Number: ETSO1

Last Updated 3rd January 2022

Introduction

WBM Insulation Ltd (the company) aims to provide its customers with quality products and value for money. In today’s global market, this means sourcing products from a variety of locations nationally and internationally.

In recent years, concerns over poor working conditions and environmental degradation in developing countries and emerging markets have seen companies implement specific social and environmental criteria for the production facilities from which they source products.

In order to address these concerns, WBM are introducing its Ethical Sourcing Policy to ensure it is:

1. Sourcing its products in a responsible manner,
2. Working with its suppliers to improve their social and environmental practices, providing clear guidance to its buying staff, and
3. Protecting its corporate reputation, the reputation of their brands.

Our Commitment

WBM are committed to upholding human rights, fair working conditions and environmental protection.

In accordance with the expectations of our customers, the community, and the requirements of the Law, we endeavour to always operate responsibly within the community and we expect the same from our suppliers.

Maintaining a reputation for the highest legal, moral and ethical standards in our dealings with our customers for our ongoing success. 

The Policy has been developed to complement our core values of integrity, trust and acting responsibly.

We are committed to working with our suppliers to help improve their labour and environmental practices.

Expectations

We expect our suppliers to support the ethical standards set out in this Policy with regard to workplace safety, environment, and fair pay and employment conditions.

The Policy sets out the standards that we expect all of our suppliers to comply with when producing and supplying products for WBM, no matter where they operate in the world. We recognise that full compliance with these criteria may take time for some suppliers, and we are committed to working with our suppliers to implement improvement plans and help them achieve compliance.

• Business Integrity

We will ensure integrity in all our business transactions. We will be open, honest & fair in our communications and our dealings with others affected by our activities and where necessary that of our supply chain. 

The company operate strict codes of conduct with regard to acceptance of bribery or gifts made in the in the course of our business (see the Company’s anti-bribery & corruption policy).

People

We expect our suppliers and sub-contractors to share our commitment to Labour Rights, Working Conditions and  H&S by implementing robust policies and procedures that put the employees and others who could be affected by their activities at the heart of their operations.

Labour Rights

• We are committed to the promotion of ethical working conditions including fair wage, working hours and equal opportunities.

• We will respect the principles of human rights, to treat employees with dignity and respect and to ensure: 

1. That no child labour is employed and will not work with suppliers who use child labour.

Child labour refers to work that:

Is mentally, physically, or morally harmful to children;

Can negatively affect their mental, physical, or social development, and Interferes with their schooling:

by depriving them of the opportunity to attend school;

by obliging them to leave school prematurely; or

by requiring them to attempt to combine school attendance with excessively long and heavy work.

In short: child labour is work that deprives children of their childhood, their potential and their dignity, and is harmful to their physical and mental development.

1. That employment is freely chosen, that there is no forced, bonded or involuntary prison labour.
2. That workers are not required to lodge deposits or their identity papers with their employer and are free to leave their employer after reasonable notice

Working Conditions

•  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 in the working environment
• Workers shall receive regular and recorded health and safety training, and such training shall be repeated for new or reassigned workers
• Access to clean toilet facilities and to clean and drinkable water and, if appropriate facilities for food storage.
• Suppliers will ensure that personal protective equipment is available and workers are trained in its use. Safeguards on machinery must meet or exceed local laws
• Suppliers shall assign responsibility for health and safety to a senior management representative.

Living Wages & Working Hours

We will ensure wages and benefits paid for a standard working week meet,  a minimum, national legal standard  or industry benchmark standard, whichever is higher. 

• In any event wages should always be enough to meet basic needs and to provide some discretionary income.
• 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.
• Deductions from wages as a disciplinary measure or any deductions from wages not provided for by Law shall not occur without the expressed permission of the worker concerned. All disciplinary measures should be recorded
• Working hours comply with any Law and benchmark industry standards, whichever affords greater protection
• In any event, workers shall not on a regular basis be required to work in excess of 48 hours per week and shall be provided with at least one day off for every 7 day period on average.
• Overtime shall be voluntary, shall not be excessive, shall not be demanded on a regular basis and shall always be compensated at a premium rate.

Discrimination

We will ensure that 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.

Harsh or Inhumane Treatment

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

Entitlement to Work and Immigration

• Only workers with a legal right to work shall be employed or used by the supplier
• All workers, including employment agency staff must be validated by the supplier for their legal right to work by reviewing original documentation
• The supplier shall implement processes to enable adequate control with regards to the above points and related legislation.

Environmental Impact

The Company will take into account, wherever practicable, the environmental performance and impact of goods and services when making purchasing decisions.

• We will seek to reduce waste and will do this through reviewing the amount & type of materials being used & specified and optimise opportunities for the use of recycled or reclaimed materials.

• We will seek to reduce our carbon footprint by sourcing goods / materials with low embodied carbon.
• The use of materials with hazardous content will be minimised wherever technically & commercially feasible.
• We will procure all timber and wood based products from a certified legal and sustainable source.
• We expect our suppliers to manage their own impacts and to work with us to meet our environmental objectives.
• We expect our suppliers to have an environmental policy and to operate in compliance with all applicable laws and regulations.
• We will ensure the specification of environmentally sustainable materials wherever technically & commercially feasible.

Procurement

• We will support local procurement wherever technically and commercially feasible.
• Local procurement of goods, services and materials will be encouraged with a view to supporting local communities and reducing the overall carbon footprint of our activities.
• Where possible, we will maximise the benefits to the local community from our projects by working with local authorities and organisations to recruit local labour and source good services from the local area.
• We will work with our clients and local agencies to find appropriate opportunities for skills, training & apprenticeships to promote career progression and to support local economic regeneration.
• Source material from approved and reputable suppliers and assure that no child labour is used at any stage in the production or fabrication of material to be supplied.
• We support, and expect all our suppliers to support, the principles set out within the UN Universal Declaration of Human Rights, the International Labour Organisation Declaration on Fundamental Principles and Rights at Work, the UN Global Compact and the UN Guiding Principles on Business and Human Rights.
• Ethical Procurement: We strive to maintain the highest standards of ethical conduct and corporate responsibility and seek to encourage our suppliers to operate to similar high standards.
• We are committed to the principles of sustainable development and aim to encourage our suppliers to adopt the values of sustainability which we uphold.
• We expect all of our partners, staff and those representing the firm to adhere to our principles

Implementation & Review

WBM Insulation Ltd are committed to working in partnership with its suppliers to help achieve compliance with this Policy. In the event where any supplier is unwilling or unable to demonstrate continuous improvement towards full compliance with our standards, the trading agreement between WBM and the supplier will be terminated

Claire Wilkins – Director

Sue Budd – Health & Safety Manager

Last Updated 3rd January 2022