Labour Standards Assurance System (LSAS) Policy

Introduction

Corporate Social Responsibility (CSR) for businesses is well established. Our CSR statement includes aims in relation to fair labour standards, ethics and human rights, health and safety, and sustainable and ethical procurement. IPS Converters Ltd (IPS) is committed to ethical procurement. Ethical procurement can make a significant contribution to our CSR aims. It can do this by minimising the risks of social exploitation within the supply chain. It also has the potential of improving the living and working standards of people within our supply chain.

IPS expects all supply chain partners to apply the principles of fair and honest dealings when undertaking all business activities, and ensuring anyone they deal with is treated with respect, fairness and honesty.

Aim and objectives

IPS’s LSAS Policy is relevant to the company internally, and to its supply chain in relation to both its labour standards and ethical responsibilities. It has been approved by the board of directors.

IPS is aware of and acknowledges its obligations towards its customers, employees, suppliers and the communities in which it works. Sufficient and adequate resources will therefore be made available in maintaining and further developing the LSAS. An LSAS champion has been identified and taken up the role within the company.

Our ethical objective is to ensure that people internally and in our supply chain are treated with respect and have rights in relation to employment. These include the rights to freely choose employment, freedom of association, payment of at least a legal minimum wage, working hours that comply with national laws, equal opportunities, recognised employment relationship, freedom from intimidation, and access to a safe and healthy working environment.

This policy has been communicated internally via the staff noticeboard. The policy is sent to suppliers who are required to confirm that they have read and understood the policy and their obligations.

Our LSAS policy is linked to our CSR policy, Modern Slavery Statement, Equal Opportunities Statement, Health and Safety Policy and employment terms and conditions as set out in the staff handbook.

Scope

Initially, this policy is being applied to products supplied to the NHS. It will be reviewed annually. Evidence for this will be contained in the annual Management Review. This periodic review will ensure ongoing improvement taking into consideration changes in legislation, and relevant codes of conduct and principles to which IPS adheres to. Periodic review should also help to ensure the adequacy, suitability and ongoing effectiveness of the policy.

This policy is relevant to the company internally and its supply chain.

IPS also requires its supply chain to comply with their national laws, the principles in this LSAS policy, and the Base Code of the Ethical Trading Initiative.
This policy is underpinned by the Ethical Trading Initiative (ETI) Base Code
The ETI Base code has the following principles:

1. Employment is freely chosen not forced.
2. Freedom of association for the workforce and supply chain members.
3. Working conditions are safe and hygienic.
4. Child labour should not be used.
5. Living wages are paid.
6. Working hours are not excessive.
7. No discrimination is practiced.
8. Regular employment is provided.
9. No harsh or inhumane treatment is allowed.

The minimum labour standards set out in this policy are based on the above ETI principles.

Supply chain partners are expected to not engage in any activity that may pose a conflict with the minimum labour standards or any other principles contained within this policy.

Business case

There are compelling business reasons for establishing minimum labour standards.

CSR responsibilities – the company acknowledges its obligations arising from its business operations in relation to its customers, employees and the wider communities in which it operates. The company has a commitment to work towards being more socially and ethically responsible (see CSR statement).

Loss of business – minimum labour standards are mandatory for NHS framework agreement suppliers. The company would not be able to supply the NHS without an LSAS system in place. The company will commit to implement LSAS Level 1 within six months, and LSAS level 2 within eighteen months of any new NHS framework agreement.

Maintaining the company’s reputation – adverse publicity can result from the discovery of labour standards abuses. Customers may choose to buy from a different supplier. There may also be problems with employee recruitment and retention if a company is known for its labour standards abuses.

Threat to security of supply – if a supply chain partner is facing legal enforcement action for labour standards abuses, this may lead to operational difficulties and interfere with their ability to continue supplying.

Poor quality goods – the company recognises the potential links between poor quality goods and poor labour standards. It is therefore in the company’s interests to ensure its suppliers maintain labour standards.

Responsibilities

The company directors along with the company accountant are responsible for ensuring the minimum labour standards are maintained and adhered to.

Minimum labour standards

The minimum labour standards that the company and its supply chain are expected to adhere to are as follows.

Forced & Compulsory Labour – the company/supplier shall not engage in or support the use of forced or compulsory labour, or bonded or involuntary prison labour. Employees are free to leave upon reasonable notice.

Freedom of Association – freedom of association is respected and the company/supplier will comply with UK labour relations legislation in this regard and relevant legislation across the world.

Health & Safety – the company/supplier shall provide a safe and healthy workplace environment and shall take effective steps to prevent potential accidents and injury to employees’ health by minimising, so far as is reasonably practicable, and in co-operation with its employees, the causes of hazards inherent in the workplace. All employees will receive safety and job specific instructions during the course of their employment with the company. Employees shall have access to clean sanitary facilities and drinking water. Responsibility for implementing the Health & Safety element of this policy is assigned to the Joint Managing Directors.

Child Labour – the company/supplier does not engage in or support the use of child labour. If the company engages any young workers, it will ensure that a suitable risk assessment is carried out and that young persons are not exposed to any hazardous conditions, or in any case work more than 8 hours per day.

Remuneration – the company/supplier shall comply with national laws and regulations with regard to wages and benefits. All work-related activities are carried out on the basis of a recognised employment relationship established according to national law and practice.

Working Hours – the company/supplier shall comply with applicable laws and industry standards on working hours and holiday entitlements. The company’s/supplier’s normal working hours do not exceed 48 hours per week, and overtime hours do not exceed 12 hours per week. The company/supplier ensures all employees have the legal right to be employed in the relevant country.

Discrimination – the company/supplier shall not engage in or support any discriminatory practices in hiring, remuneration, access to training, promotion, termination or retirement based on race, national or social origin, caste, religion, gender, sexual orientation, political affiliations, age or other conditions.

Bribery and corruption – suppliers must also comply with the anti-corruption laws of the countries in which they operate, for example the UK Bribery act or the US Foreign Corrupt Practices Act. IPS expects its supply chain to honestly and accurately record and report all business information, and to retain and dispose of business records in accordance with regulatory requirements. Suppliers may not make any direct or indirect payments or promises to any government officials or others for inducing that individual to use their position to obtain or retain business.

Compliance

There will be ongoing internal monitoring by the LSAS champion, along with periodic review at least annually by the directors.
The company will seek an independent external audit of the LSAS Level 1 standards within six months of the new NHS framework agreement.

Name: Ian Davies

Position: Director

Date: 31.01.2020