouraged to be transparent about any actual or potential unapproved subcontracting in their supply chain. Proactively alerting Deserve to risks or instances of unapproved subcontracting will be viewed favourably, including in the application of monetary deductions. If suppliers have concerns about their ability to produce Deserve’s product in approved sites due to Deserve buying practices, capacity or forecasting issues, labour shortages or any other reason, they are encouraged to communicate these to Deserve Retail or Corporate Social Responsibility teams. Deserve will seek to support suppliers in managing these concerns.

*Unapproved subcontracting deductions will be used or donated by Deserve to support ethical supply chain initiatives or charitable causes.




Child Labour, Remediation and Young Worker Policy


Deserve expects our suppliers to monitor and manage their supply chains to ensure that children are not involved in the manufacture and/or supply of products to Deserve. If children are active in the workplace, they are being denied the access to education, their rights to childhood and their physical and mental health and general wellbeing are at risk.

The policy below details the actions to be taken to verify age prior to employment to avoid any instances of child labour and it is the suppliers’ responsibility to implement and communicate this to all levels of their supply chain. A remediation plan is also laid out in the event that child labour is detected. 


Young Worker and Age Verification Policy 

Young workers are defined as workers between the minimum working age (which is stipulated by local law as per the ILO’s Minimum Age Convention, 1973 (No. 138)) and 18. Young workers can be employed, although there are precautions that need to be in place to ensure that they are afforded adequate protection:

  • Young workers cannot be employed at night

  • Young workers cannot work overtime

  • Young workers cannot carry out any form of potentially hazardous or physically demanding work.

  • Young workers must be provided any health checks as required by law

  • Young workers must be registered with any local labour departments as required.

  • Young worker’s employment contracts must be counter signed by their parents.

Deserve is supportive of any programmes in place to help develop the skills of young workers, but any young workers on such a programme must receive at least minimum wage.

In addition to the stipulations in the Deserve Code of Conduct, the below has been laid out to provide guidance on the minimum requirements to ensure that this is managed effectively, all suppliers are expected to fully implement as follows:

  • There must be an effective procedure in place to verify the ages of all workers prior to employment. Evidence to verify every worker’s date of birth must be kept on file, and if records are not available to verify the date of birth then a suitable and reliable method must be used and relevant documentation maintained.

  • Ensure that this policy is communicated to and agreed by all labour providers.

  • Ensure that all employment vacancy advertisements and postings clearly define the minimum age requirements

  • Post minimum working age policy on the factory/site exterior.

  • Where young workers are employed, all local requirements must be followed and specific risk assessments must be carried out to identify any specific hazards.


For complete clarity on Deserve’s position on child labour, and to avoid any confusion: No children are to be allowed in production areas under any circumstances.







Remediation

In the event that you currently have, or discover any person under the age of 16 in your supply chain, you must inform Deserve immediately.  Deserve will not terminate the trading relationship based on a report of child labour alone. Support will be offered to any supplier through the below process of remediation and provided all steps are followed, no sanctions will be imposed. The best interests of the child are to be held above all else. The below actions must be taken:

  • To mitigate the risk to the child, immediately remove the child from the production area, or if working from home, stop the work. 

  • Make immediate contact with a member of Deserve’s CSR or Sourcing team.

Deserve will work alongside the supplier to work out a personalised plan for the remediation of the child. Whilst that plan is being developed, the child should not be formally dismissed, and wages must continue to be paid. The child must not be present at the site of work during this period. In the event that the child detected is a migrant, safe accommodation should be provided that is suitable for the needs and circumstances of the child in the context of their age and gender. For children who are away from home or have migrated for work with or without their families, the best interim solution may be for the child to remain in his or her current dwelling or continue to lodge in the factory dormitory whilst the remediation plan is developed.

Alongside the supplier and any appropriate local organisations, Deserve will draft a plan that ensures that the child is returned to education until the national minimum working age or mandatory schooling age (whichever is longest is reached), without being financially disadvantaged. This would include but not limited to:

  • Making contact with the child’s family wherever possible to ascertain the circumstances prompting the need for the child to work.

  • Providing for the immediate welfare of the child.

  • Ensuring that the child continues to receive their salary until they reach legal working age.

  • Make sure that the child completes compulsory schooling. If the child has already completed compulsory schooling, then vocational training is to be arranged as an alternative.

In the event that the child detected is a migrant, safe accommodation should be provided that is suitable for the needs and circumstances of the child in the context of their age and gender. If you have any concerns or questions regarding child labour, please contact Deserve’s CSR team.


Homeworking Policy


Homeworking is a valuable and at times essential part of the supply chain, providing specialist components and flexibility in reaction to production demands. In addition, the opportunity to work off site can offer advantages to the workers, particularly women, enabling paid work to be balanced with domestic and family responsibilities. However, homeworkers can be among the most vulnerable and marginalised workers in any supply chain. Deserve believes that one of the first steps towards reducing the vulnerability of these workers is to take an open and positive position towards homeworking. 

The below is based upon R184 - Home Work Recommendation, 1996 (No. 184) of the ILO framework and is intended as additional guidance to assist suppliers in ensuring compliance to the Deserve Code of Conduct in regard to any homeworkers in their supply chain.


Deserve’s Position

Deserve will work with suppliers for the sustainable improvement of labour conditions with homeworkers in the supply chain and is committed to ensuring that the presence of homeworkers will not lead to relocation of work or cancellations of orders.  Where homeworkers are employed in the production of Deserve goods, suppliers must have accurate mapping of the contractors used and declare this to Deserve. Deserve’s Ethical Trading Policy applies to homeworkers and suppliers are responsible for monitoring that the employment of contractors meets the standards set out in this policy and Code of Conduct, and that homeworkers’ entitlements are understood.

Wherever possible, arrangements should be made for homeworkers to be brought inside the factory. Homeworkers must be given a clear agreement through employment contracts, and where workers are paid according to output, manufacturers must agree prices with contractors based on a clear and documented work time study which include sufficient provision for workers to be paid at least the legal minimum wage. The manufacturer or the contractor should see that the homeworkers are paid promptly and given an itemised pay slip indicating the piece rate of pay and the amount, cause, and nature of deductions. All documentation on contractors, code agreements, workers location and costing models should be available for review upon request.



Defining Homework

The definition of homework is based upon the ILO definition (1996, C177, Article 1) which states: 

  1. The term homework means work carried out by a person, to be referred to as a homeworker

  1. In his or her home or in other premises of his or her choice, other than the workplace of the employer;

  2. For remuneration.

  3. Which results in a product or service as specified by the employer, irrespective of who provides the equipment, materials or other inputs used, unless this person has the degree of autonomy and of economic independence necessary to be considered an independent worker under national laws, regulations or court decisions

  1. Persons with employee status do not become homeworkers within the meaning of this Convention simply by occasionally performing their work as employees at home, rather than at their usual workplaces;

  2. The term employer means a person, natural or legal, who, either directly or through an intermediary, whether or not intermediaries are provided for in national legislation, gives out homework in pursuance of his or her business activity.


Forced Labour and Modern Slavery Policy


Modern slavery is an overarching term used to describe its various forms:

  • Human trafficking is a process of bringing a person into a situation of exploitation through a series of actions, including deceptive recruitment and coercion.

  • Forced labour is any work or services which people are not doing voluntarily and which is exacted under a threat of some form of punishment.

  • Bonded labour is demanded as a means of repayment of a debt or a loan.

  • Slavery is a situation where a person exercises (perceived) power of ownership over another person.

Modern slavery lies at the extreme edge of a continuum in which respect for workers’ rights and their ability to claim their rights lie at the opposite end. It is found at many workplaces – on farms, in factories, private homes and in ancillary services. 

Deserve does not tolerate any form of forced labour, human trafficking, bonded labour or slavery – including prison and state-imposed forced labour, or any use of force or other forms of coercion, fraud, deception, abuse of power or other means to achieve control over another person for the purpose of exploitation.

The ILO has identified eleven potential indicators of circumstances in which forced labour is found, these are:

  1. Abuse of vulnerability

  2. Deception

  3. Restriction of movement

  4. Isolation

  5. Physical and sexual violence

  6. Intimidation and threats

  7. Retention of identity documents

  8. Withholding of wages

  9. Debt bondage

  10. Abusive working and living conditions

  11. Excessive overtime


More information on the ILO indicators can be found here: https://www.ilo.org/global/topics/forced-labour/publications/WCMS_203832/lang--en/index.htm

More information on the UK Modern Slavery Act 2015 can be found here: https://www.legislation.gov.uk/ukpga/2015/30/contents/enacted



Supplier Expectations

  • Ensure compliance with all local, regional, and international laws and regulations on labour protection and modern slavery (including but not limited to the UK Modern Slavery Act 2015) in sourcing countries and/or any other countries where business operations take place. Where there is a conflict between Deserve requirements, local laws, and/or international standards, the principle that provides the highest protection to workers should apply.

  • Establish management systems to ensure compliance with the policy and lay out the responsibilities for tackling forced labour throughout the supply base.

  • Have knowledge of supply base and identify where there are instances of the ILO forced labour indicators. Where these are uncovered and breaches are identified, seek to remediate where possible rather than disengage and alert Deserve to allow a collaborative investigation.

  • Ensure the supply base and associated labour providers are aware that workers must not pay in order to gain employment.  

  • Ensure all workers in the supply chain and service provider sites are appraised of their rights and provided with independent access to remedy. This must be in languages the workers understand and offered without fear of reprisal.

  • Ensure workers are always paid in full and on time.

  • If labour providers are used within the supply chain, conduct due diligence and identify where and how workers are recruited.

  • Have a clearly documented recruitment process and ensure this is in place at the factories you are using. When communicating terms to workers, this must be done in a language they can understand and records of job offer letters, worker addresses and verification of payment methods (i.e. to verify that where bank details are provided, they belong to individual workers) and worker inductions must be kept. 

Response to Indicators

Suppliers must not conceal any cases where indicators of modern slavery and forced or bonded labour are found. Suppliers are expected to report the issues at the earliest possible stage to Deserve who will support in investigation and any necessary remediation which will include as a minimum:

  • Identifying who has engaged the worker(s) and how this was done.

  • Research what local NGOs, community organisations may be able to support and aid with the investigation.

  • Seek to learn the needs and wishes of the worker(s) involved.

  • Work to protect the worker(s) from any further harm such as prosecutions, deportation or retaliation.

  • Identify underlying cause and assess suppliers’ and Deserve’s own business practices for any potential impact.

  • Support worker(s) affected as far as possible in securing alternative jobs or income.

If instances have been found to be concealed, or the required remedial action is not undertaken, Deserve will review the severity alongside the future of the trading relationship.


Cotton Sourcing Policy


There are well documented reports of widespread and systematic use of forced and child labour in the harvest of cotton in Uzbekistan, Turkmenistan and Syria, and more recently in the Xinjiang province of China. 

Despite effort of industry organisations, NGOs and socially responsible investors to eliminate this practise there has been little progress. As such, Deserve is standing alongside other international brands in banning the use of cotton from these regions in the products it sells.  

The accurate tracing of the sourcing of raw materials, especially cotton, is extremely difficult and as such the request is for suppliers to ensure that they are not knowingly sourcing cotton from these regions by making contact with their own fabric and yarn suppliers to identify the country of origin of the cotton to ensure that is does not contravene this policy. Supporting records should be maintained.  

In the event that cotton from these regions is detected in the supply chain, suppliers must inform Deserve immediately. 

This policy will remain our position until such time that there is independent evidence of a change in the cotton industry in either of the countries listed above. 

With regards to Uzbekistan, Deserve welcomes the ILO Report of the Cotton Harvest in Uzbekistan which concludes that forced and child labour have been eradicated from Uzbek cotton. We will continue to monitor the situation and review cotton sourcing from this region on a case-by-case basis. Suppliers wishing to source cotton from Uzbekistan should contact csr@inthestyle.com in the first instance. As a minimum, any cotton sourced from this region must be from certified, more sustainable sources, such as Better Cotton (BCI), Global Organic Textile Standard (GOTS) or Organic Content Standard (OCS) certified.

The 2021 ILO Third Party Monitoring Report of the Cotton Harvest in Uzbekistan can be viewed here: https://www.ilo.org/wcmsp5/groups/public/---dgreports/---ilo-washington/documents/projectdocumentation/wcms_767756.pdf


Sandblasting Policy 


Sandblasting is a technique used to give denim a worn, faded and bleached appearance. It is performed by using air compressors to blast crystalline silica (found in sand) on to the product to create the desired effect.

As a process, sandblasting is extremely hazardous to workers health and can cause silicosis, lung cancer and autoimmune diseases.

Due to the risks associated with this process, sandblasting and other processes that involve silica must not be used on any Deserve products, or in any manufacturing sites associated with the Deserve supply chain.

Alternative methods such as abrasive rubbing or chemical spraying can be used to achieve the same effect. Any use of chemicals must be compliant with Health and Safety requirements, with appropriate PPE provided. Deserve will only approve factories for production that have dismantled the sandblasting equipment, thereby eliminating the risk that the equipment may be used for other customers despite this requirement.

Within the Deserve Ethical Trading Policy, suppliers are request to declare all locations of sites where any additional processes such as laundering or artificial ageing of garments takes place (whether in a primary or secondary production site). Suppliers of artificially aged/worn product will be requested to provide details of the methods used on site.



Animal Welfare Policy


Deserve endorses that no animal should suffer in the name of fashion or beauty and suppliers are responsible for ensuring animal welfare is upheld; good animal welfare is only possible when there is transparency across the supply chain and an understanding of where animal products have come from. Where animal products are used, suppliers will be asked to provide evidence of good animal husbandry, such as a farm level audit or appropriate certification, to ensure animal welfare is maintained throughout the supply chain. 

Deserve supports the Five Domains framework and as a minimum expects suppliers to adhere to this. The Five Domains framework, which has evolved from the Five Freedoms, is a science-based structure for assessing animal welfare which recognises that animals can experience feelings. The Five Domains are: 

  • Nutrition: access to fresh water and a balanced diet to maintain full health

  • Environment: appropriate physical environment, including shelter, noise and temperature regulation and a comfortable resting area

  • Health: good fitness levels and measures to prevent disease or injury, and rapid and stress-free treatment 

  • Behaviour: adequate space, facilities, company of their own kind and opportunities to make their own decisions

  • Mental State: eliminate or reduce negative emotional experiences and provide comfort with positive emotional experiences

Any materials of animal origin used on Deserve branded product (where these are permitted for use) must be a by-product of the meat and food industry. All suppliers are expected to conduct their operations in a responsible manner, and to fully abide by this policy.


Animal Fur

The use of any fur in any product, including product trim, supplied to Deserve (regardless of the branding the article carries) is strictly prohibited. This includes Karakul lambskin from new-born or aborted lambs. Fur means any animal skin or part thereof with hair or fur fibres attached thereto, either in its raw or processed state or the pelt of any animal killed for the animal’s fur, as per the Fur Free Retailer definition. 

Suppliers must ensure that any fur used in Deserve product is faux; suppliers should be able to verify internally if the materials used are faux by:

  • Examining the backing of the faux “fur”, this should be made of a woven or knitted material (whereas genuine fur usually protrudes from the skin). On some faux samples the pile can be pulled aside to view the backing.

  • Using a pin pressed against the backing -  it will pass through easily on faux “fur”.

  • Looking at the ends of the “fur” fibres.  Where these are tapered at the end and not cut straight, the specimen is more likely to be genuine fur.

  • Rolling the “fur” fibres between your finger and thumb – genuine fur feels smooth and soft, whereas faux generally feels coarse in comparison.

  • Burning the pile. If the pile produces a smell like burning hair, this is indicative of genuine fur.

Deserve may ask for evidence that the material in use is not of animal origin. In this case a Fibre Composition Test from a UKAS accredited Laboratory would normally suffice.




Leather and Skin

Deserve only accepts the use of leather and hide from cow, buffalo, pig, goat and sheep, with the exception of Karakul lamb which is strictly prohibited. In addition:

  • All leather and hide must be from producers with proven good animal husbandry and produced in accordance with the animal welfare requirements noted in this policy.

  • All leather and hide must be a by-product of the meat industry and must not be obtained while the animal is still alive or from aborted animals. 

  • Bovine leather from India will not be accepted under any circumstance. Where the COO is India, suppliers will be asked to provide evidence of species.

  • Leather from Bangladesh will not be accepted under any circumstance. 

  • Leather or skin from wild caught, exotic or rare animals (and those appearing on the CITES (Appendix I, II and III) or IUCN list) is strictly prohibited.


Endangered Species

Deserve will not accept any products, including trims and jewellery, containing any part of or by-product from any species on the CITES (Appendix I, II and III) or IUCN lists of endangered species – this includes but is not limited to additional common materials such as bone, horn, shell, coral and teeth. In order to comply with this, suppliers are requested to provide Deserve with the common and Latin species names for any components derived from animals, along with the country of origin and declarations regarding the harvesting of the materials having been conducted in a humane manner. 


Wool and Animal Hair

Deserve only accepts the use of wool and animal hair clipped, shorn or combed from sheep, alpaca, lamb and goat from producers with proven good animal husbandry and produced in accordance with the animal welfare requirements noted in this policy. Please note that:

  • Merino wool must not be sourced from producers who practise mulesing.

  • Angora rabbit and Angora goat (mohair) is prohibited in any product supplied to Deserve (regardless of the branding the article carries).

  • The use of hair from companion animals (such as cats and dogs) and animals reared in cages, including but not limited to racoon, marten, fox, squirrel, sable, chinchilla or ferret is strictly prohibited. 


Feather and Down

The use of genuine feathers or down is strictly prohibited in any product supplied to Deserve (regardless of the branding the article carries). Acceptable alternatives include synthetic fillings and wadding (with a preference for recycled). 


Animal Testing 

Cosmetics and beauty products supplied to Deserve must not be tested on animals in accordance with the EU animal testing ban that came into effect on 11th March 2013.

Environment Policy


Suppliers are expected to effectively manage their businesses in order to have minimal impacts on their local environments and communities. Deserve is at the beginning of its journey on Environmental Management and wants to work with suppliers to take steps to improve impacts over time. We will begin to ask more from suppliers in this regard over the next few years and ask that suppliers work with us to make improvements as we will be doing. 

The first step on the journey will be to quantify the impacts that we have both internally, and through our supply base, and set targets to reduce those impacts. We will communicate these impacts, and targets, to suppliers. 

The below represents minimum expectations in this regard and suppliers are required to communicate these expectations throughout their supply base, and strive for improvements where possible.  


Management Systems

  • Ensure that all sites are aware of and comply to all relevant local and international laws. 

  • Have internal systems in place to check that legal requirements are being met, and that these systems are documented.

  • Keep records of any government checks.

  • Establish management systems for  ensuring environmental requirements are maintained.

  • Train all employees on relevant environment matters including air emissions, management of hazardous substances, preventing groundwater/surface water contamination, wastewater management, waste use and water management.

  • Advise Deserve should you be subject to any fines/prosecutions for non-compliance to environmental regulations.


Energy Use, Greenhouse Gas Emissions and Air Emissions

  • Where required, ensure permits for energy use are in place and up to date.

  • Where there are local regulations in place governing air emissions, ensure that these are met and that any permits are in place and up to date.


Biodiversity

  • The protection of our ecosystems is key to protect the raw materials that we use in Deserve products, as well as the communities that live and work in our business and supply chain. Deserve expects all suppliers to protect biodiversity at a local level around their manufacturing sites, for example by ensuring the proper treatment of waste and wastewater, and by taking the initiative to protect local plants and wildlife.  

  • Deserve also encourages the protection of ecosystems through the supply chain by sourcing fibres from regions or suppliers that protect natural forests and their environment.

  

Water Management

  • Where required, ensure permits for water usage and discharge are in place and up to date.

  • Ensure that wastewater is tested prior to off-site discharge to ensure that this will not breach local regulations or pollute the local water supply.

  • Have procedures in place for testing wastewater and actions to be taken if these are found to be out of regulatory limits.  Ensure all operators are trained according to these procedures.




Waste Management

  • Where required, ensure permits for waste disposal are in place and up to date.

  • Maintain records of off-site transfer, treatment and disposal of waste to track the waste disposal routes ensuring that they meet legal requirements.

  • Ensure that any external waste contractors have relevant certifications/permissions.


Packaging

  • Reduce the amount of virgin packaging used around Deserve products, and support Deserve by flagging where packaging can be removed or replaced with packaging that has recycled content.


Hazardous Materials

  • Assess and record all substances stored, used or handled on-site to ensure that none are prohibited by national or international regulations.

  • Maintain an up to date list of and MSDS for all chemicals onsite, understand how they impact the environment and have written procedures in place for use and disposal of these.


Chemical Usage

  • Ensure compliance with all requirements of Deserve’s Chemical Policies.

  • It is important to be aware of the chemicals that are being used with all fibre processing and garment manufacturing. Deserve expects suppliers to implement their Restricted Substance List (‘RSL’) for all products.  

  • Deserve reserves the right to check production records to ensure chemicals that meet our specifications have been used, and will test garments as per our testing policy to ensure that these meet our standards and legal requirements.

  • Deserve expect suppliers throughout the supply chain to protect the health and safety of workers, as well as those in local communities, by ensuring that chemicals are treated properly before disposal and that appropriate PPE is always worn whilst chemicals are being handled. Suppliers have responsibility to make employees aware of the impacts of the chemicals they are using and the reasons why PPE must be worn.

Transportation

  • Maintain records on transportation used within sourcing, manufacturing and delivery.

  • Deserve aims to avoid air freight where possible and wants to work with suppliers to get garments approved in a timely manner to enable other methods of transport for our garments.