Our Supply chain

Templecoombe Ltd Ethical Policy
(Inc Modern Slavery Act legislation and responsibilities

1: Employment is freely chosen
1.1 There is no forced, bonded or involuntary prison labour.
1.2 Workers are not required to lodge “deposits” or their identity papers with their employer and are free to leave their employer after reasonable notice.

2: Freedom of association and the right to collective bargaining are respected
2.1 Workers, without distinction, have the right to join or form trade unions of their own choosing and to bargain collectively.
2.2 The employer adopts an open attitude towards the activities of trade unions and their organisational activities.
2.3 Workers representatives are not discriminated against and have access to carry out their representative functions in the workplace.
2.4 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
3.1 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.
3.2 Workers shall receive regular and recorded health and safety training, and such training shall be repeated for new or reassigned workers.
3.3 Access to clean toilet facilities and to potable water, and, if appropriate, sanitary facilities for food storage shall be provided.
3.4 Accommodation, where provided, shall be clean, safe, and meet the basic needs of the workers.
3.5 The company observing the code shall assign responsibility for health and safety to a senior management representative.

4: Child labour shall not be used
4.1 There shall be no new recruitment of child labour.
4.2 Companies shall develop or participate in and contribute to policies and programmes that 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.
4.3 Children and young persons under 18 shall not be employed at night or in hazardous conditions.
4.4 These policies and procedures shall conform to the provisions of the relevant ILO standards.

5: Living wages are paid
5.1 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.
5.2 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.
5.3 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
6.1 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.
6.2 to 6.6 are based on international labour standards.
6.2 Working hours, excluding overtime, shall be defined by contract, and shall not exceed 48 hours per week*
6.3 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.
6.4 The total hours worked in any 7 day period shall not exceed 60 hours, except where covered by clause 6.5 below.
6.5 Working hours may exceed 60 hours in any 7 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 a workers’ organisation representing a significant portion of the workforce;
• appropriate safeguards are taken to protect the workers’ health and safety; and
• the employer can demonstrate that exceptional circumstances apply such as unexpected production peaks, accidents or emergencies.
6.6 Workers shall be provided with at least one day off in every 7 day period or, where allowed by national law, 2 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 workers’ wages as hours are reduced

7: No discrimination is practiced
7.1 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
8.1 To every extent possible work performed must be on the basis of recognised employment relationship established through national law and practice.
8.2 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
9.1 Physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation shall be prohibited

10: Supplier Policy
10.1 Templecoombe Ltd recognises its obligations to do its best to ensure its suppliers operate under a similar ethical code of conduct, in order for the commitment to follow through the supply chain.
10.2 For this to take place we have a supplier rating system and only suppliers that achieve a level A or B on inspection can be used as a supplier.
10.3 The Templecoombe Ltd company database operates to block suppliers at level C or below.
10.4 Suppliers are assessed on a yearly basis every July on a comprehensive set of criteria, including their ethical policy.

Templecoombe Ltd: Equal Opportunities Policy

Templecoombe Ltd is committed to treating all people equally and with respect irrespective of their age, disability, gender reassignment, marriage or civil partnership, pregnancy or maternity, race, religion or belief, sex, or sexual orientation”.

To achieve this in practice, interviews are conducted at first and second round by two different individuals and by a points based system against set criteria for each role.

Templecoombe Ltd: Health & Safety Culture

Here at Templecoombe Ltd, we are pleased to confirm that we take the health and safety of our team seriously.

STAFF TRAINING
Upon starting work here, all staff are given a full health and safety induction, conducted by our internal health and safety manager. Health and safety policies are stated in an information health and safety manual and staff are asked to sign to confirm their adherence to this policy as part of their induction. A training session on site is also undertaken for the use of fire extinguishers and fire safety.

We have a trained first aider on site and each time this certification expires a different member of the team goes for the external training course and certification. After each course; feedback is given in person to all team members. This covers any changes since the last course, lifesaving reminders and reminders of the nearest locations of defibrillators.

COMMUNICATION OF HEALTH AND SAFETY INFORMATION
Health and safety updates are normally conveyed to staff in a training meeting. Alternatively updates may be communicated by electronic mail to all staff involved. As required, there are health and safety messages, information and signs displayed throughout the workplace, to communicate to staff any health and safety hazards or systems.The main Health and Safety Law poster is displayed in the work kitchen that all team members use.

MANAGEMENT SYSTEMS
We are pleased to confirm that our internal health and safety manager has numerous H&S management systems in place used for the monitoring, reporting and resolving of H&S topics.

Management systems that we have in place include the regular checking and monitoring of potential hazards such as checking for trip hazards and other potential hazards on the premises. The regular checking of the fire alarm, emergency lighting and fire extinguishers are all logged. Fire evacuations are undertaken on a regular basis (yearly) and in addition always within one month of a new starter.

All accident and incident reports are logged and reported to management. The team are aware of where to find the accident reporting book.

Templecoombe Ltd: Health & Safety Policy Statement

Templecoombe Ltd recognises that it has responsibilities for the health and safety of our workforce whilst at work and other partners; particularly our customers, who could be affected by our work activities. We will continuously assess the potential hazards and risks faced by our work force in the course of their work and take action to minimise those risks to an acceptable level.

The directors working at Templecoombe Ltd are aware of their responsibilities and are required to take all reasonable precautions to ensure the health, safety and welfare of potentially ‘at risk’
stakeholders.

Templecoombe Ltd intends to meet and maintain its legal and moral obligations by providing a safe and healthy working environment so far as is reasonably practicable. This will be achieved by:

– Providing leadership and adequate control of identified health and safety risks
– Continuously consulting with our team on matters affecting their health and safety
– Providing a safe working environment and regularly assessing any existing or new risks
– The provision of the resources necessary to ensure the policy is effective, reviewed regularly
and is proactive

We also recognise

– Our duty to co-operate and work with our suppliers and customers; to ensure safety
throughout the supply chain
– Our duty to minimise and assess risks to any visitors

To help achieve our objectives and ensure our employees recognise their duties under health and safety legislation whilst at work, we will also instruct and remind them of their duty to take
reasonable care for themselves and for others that might be affected by their actions. These duties are explained to them at induction and are visual on the Health and Safety Law poster displayed prominently in the kitchen.

In addition to and in support of this policy, specific responsibilities for First Aid and Fire Safety have been allocated.

Templecoombe Ltd Anti-Bribery Policy

We do not, and will not, pay bribes or offer improper inducements to anyone for any purpose, nor do we or will we, accept bribes or improper inducements. To use a third party as a conduit to channel bribes to others is a criminal offence. We do not, and will not, engage indirectly in or otherwise encourage bribery.

Employees must not engage in any form of bribery, either directly or through any third party (such as an agent or distributor). The anti bribery policy is discussed with all new employees on induction.

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Templecoombe Ltd Sustainability Policy Statement

We are committed to a sustainable future and to improving the social, economic and environmental well being of the community. We recognise our business can have negative impacts and are committed to reducing this impact both in our company and our supply chain. We aim to contribute positively to our local community.

Our business:
We recognise that although our operations have a relatively low impact environmentally we still have a responsibility to reduce the impact of our day to day activity and to help advise customers make the best possible decisions they can. In order to do this we:

• Train our staff to be as transparent as possible about the products and give as much information as they can when asked. We do not promote one ‘best’ option believing that this must be determined by the customer and their individual requirements and needs.
• Operate a diary system for each customer to remind them to keep an eye on their stock. This can reduce or negate any need for airfreight and allows us to use standard deliveries where orders are bulked together
• Use electronic communications where possible and are constantly looking to reduce our consumption of paper (see policies in progress)
• We recycle all our scrap paper and have dramatically reduced our consumption of ‘virgin’ paper
• We recycle printer cartridges and old computer equipment where we can (see policies in progress)
• Strict ‘switch off’ policy. All our lights and computers are turned off by the last member of staff in the building at night.
• Communal kitchen and tea and coffee making facilities. The majority of staff bring in a packed lunch and use the facilities thus reducing any packaging from disposable cups and bought sandwiches.

Our manufacturing supply chain:
Templecoombe Ltd recognises its obligations to do its best to ensure its partner factories operate under a similar ethical and environmentally proactive code of conduct. In order for the commitment to follow through the supply chain we:

• Have a supplier rating system and only use suppliers that achieve a level A or B on inspection
• Programme the company database to block use of suppliers at level C
• Assess partner factories on a yearly basis every July on a comprehensive set of criteria, including their ethical and environmental policy and practice.

Our community:
We make efforts to positively impact our local community and wider community by doing the following:

• Always supporting the towns flower displays and Christmas trees and lights. Also other adhoc celebrations such as the Coronation
• Supporting our local Lions club
• Supporting national emergency appeals; the most recent being the Turkey/Syria earthquake appeal.
• Supporting our team, our factories teams and our customers with any personal fundraising sponsorship requests
• Ad hoc local support projects; current examples:
-we have hosted two events and helped sponsor the towns Ukrainian flags; we have a large Ukrainian refugee community relative to the size of the town
-we have recently contributed to the purchase of a fridge for the local food bank

Templecoombe Ltd Environmental Policy Statement

Templecoombe Ltd is committed to providing quality products and excellent service to its customers. We believe this should be done in a way that protects and limits potential harm to the environment and that this should be achieved by a continuous process of review.

We aim to minimise adverse environmental effects arising from our business activities and promote a positive attitude to the conservation and enhancement of all aspects of our environment. The company will comply with all the relevant legislation and adhere to the principles of the prevention of pollution during the manufacture and delivery of the products by the factories as well as the office based operations.

We aim to achieve this by:

– monitoring materials used to make the products and being clear with our customers about the materials
– offering recycled materials as options for the products where appropriate
– reducing waste and scrap by efficient and planned purchasing and order processing
– having a diary system so that customers are able to cope with and are encouraged to use sea freight when goods are imported, as opposed to using airfreight
– carefully vetting our suppliers and factories to ensure their commitments and standards and filtering this information through the company as part of our approved supplier rating system
– electronic invoicing and internal memo policy as well as recycling of all other office based waste
– reviewing our objectives and performance annually

For further information about materials used in our products and the finished products, manufacture and distribution see ‘Environmental Guide and Commitment’