At Dowlis Inspired Branding Limited, we are fully committed to conducting our business operations in a socially responsible and ethical manner. Our Ethical Trading Policy serves as a comprehensive guideline outlining our unwavering dedication to promoting fair and ethical practices across our supply chain. We consistently adhere to all legal requirements and regulations within the European Union (EU) and strive to surpass these standards whenever possible. Furthermore, our practices are closely aligned with the Ethical Trading Initiative (ETI) Base Code. This policy articulates the minimum corporate social responsibility standards that Dowlis expects its chosen suppliers to both achieve and uphold.

Management Systems and Code Implementation

1. Implementation and Maintenance: Dowlis' suppliers are expected to establish and maintain robust systems to ensure compliance with this policy.
2. Accountability: Our suppliers must designate a senior member of their management team who will be accountable for adhering to the policy.
3. Communication: Our suppliers are obligated to effectively communicate this policy to all their employees and extend it to their own suppliers.
4. Supply Chain Alignment: The principles outlined in this code must be extended throughout our suppliers' entire supply chain.

Forced Labour

1. Zero Tolerance: Dowlis unequivocally condemns any form of forced, bonded, or involuntary prison labor.
2. Worker Freedom: Workers should never be compelled to deposit their identity papers with their employer, and they must have the freedom to leave their employer after providing reasonable notice.

Freedom of Association

1. Collective Rights: We firmly uphold the rights of freedom of association and collective bargaining, ensuring that workers have the liberty to join or establish trade unions without any discrimination.
2. Open Attitude: Dowlis encourages our suppliers to maintain an open attitude towards trade unions and their activities.
3. Non-Discrimination: Workers' representatives should not face discrimination and must be granted access to fulfill their representative functions in the workplace.
4. Facilitation of Freedom: In cases where legal restrictions exist, we expect our suppliers to facilitate the development of independent and free association and bargaining methods.

Health and Safety

1. Safe Working Conditions: Dowlis' suppliers must provide a safe and hygienic working environment, taking appropriate steps to minimize hazards associated with the industry.
2. Training: Workers must receive regular, documented health and safety training, especially for new or reassigned employees.
3. Facilities: Access to clean toilet facilities, potable water, and, where necessary, sanitary food storage facilities must be provided.
4. Accommodation: If accommodation is offered, it must be clean, safe, and meet the basic needs of the workers.
5. Management Responsibility: Companies adhering to this code must designate a senior management representative responsible for health and safety.

Child Labour and Young Workers

1. Child Labor Prohibition: Dowlis categorically rejects child labor in any part of our supply chain.

Rates of Pay

1. Wage Standards: Wages and benefits for a standard working week throughout our supply chain must meet at least the national legal standards or industry benchmark standards, whichever is higher. In all cases, wages should cover basic needs and provide discretionary income.
2. Transparency: Suppliers must ensure that all employees receive clear and understandable information regarding their employment conditions, including wages, before commencing employment.
3. Deductions: Deductions from wages as a disciplinary measure are strictly prohibited unless permitted by national law and with the worker's explicit consent, and all such measures must be documented.

Working Hours

1. Limiting Excess: Our suppliers must ensure that working hours do not exceed legal requirements or benchmark industry standards, whichever offers greater protection to employees.
2. Overtime Regulation: Workers should not regularly work more than 48 hours per week and must receive at least one day off for every 7-day period. Overtime should be voluntary, not exceed 12 hours per week, not be demanded regularly, and always be compensated at a premium rate.

Discrimination

1. Non-Discrimination: Discrimination based on race, caste, national origin, religion, age, disability, gender, marital status, sexual orientation, union membership, or political affiliation is strictly prohibited at Dowlis.

Regular Employment

1. Legal Employment Relationships: Our suppliers must establish recognized employment relationships with their workers based on national law and practices.
2. Avoiding Obligations: Suppliers must not use labor-only contracting, sub-contracting, home-working arrangements, or apprenticeship schemes to evade labor or social security obligations. Any sub-contracting must be pre-approved by Dowlis, and proper control processes must be in place.

Discipline

1. Warranted Discipline: Discipline must be warranted, and no form of harsh or inhumane treatment will be tolerated. Physical abuse, threats, harassment, or intimidation in any form is strictly prohibited.

Entitlement to Work, Migrant/Agency Labor

1. Legal Employment Validation: Our chosen suppliers must ensure that all workers, including employment agency staff, have the legal right to work and validate their status through original documentation.
2. Agency Staff Registration: Employment agencies used by our suppliers should only provide registered workers.
3. Agency Control: Suppliers must establish processes for adequate control over agencies in accordance with relevant legislation.

Environment

1. Environmental Compliance: Dowlis must be promptly informed of any environmental law breaches.
2. Environmental Improvement: Suppliers should continually strive to enhance their environmental performance and, at a minimum, adhere to local and international laws and regulations.

Important Note: This code represents the minimum standards, and we encourage companies to exceed these standards where possible. Companies applying this code are expected to comply with national and other applicable laws, prioritizing provisions that offer greater protection.

David Lynn, Director
January 2024