NURSE CARE UNIFORMS
LABOUR STANDARDS ASSURANCE SYSTEM (LEVEL 1)
POLICY AND PROCEDURES
Overview
It is the clear policy of Nurse Care Uniforms to comply with all relevant legislation both in our own country (the United Kingdom) and in any other country where we have a direct involvement – including where we have sub-contractors as part of our supply chain.
We have, and will monitor and update, a range of policies that are relevant to our own UK operation and will also monitor overseas sub-contractors’ policies to ensure that they are in place, reviewed and updated regularly. As far as possible we will take steps to ensure that our overseas suppliers adhere to the policies that they have in place.
The relevant policy documents will cover:
Health and Safety issues (including Health and Safety training policy)
Human Resources
Labour Standards
Corporate Social Responsibility
Policies related to the selection of sub-contractors.
We will require all sub-contractors to provide copies of their relevant policy documents, and to confirm that these comply with the appropriate legislation in their own country and to formally confirm that they adhere to these policies.
It is a fundamental requirement within the Nurse Care Uniforms supply chain that all suppliers operate safe and ethical manufacturing operation and abide by any local legislation regarding the age of workers, their working condition and minimum wages.
We will not contract with any organisation that employs children less than 15 years of age (under any circumstances) and only where allowed by local legislation will we engage with companies employing children between 14 and 15 years old and then only if these children undertake light work and are not prevented from undertaking any mandatory training or education.
The Directors of Nurse Care Uniforms are aware of current UK legislation relating to bribery and other inappropriate inducements and will not tolerate any breaches of this legislation either within our own team or amongst our suppliers.
Where the Directors of Nurse Care Uniforms do not possess the necessary skills or knowledge to fully implement this procedure, we will utilise the services of external consultants, or others having the necessary knowledge, to assist us.
Signed
Glen Elms, Managing Director Nurse Care Uniforms
November 20th 2013
Latest Review date November 19th 2014
Section 1 - Specific Standards
Nurse Care Uniforms Directors are aware of the NHS Suppliers Code of Conduct and have a clear policy of complying with this Code of Conduct which is based on the Chartered Institute of Purchasing and Supply’s Professional Code of Ethics.
The key elements of this Code of Conduct cover:
- Maintaining integrity in business relationships
- Rejecting improper business practice
- Declaring any potential personal or business conflicts of interest
- Acquiring and maintaining latest standards of technical knowledge and ethical
behavior
- Optimizing the use of resources
- Compliance with UK law, industry guidelines and contractual obligations
- Fair, honest and respectable treatment of suppliers
- Common courtesy at all times
- Incorporating sustainable procurement aspects into procurement processes
including human and employee rights and the environment.
We support the aims and principles of the United Nations Global Compact, The United Nations Universal Declaration of Human Rights and the 1998 International Labour Organisation Declaration of the Fundamental Principles and Rights at Work.
Under no circumstances will Nurse Care Uniforms contract with any organisation utilising forced labour or any organisation using any illegal or unethical practices in their recruitment.
We will not contract with any organisation that discriminates on the grounds of race, religion, age, gender, disability or sexual orientation.
Section 2 -Management Representative
The Directors of Nurse Care Uniforms have nominated Mr Sean Elms, Sales Director as the Management Representative having overall responsibility for overseeing and reviewing labour standards both within the company and our sub-contractors.
Amongst the specific tasks to be undertaken by the Management representative are:
- To require all sub-contractors to provide an organigram (organisation chart) that clearly indicates who in that organisation has overall responsibility for the Labour Standards Assurance System (LSAS) Level 1 compliance and other individuals throughout the organisation who LSAS related responsibilities
- To review the seniority level of the sub-contractors person with overall responsibility for LSAS Level 1 compliance and to ensure that if they are not at the highest level of management within the company, that at least they have a direct reporting to the highest management level.
- The sub-contractors person with overall LSAS compliance responsibility clearly understands their roles and responsibilities and has documentary evidence to indicate that such roles and responsibilities have been unambiguously defined.
- The Management Representative will undertake regular interviews (at least annually) – either face to face, by telephone or as a last resort by exchange of emails – to ensure that the sub-contractors LSAS responsible person does understand their role and that they can demonstrate that they are taking the appropriate steps to ensure LSAS Level 1 compliance.
Section 3 – Labour Standards Status Review
Nurse Care Uniforms acknowledges that there is the potential for abuse of workers in the Asian Countries where our sub-contractors are based. However we will not tolerate any such abuses and all sub-contractors will be required to provide evidence that they comply with National and relevant International legislation is understood and that our sub-contractors comply with all such legislation.
As such we will undertake a risk assessment at regular intervals of no more than twelve months to identify how such legislation can impact our own business and how breaches of compliance amongst our sub-contractors could lead to termination of supply contracts and therefore disrupt our own supplies.
In order to mitigate such risks, wherever possible, we will operate a policy of (at least) dual supply to ensure supply continuity until such time that breaches are rectified or alternative (fully compliant) suppliers are identified.
Our own risk assessment will include an evaluation of all suppliers and sub-contractors who may not necessarily be involved in the supply of Nurses Uniforms and other work wear – including provision of services rather than merely goods.
All key issues covered by the aims and principles of the United Nations Global Compact, The United Nations Universal Declaration of Human Rights and the 1998 International Labour Organisation Declaration of the Fundamental Principles and Rights at Work will be considered. We will also consider the effects, compliance and implications of our policies detailed in the overview to this document, above.
As part of our risk assessment we will identify how the International Labour Standards (detailed above) relate to Nurse Care Uniforms – both directly in our own organisation as well as with our sub-contractors.
In addition to covering our own operation in this risk assessment we will also require our sub-contractors to undertake a similar risk assessment for their own operation – providing a risk assessment template if they are not full familiar with such processes.
As appropriate, as part of our own risk assessment and those of our sub-contractors we will invite and consider the views of other relevant stakeholders and interested parties.
Section 4- Legal and Other Requirements
In order to maintain up to date information regarding all aspects of Human Resource management, including legislation in both the United Kingdom and other countries where our sub-contractors are located, we utilise the services of Abacus HR Limited who are professional HR consultants.
Abacus HR also provide updates, as appropriate, of any changes to Human Rights Legislation that is relevant to Nurse Care Uniforms, including any legislation that directly affects our existing – and potential - sub-contractors.
Within Nurse Care Uniforms, our Management Representative has overall responsibility for assuring labour standards within our supply chainThis representative – our Sales Director Sean Elms – liaises directly with Abacus HR to ensure that he is fully acquainted with all aspects of Human Rights and Human Resources legislation as it affects Nurse Care Uniforms.
Whilst the overall responsibility for ensuring that we and our sub-contractors are compliant with current Human Resources and Human Rights legislation, our Sales Director – Mr Glen Elms – acts as his deputy and is the only other individual within Nurse Care Uniforms who has direct contact with our sub-contractors. The Managing Director is copied in to briefing notes from Abacus HR.
Section 5- Objectives, Targets and Programmes
Nurse Care Uniforms has established targets for labour standards assurance and these targets are covered in a separate document.
Targets will be reviewed, and in necessary, updated at intervals of no longer than one year.
All subcontractors will be required to adhere to these targets providing evidence of their compliance where appropriate.
Section 6-Roles and Responsibilities
Nurse Care Uniforms has a very small number of subcontractors outside the UK, and the monitoring and implementation of the Labour Standards Assurance System Level 1can readily be handled by the Management Representative without the need to allocate additional resources within Nurse Care Uniforms.
The only additional resource required in the United Kingdom is that regarding specialist consultants.
The Management Representative will ensure that all subcontractors also have sufficient resource to monitor and implement all aspects of LSAS Level 1 within their own organisation.
Section 7- Competence Training and Awareness
Nurse Care Uniforms will ensure that the Management Representative, his deputy (the Sales Director) and Human Resources/Human RightsConsultants will be fully trained and/or briefed in all aspects of labour standards relevant to LSAS implementation.
The Management Representative will seek similar assurances regarding training and/or experience from the responsible person (people) in all of our subcontractors.
The relevant levels of training and/or experience for the Management Representative will be determined by the HR consultant from Abacus HR in consultation with any LSAS consultant if deemed necessary or appropriate.
Section 8 - Communications
All LSAS subcontractor reviews will be fully documented by the Management Representative.
The Management Representative will have personal responsibility for responding to any communications relating to LSAS compliance and reviews – whether such communications are with subcontractors or stakeholders (including the NHS and other clients).
In the case of non-compliance being reported by Nurse Care Uniforms staff, the individual concerned will protected from any adverse action by the existing Whistle Blower policy contained in the Staff Handbook. Any information received from a whistle blower will be treated in the strictest confidence with the source of any non-compliance being treated in the strictest of confidence.
Nurse Care Uniforms will detail its compliance with LSAS Level 1 (and in due course higher levels) on its website and in relevant sales related documentation.
The Management Representative will provide a report at each board meeting in which he will provide an update on the progress made in monitoring the results of LSAS related investigations and general progress regarding Human Resources and Human Rights issues.
Outline information regarding subcontractor progress relating to LSAS related performanceand in particular the status (pass or fail) of all subcontractor reviews will be passed to all Nurse Care Uniform staff as part of the existing management information process.
Section 10 - Operational Control
As part of its regular subcontractor review processes Nurse Care Uniforms will include questions to the subcontractors regarding compliance with Human Resources and Human Rights issues.
These questions – which are in addition to the full LSAS compliance questionnaire and review process will include the requirement to confirm the age range of employees currently working (whether on products for Nurse Care Uniforms or not), confirmation that minimum wage standards are met or surpassed and that employees all have sufficient breaks (either during to working day or at night between working days).
These questions address what are considered to be the most critical areas of potential weaknesses or even non-compliance with current legislation, and will be raised at intervals of no more than every three months.
Section 11 - Supply Chain Management
Nurse Care Uniforms will maintain a database of all suppliers and subcontractors although it must be acknowledged that the nature of our business means that we work with a very small number of subcontractors.
All Tier One subcontractors will be required to inform Nurse Care Uniforms if they, in turn, subcontract work – in which case they will be required to provide full details of these lower tier contractors and will also be required to ensure that these lower tier contractors also complete the Nurse Care Uniforms’ questionnaires relating to labour standards.
All existing and potential suppliers/subcontractors will be informed of the Nurse Care Uniforms LSAS level 1 credentials and will be made aware that following the aims and principles of the United Nations Global Compact, The United Nations Universal Declaration of Human Rights and the 1998 International Labour Organisation Declaration of the Fundamental Principles and Rights at Work are mandatory if they are to become/remain Nurse Care Uniform subcontractors..
If we receive information that any subcontractors are breaching these aims our Management Representative will immediately undertake an investigation to confirm, or eliminate, any such claims. If the claims are upheld, or if in the process of routine monitoring, any subcontractors are found to breaching these aims then no further orders will be placed on them by Nurse Care Uniforms until remedial action has been undertaken and verified.
All written orders placed on our subcontractors will contain reference to the need to comply with the aim listed above.
Section 12 - Emergency Response
If our aims regarding labour relations and human rights are found to have been breached by any subcontractor, Nurse Care Uniforms will not place any further orders on this subcontractor until remedial action has been taken and evidence has been presented to prove that the remedy has been fully implemented.
For this reason we will (at least) duel source all items to enable us to take this action without causing a rupture in our overall supply chain and therefore compromise our clients.
On our supplier database as detailed in Section 11, above, will include details of alternative suppliers against each existing subcontractor/product category to enable the supply chain to remain intact in the case of temporary non-compliance by any one supplier.
Section 15 - Management Review
The Directors of Nurse Care Uniforms, led by the Sales Director (who is the Management Representative) will provide an update on LSAS related issues at each board meeting and will arrange for a complete review of this document at regular intervals of no more than one year.
Any significant or serious lapses or deficiencies in adherence to LSAS related processes will be reported to all members of the Board of Directors.