Ethical Trading Policy



The CONTUR ethical trade policy is set out to demonstrate that as a business we require all workers in our supply chain to be respected and treated fairly, as well as being financially secure and having a clean, safe work environment.  We are committed to working closely with partners who share our basic principles and in order to achieve this, we will share our values which will form the minimum standards that we expect from our partners.  Essentially, we will only work with partners who can demonstrate and promote our ethics up the supply chain. 

CONTUR will comply with the Modern Slavery Act 2015.

‘Supplier’- refers to any person or organisation that has had input into a final product

‘Tier 1’- refers to the (cut, make, trim) factories which involved in the manufacturing and processing of the final product. 


CONTUR recognise the following definitions, in relation to their Ethical Policy:

2.1 Employer- an employer is someone who offers work (for any period) in return for remuneration and has control of the workers duties and work environment.

2.2 Employment- is where someone seeks to perform a job in return for remuneration. Employment may be sought directly from an employer or through a form of labour agency. A person providing a service to an employer is deemed to be employed, even without a contract or regularity of number of hours worked.

2.3 Forced or compulsory labour– Menace towards a work to complete services/ work they unwillingly consent to do.

2.4 Hazardous Work- Work which endangers the workers health and safety. This can vary from work environment, working overtime, working without breaks, working around chemicals that could be harmful to the body and health, extreme temperatures, loud noises, carrying heavy objects, working at height or in confined spaces.

2.5 Migrant work– a migrant worker is someone who migrates to another country to seek work or better living conditions.

2.6 Subcontractor- an entity that contributes to the completion of a product to a supplier i.e. packaging, manufacturing, assembly.

2.7 Overtime– this is the hours worked out of contracted or agreed hours, which could be excessive or normal.

2.8 Indirect employment- an arrangement for an employee to carry out work via an agency for a supplier.

2.9 Direct employment- an arrangement between the employee and supplier for work directly.

2.10 Contract worker- A contract worker is a person who is managed, employed by a third party.

2.11 Child Worker- A ‘child worker’ is a young person who has not completed the compulsory schooling or legally old enough to start full time work. Someone who has not reached their 15th birthday is defined as a ‘child worker’.

2.12 Child Labour– This is the employment of children that are exploited to hazardous work.

2.13 Discrimination– unfair treatment not permitted by law, due to a person’s: ethnicity, colour, race, age, gender, disability, religion or belief, marriage status and sexual orientation.

CONTUR basic principles are:

  1. Employment is chosen freely

1.1. The employer should not use bonded, forced or involuntary prison labour. All workers in the supply chain must be:

1.1.1  Legally be employed and have a valid right to work

1.1.2 Employed or recruited by their own free will

1.1.3 Working voluntarily without pressure or threat to do so

1.1.4 Not working to pay off debt to employer or agency

1.1.5 Paid the national minimum wage, paid in full and on time

1.1.6 Free to give reasonable notice and leave employment

1.2 Workers should have access to their belongings, and they should not have personal documents (identity papers/ immigration documents)/ deposits held from them by their employer.

1.3 Deposits will not be retained to secure tools used for labour, accommodation, training, personal protective equipment (PPE) or for any other reason.

1.4 There will be no unreasonable restrictions of workers movement at the site of employment- entering or exiting.

  1. Freedom of association

2.1 Workers must be able to speak openly to their employer about the working conditions, without fear of repercussion for doing so.

2.2 Workers will have the right to freely join trade unions or other organisations to represent them, without being discriminated against for doing so.

2.3 Employers are not to input on the election of the union representative, or seek a worker for their own interest.

2.4 The employer should encourage the activities of a trade union and their organisational activities.

2.5 Where local laws restrict organisational activities and trade unions the employer will allow the workers to form their own committees and groups, where the representation ratio of management to staff is equal.

2.6 Collective bargaining documentation agreed by management and the trade union will be communicated to all workers and available for them to review.

2.7 Where an employer needs to legally consult a worker, these requirements must be met in full. Formal committees must meet regularly and operate to effectively work in the employee interest.

2.8 Trade unions and formal organisation representatives must have access to employers and colleagues without being discriminated against or restricted.

  1. Working Conditions are safe and hygienic

3.1 The employer will endeavor to provide a safe and hygienic working environment, bearing in mind the prevailing knowledge of the industry and of any specific hazards.

3.2 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 minimizing, so far as is reasonably practicable, the causes of hazards inherent in the working environment.

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

3.4 Cleanliness

3.4.1 The work environment will have access to clean drinking water, clean functional toilet facilities and if appropriate sanitary facilities. Toilets must have doors and give the worker privacy.

3.4.2 If on sight accommodation is provided this will be clean and safe and meet the basic needs of the workers.

3.4.3 Shared food cupboards and preparation area should be clean and hygienic.

3.5 Fire and Safety

3.5.1 Employers will examine and measure the potential fire risks their working environment could be exposed to.

3.5.2 Fire drills should be carried out every 6 months in the working environment, or if applicable accommodation.

3.5.3 Where applicable workers should be trained of how to react and use fire fighting equipment in the event of a fire, this should be conducted annually. This training must be recorded.

3.5.4 Employers should ensure their working environment has the required fire safety tools provided, for workers trained in fire safety to use in the event of a fire.

3.5.5 Employers should ensure stairs and fire escape routes are clear for staff to exit efficiently and safely in the event of a fire. All workers must know of the exit routes upon time of joining employment.

3.5.6 Fire safety signs should be visible around the working environment and in languages that the workers understand.

3.6 Medical structures

3.6.1 In case of an injury or illness at work, employers should provide the correct medical facilities and equipment for their workers.

3.6.2 Each workplace should have an appointed trained first aider on sight each shift and there should be 1 first aider to every 100 workers at one time.

3.6.3 First aid supplies should be readily available and accessible to workers and these should not be chargeable. They should be managed by designated personnel.

3.6.4 To ensure injuries that have previously occurred in the workplace are prevented, they should be logged, investigated and analysed to ensure the correct measures are being taken to avoid them in the future.

3.6.5 Channels to report accidents should be established and communicated to all workers.

3.7 Chemical Safety

3.7.1 Employer safety should be considered when hazardous chemicals are in the work place. Workers can be protected by implementing safety measures and providing personal protection equipment (PPE) where necessary.

3.7.2 Chemicals in the work environment should be labelled with their correct name and properties, so if an instance occurs where the workers is exposed to the chemical the correct actions can be taken to safe guard the worker.

3.7.3 Employers should plan and implement an emergency strategy for handling chemical releases and spills.

3.7.4 Eye washing equipment should be provided where the worker could be exposed to the risk of chemical splashes in the eye.

             4. Child labour shall not be used

4.1 Child Labour

4.1.1 A ‘child worker’ is a young person who has not completed the compulsory schooling or legally old enough to start full time work. Someone who has not reached their 15th birthday is defined as a ‘child worker’.

4.1.2 There shall be no recruitment of child labour.

4.1.3 Child workers must not be found participating in any process of the manufacturing of goods for Kacoo Fashion.

4.1.4 These policies and procedures shall conform to the provisions of the relevant ILO standards.

4.1.5 Copies of workers documents verifying their age should be retained in the workplace.

4.1.6 Documents with the workers age should be cross checked against photo identification to confirm the workers age is correct and meets legal requirements.

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 The worker should be provided with written and clear information of the calculation of their wage, by the employer:

  • Pay rate
  • Gross pay
  • Overtime pay
  • Net pay
  • Deductions
  • Hours worked, or piece rate if applicable

5.3 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.

5.4 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:

6.5.1 this is allowed by national law;

6.5.2 this is allowed by a collective agreement freely negotiated with a workers’ organisation representing a significant portion of the workforce;

6.5.3 appropriate safeguards are taken to protect the workers’ health and safety; and

6.5.4 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.

6.7 All employees shall be entitled to a period of holiday leave each year, which is in line with national law.

  1. 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.

7.2 Polices and practices for employees in the workplace should demonstrate equality of treatment.

7.3 No worker should be faced or threatened with discrimination. Evidence of this occurring in the workplace should be handled by management appropriately.

8. Regular employment is provided

8.1 All aspects of work carried out must be based on acknowledged employment relationship, that is established through national law and practices.

8.2 Sub-contracting, labour-only contracting, home-working arrangements, or apprenticeship schemes should not be used by an employer to avoid the obligations of employees under social or labour security laws and regulations, that provide them with a regular employment relationship.

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.

9.2 Employers should develop a written grievance and disciplinary procedure for employees in the workplace and make sure all employees are aware and clear of this.

9.3 Disciplinary and grievances that are addressed must be recorded and kept on record in the workplace.

9.4 There must be no penalisation or intimidation against an employee who raises a grievance.