CSR Policy

S. T. Gifts Ltd considers the interests of society by taking responsibility for the impact of our activities on our customers, suppliers, employees, communities and other stakeholders, and the environment. We are committed to consistent and ongoing improvements in ethical and environmental practices

S. T. Gifts Ltd strives to implement and encourage the highest environmental and ethical standards through its global operations. Solo believes in doing business with those suppliers and partners who embrace and demonstrate high standards of ethical business behaviour.
 

Ethical Sourcing Policy

S. T. Gifts Ltd prides itself on being able to offer its customers regularly new products in all areas of the business.

Our buyers continually search for new and exciting products from different parts of the world, and have, over the years, developed long term relationships with many suppliers. As a result, the company has consistently offered its customers high quality products.

The company, as a result of the emphasis on environmental and sustainability issues being high on the agenda in many fronts, is in the process of developing an Ethical Sourcing Policy.

In the meantime, our Quality Control process remain in place to responsibly reinforce the quality of the service we currently offer to all our customers.

The company acknowledges the importance of responsible sourcing and the promotion

of fair and safe working conditions within the supply chain. Our ESP will recognise the complexity of its supply chain, diversity of product lines and the global citizens who produce them.

The intention is to promote high ethical standards within the supply chain without imposing unachievable conditions. Our aim is to understand the diversity of the supply chain, embrace local cultures and, through its trading relationships, support livelihoods.

The Company recognises that global influences on employment conditions and human

rights are continually changing. In order to keep up to date with these changes and

developments, we will review our policies periodically.

Sourcing Principles

The Company offers products sold under giftware category suitable to both genders and age groups. To create and produce this range of products, most suppliers

have their own complex supply chains and the Company aims to understand the diverse

components within them.

We are aware of the complexity of our supply chain and aim to understand the diverse needs within it. S. T. Gifts Ltd is committed to ensuring our suppliers look at ways of improving the working standards and environment of their workers.

Since the company is not the direct employer of such workers within these supply

chains, it appreciates that achieving our objectives will not be a simple task. There

are many constraints on the company’s ability to raise working conditions, particularly

where local governments do not enforce the law. However, S. T. Gifts Ltd aims to

overcome these constraints through innovative partnerships and a process of

continuous improvement.

Where non-compliance is reported, the Board will discuss a remediation programme with the supplier and agree a review of the changes within a realistic period. Where a supplier is unable or unwilling to make the proposed changes, the company will disengage from that supplier without hesitation. The ESP is communicated to all the employees involved in the procurement of products. This is to ensure a collective and active role in influencing good practices, in addition to encouraging open and honest dialogue with our suppliers.

Our Approach

The company’s policy framework is necessarily complex, as it recognises the diversity of its product lines and the global citizens who produce these products. The approach is therefore realistic, objective and geared towards continuous improvement. In our relations with suppliers, we do not intend to impose unachievable conditions, which may be counterproductive to the workers and suppliers’ interests or which may encourage dishonesty amongst the company’s supply chain. Instead, it endeavours to realise the diversity of our supply chain and embrace local cultures.

The Ethical Sourcing Code (ESC)

It will be the supplier’s responsibility to communicate and implement the company’s

ESP within their supply chain. The supplier must assign a senior manager with the

responsibility of implementing the code.

Where previous audits have been carried out against a different code, the company  will

review such policy to establish compatibility with its own Policy. The ESC will be founded on, and will comprise, the following principles:

1.-Forced Labour

1.1 No forced, bonded or involuntary prison labour.

1.2 Workers are not required to lodge ‘’deposits’’ or their identity papers with the employer. However, employers may make copies of the workers documents for purposes of keeping records.

1.3 Where workers are required by law to lodge deposits or identity papers, these must be returned to the worker promptly following the termination of employment contract. The holding of such papers should not be used to restrict free movement of workers.

2. -Health and Safety

2.1 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.

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

2.3 Access to clean sanitary facilities and to visibly placed potable water shall be provided. No limits shall be imposed on the number of times workers can take drinks of water or use sanitary facilities.

2.4 If accommodation is provided, this should be safe and clean.

2.5 A sanitary food storage area shall be provided.

2.6 The company observing the code shall assign responsibility for health and safety to a senior management representative.

3. Wages and Benefits

3.1 The terms and conditions of employment should be made clear to the worker, either in writing or verbally in a way in which the workers understand them.

3.2 Wages must be paid according to the national law or industry benchmark, whichever is the same, or greater than the minimum wage.

3.3 Wages must be paid at regular intervals according to the national law or industry benchmark, whichever affords greater benefit.

3.4 Deductions from wages not provided for by national law shall not be permitted

without the expressed permission of the worker concerned.

4. Working Hours

4.1 Workers shall not work in excess of the lesser of (a) the limits on regular and overtime hours allowed by local and national law, or (b) 60 hours a week on a regularly scheduled basis, including overtime. Only under extraordinary business circumstances, and where permitted by national and local law, may 72 hours a week be permitted as an absolute maximum.

4.2 Workers shall be guaranteed one day off every consecutive seven day period.

4.3 Overtime shall be voluntary only and workers shall be paid in accordance with national law.

5. Child Labour

5.1 No children younger than the greater of 15 years of age, or 14 where the local law allows such exception consistent with International Labour Organization (ILO) guidelines, or the minimum age established by national and local law.

5.2 In the event that child labour is found, the supplier should not terminate their employment but look for ways of remediation.

5.3 There shall be no new recruitment of child labour.

5.4 Children and young persons under 18 shall not be employed at night or in hazardous conditions.

 6. Equal Treatment

6.1 There shall be 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. Freedom of Association

7.1 Workers, without distinction, have the right to join or not to join trade unions, workers’ associations and bargain collectively.

7.2 The employer adopts an open attitude towards the activities of trade unions and their organizational activities.

7.3 Where this right is restricted by law, the supplier should facilitate the development of parallel means for independent and free association and bargaining such as a workers’ council.

8. Discipline

8.1 Deductions from wages as a disciplinary measure shall not be permitted.

8.2 All disciplinary measures shall be recorded.

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

Monitoring the ESC

The purpose of audits is to monitor, inspect and assess the implementation of the ESC.

All manufacturing and processing units are subject to random factory compliance monitoring. New suppliers are required to complete a self evaluation assessment on their sourcing principles and production capabilities, followed by an audit against the company’s ESP. Existing suppliers will be requested to submit an up to date social audit report supported by detailed remediation plans for non-compliances.

The company if required will use independent consultants with a local presence to verify the accuracy of the reporting and assess the progress on any remediation programme in place. Suppliers must ensure that access to all the factory premises is not restricted and must provide all the information requested by the auditors for verification. Suppliers will maintain on file, all documentation necessary to demonstrate compliance with the company’s ESP, it being acknowledged that all information provided will be used in the strictest confidence.

Environmental Policy:

S.T. Gifts Limited is a professional and environmentally conscious organisation, which acknowledges the impact that our operations may potentially have on the environment.  The clear objective for S. T. Gifts Limited is to minimise any impact on the environment by:

  • Preventing pollution, reducing waste and ensuring that wherever practical, measures are implemented to protect and preserve natural habitats, flora and fauna;
  • Considering the effects that our operations may have on the local community;
  • Taking action to eliminate or reduce, as far as practicable, any potentially adverse environmental impacts;
  • Promoting environmental awareness amongst our suppliers, contractors and partners by implementation of operational procedures;
  • Seeking to work in partnership with the community by behaving in a considerate and socially responsible manner;
  • Ensuring effective and expedient incident control, investigation and reporting

Management and supervisory staff have responsibilities for the implementation of the policy and must ensure that environmental issues are given adequate consideration in the planning and day-to-day supervision of all work.

S. T. Gifts Limited will fully comply with the duties placed upon it within the requirements of Statutory Legislation, whilst at all times complying with, as a matter of best practice, the requirements and duties set out within Approved Guidance as issued by the Environment Agency and other organisations.  As part of the S. T. Gifts Limited commitment to maintaining the highest levels of environmental management, it is the intention that S. T. Gifts Limited will work towards environmental management systems compliant with ISO14001.

All employees and sub-contractors are expected to co-operate and assist in the implementation of this policy, whilst ensuring that their own works, so far as is reasonably practicable, are carried out without risk to themselves, others or the environment.  This includes co-operating with management on any environment related matter.

S. T. Gifts Limited will take all practical steps to ensure that potential hazards and risks to the environment are identified and that suitable and effective prevent and control measures are implemented.  All employees will be provided with the necessary resources, equipment, information, instruction and training to fulfill the requirements of this policy.

EQUAL OPPORTUNITIES AND DIGNITY AT WORK policy

The Company is an equal opportunity employer and is fully committed to a policy of treating all of its employees and job applicants equally.

The Company will take all reasonable steps to employ, train and promote employees on the basis of their experience, abilities and qualifications without regard to race, colour, ethnic origin, nationality, national origin, religion or belief, sex, sexual orientation, gender reassignment, age, marital or civil partnership status or disability. The Company will also take all reasonable steps to provide a work environment in which all employees are treated with respect and dignity and that is free of harassment based upon an employee’s race, colour, ethnic origin, nationality, national origin, religion or belief, sex, sexual orientation, gender reassignment, age, marital or civil partnership status or disability. The Company will not condone any form of harassment, whether engaged in by employees or by outside third parties who do business with the Company, such as clients, customers, contractors and suppliers.

Employees have a duty to co-operate with the Company to ensure that this policy is effective in ensuring equal opportunities and in preventing discrimination, harassment or bullying. Action will be taken under the Company’s disciplinary procedure against any employee who is found to have committed an act of improper or unlawful discrimination, harassment, bullying or intimidation. Serious breaches of this equal opportunities and dignity at work statement will be treated as potential gross misconduct and could render the employee liable to summary dismissal.  Employees should also bear in mind that they can be held personally liable for any act of unlawful discrimination. Employees who commit serious acts of harassment may also be guilty of a criminal offence.

You should draw the attention of your line manager to suspected discriminatory acts or practices or suspected cases of harassment. You must not victimise or retaliate against an employee who has made allegations or complaints of discrimination or harassment or who has provided information about such discrimination or harassment. Such behaviour will be treated as potential gross misconduct in accordance with the Company’s disciplinary procedure. 

The Company will also take appropriate action against any third parties who are found to have committed an act of improper or unlawful harassment against its employees.

Recruitment, advertising and selection

The recruitment process will be conducted in such a way as to result in the selection of the most suitable person for the job in terms of relevant experience, abilities and qualifications. The Company is committed to applying its equal opportunities policy statement at all stages of recruitment and selection.

Advertisements will encourage applications from all suitably qualified and experienced people. When advertising job vacancies, in order to attract applications from all sections of the community, the Company will, as far as reasonably practicable:

1.   Ensure advertisements are not confined to those publications which would exclude or disproportionately reduce the numbers of applicants of a particular gender, sexual orientation, age, religion or racial group.

2.   Avoid prescribing any unnecessary requirements which would exclude a higher proportion of a particular gender, sexual orientation, age, religion or racial group or which would exclude disabled job applicants.

3.   Avoid prescribing any requirements as to marital or civil partnership status.

4.   Where vacancies may be filled by promotion or transfer, they will be published to all eligible employees in such a way that they do not restrict applications from employees of any particular gender, sexual orientation, age, religion or racial group or from employees with a disability.

The selection process will be carried out consistently for all jobs at all levels. All applications will be processed in the same way. The staff responsible for short-listing, interviewing and selecting candidates will be clearly informed of the selection criteria and of the need for their consistent application. Person specifications and job descriptions will be limited to those requirements that are necessary for the effective performance of the job. Wherever possible, all applicants will be interviewed by at least two interviewers and all questions asked of the applicants will relate to the requirements of the job. The selection of new staff will be based on the job requirements and the individual’s suitability and ability to do, or to train for, the job in question.

With disabled job applicants, the Company will have regard to its duty to make reasonable adjustments to work provisions, criteria and practices or to work premises in order to ensure that the disabled person is not placed at a substantial disadvantage in comparison with persons who are not disabled.

If it is necessary to assess whether personal circumstances will affect the performance of the job (for example, if the job involves unsociable hours or extensive travel), this will be discussed objectively, without detailed questions based on assumptions about race, colour, ethnic origin, nationality, national origin, religion or belief, sex, sexual orientation, gender reassignment, age, marital or civil partnership status, disability, children and/or domestic obligations.

Training and promotion

The Company will train all line managers in the Company’s policy on equal opportunities and in helping them identify discriminatory acts or practices or acts of harassment or bullying. Line managers will be responsible for ensuring they actively promote equal opportunity within the departments for which they are responsible.

The Company will also provide training to all employees to help them understand their rights and responsibilities in relation to dignity at work and what they can do to create a work environment that is free of bullying and harassment.

Where a promotional system is in operation, it will not be discriminatory and it will be checked from time to time to assess how it is working in practice. When a group of workers predominantly of one race, religion, sex, sexual orientation or age group or a worker with a disability appears to be excluded from access to promotion, transfer and training and to other benefits, the promotional system will be reviewed to ensure there is no unlawful discrimination

Terms of employment, benefits, facilities and services

All terms of employment, benefits, facilities and service will be reviewed from time to time, in order to ensure that there is no unlawful discrimination on the grounds of race, colour, ethnic origin, nationality, national origin, religion or belief, sex, sexual orientation, gender reassignment, age, marital or civil partnership status or disability.

Equal pay

The Company is committed to equal pay in employment. It believes its male and female employees should receive equal pay for like work, work rated as equivalent or work of equal value. In order to achieve this, the Company will endeavour to maintain a pay system that is transparent, free from bias and based on objective criteria.

Bullying and harassment

Bullying is offensive or intimidating behaviour or an abuse or misuse of power which undermines or humiliates an employee.

Harassment occurs where, on the ground of an employee’s race, colour, ethnic origin, nationality, national origin, religion or belief, sexual orientation, gender reassignment, age, marital or civil partnership status or disability, a person engages in unwanted conduct that:

  • has the purpose of violating the employee’s dignity at work, or of creating an intimidating, hostile, degrading, humiliating or offensive work environment for the employee; or
  • is reasonably considered by the employee to have the effect of violating his or her dignity at work, or of creating an intimidating, hostile, degrading, humiliating or offensive work environment for the employee, even if this effect was not intended by the person responsible for the conduct.

Harassment also occurs where, related to either the employee’s sex or that of another individual, a person engages in unwanted conduct that:

  • has the purpose of violating the employee’s dignity at work, or of creating an intimidating, hostile, degrading, humiliating or offensive work environment for the employee; or
  • is reasonably considered by the employee to have the effect of violating their dignity at work, or of creating an intimidating, hostile, degrading, humiliating or offensive work environment for the employee, even if this effect was not intended by the person responsible for the conduct.

In this scenario, the employee does not need to be the subject of the unwanted conduct for harassment to have occurred - for example, the conduct could be directed at nobody in particular or at someone other than the employee, including someone of the opposite sex.

Sexual harassment (as opposed to harassment related to gender) occurs where a person engages in any form of unwanted conduct of a sexual nature that:

  • has the purpose of violating the employee’s dignity at work, or of creating an intimidating, hostile, degrading, humiliating or offensive work environment for the employee; or
  • is reasonably considered by the employee to have the effect of violating his or her dignity at work, or of creating an intimidating, hostile, degrading, humiliating or offensive work environment for the employee, even if this effect was not intended by the person responsible for the conduct.

Conduct may be harassment whether or not the person intended to offend. Something intended as a “joke” or as “office banter” may offend another person. This is because different employees find different levels of behaviour acceptable and everyone has the right to decide for themselves what behaviour they find acceptable to them.

Behaviour which a reasonable person would realise would be likely to offend an employee will always constitute harassment without the need for the employee having to make it clear that such behaviour is unacceptable, for example, touching someone in a sexual way. With other forms of behaviour, it may not

always be clear in advance that it will offend a particular employee, for example, office banter and jokes. In these cases, the behaviour will constitute harassment if the conduct continues after the employee has made it clear, by words or conduct, that such behaviour is unacceptable to him or her. A single incident can amount to harassment if it is sufficiently serious.

Harassment also occurs where, on the ground of the employee’s rejection of or submission to unwanted conduct of the kind specified above, a person treats the employee less favourably than he or she would treat him or her had he or she not rejected, or submitted to, the unwanted conduct.

Examples

Bullying and harassment may be verbal, non-verbal, written or physical. Examples of unacceptable behaviour include, but are not limited to, the following:

  • unwelcome sexual advances, requests for sexual favours, other conduct of a sexual nature
  • subjection to obscene or other sexually suggestive or racist comments or gestures
  • the offer of rewards for going along with sexual advances or threats for rejecting sexual advances
  • jokes or pictures of a sexual or racial nature
  • demeaning comments about an employee’s appearance
  • questions about a person’s sex life
  • the use of nick names related to an employee’s sex, sexual orientation, gender reassignment, race, religion, age or disability
  • picking on or ridiculing an employee
  • isolating an employee or excluding him or her from social activities or relevant work-related matters.

Reporting complaints

All allegations of discrimination or harassment will be dealt with seriously, confidentially and speedily. The Company will not ignore or treat lightly grievances or complaints of discrimination or harassment from members of a particular race, colour, ethnic origin, nationality, national origin, religion or belief, sex, sexual orientation or age or from employees who have undergone gender reassignment, are married, have entered into a civil partnership or have a disability.

With cases of harassment, while the Company encourages employees who believe they are being harassed to notify the offender (by words or by conduct) that his or her behaviour is unwelcome, the Company also recognises that actual or perceived power and status disparities may make such confrontation impractical.

If an employee wishes to make a complaint of discrimination or harassment, whether against the Company, a fellow employee or a third party, the employee should follow the following steps:

1.   First of all, report the incident of discrimination or harassment to your line manager. If you do not wish to speak to your line manager, you can instead speak to an alternative manager or to a member of the Human Resources Department.

2.   Such reports should be made promptly so that investigation may proceed and any action taken expeditiously.

3.   All allegations of discrimination or harassment will be taken seriously. The allegation will be promptly investigated and, as part of the investigatory process, you will be interviewed and asked to provide a written witness statement setting out the details of your complaint.  Confidentiality will be maintained during the investigatory process to the extent that this is practical and appropriate in the circumstances. However, in order to effectively investigate an allegation, the Company must be able to determine the scope of the investigation and the individuals who should be informed of or interviewed about the allegation. For example, the identity of the complainant and the nature of the allegations must be revealed to the alleged harasser or discriminator so that he or she is able to fairly respond to the allegations. The Company reserves the right to arrange for another manager to conduct the investigation other than the manager with whom you raised the matter.

4.   Once the investigation has been completed, you will be informed in writing of the outcome and the Company’s conclusions and decision as soon as possible. The Company is committed to taking appropriate action with respect to all complaints of discrimination or harassment which are upheld.

5.   You will not be penalised for raising a complaint, even if it is not upheld, unless your complaint was both untrue and made in bad faith.

6.   If your complaint is upheld and the harasser or discriminator remains in the Company’s employment, the Company will take all reasonable steps to ensure that you do not have to continue working alongside him or her if you do not wish to do so. The Company will discuss the options with you.

7.   If your complaint is not upheld, arrangements will be made for you and the alleged harasser or discriminator to continue or resume working and to repair working relationships.

Alternatively, you may, if you wish, use the Company’s grievance procedure to make a complaint. 

Any employee who is found to have discriminated against or harassed another employee in violation of this policy will be subject to disciplinary action under the Company’s disciplinary procedure. Such behaviour may be treated as gross misconduct and could render the employee liable to summary dismissal. In addition, line managers who had knowledge that such discrimination or harassment had occurred in their departments but who had taken no action to eliminate it will also be subject to disciplinary action under the Company’s disciplinary procedure.

Monitoring equal opportunity and dignity at work

The Company will regularly monitor the effects of selection decisions and personnel and pay practices and procedures in order to assess whether equal opportunity and dignity at work are being achieved. This will also involve considering any possible indirectly discriminatory effects of its working practices. If changes are required, the Company will implement them. The Company will also make reasonable adjustments to its standard working practices to overcome barriers caused by disability.