Comparison of Codes:

ETI Base Code; SA8000; GSCP

Comparison of Codes: Reference ETI Base Code, SA8000 & GSCP

SEDEX CODE COMPARISON – Introduction to the Codes

ETI – Ethical Trade Initiative:

The Ethical Trading Initiative (ETI) is a ground-breaking alliance of companies, trade unions and voluntary organisations which promotes the implementation of corporate codes of practice which cover supply chain working conditions. Their ultimate goal is to ensure that the working conditions of workers producing for the UK market meet or exceed international labour standards.

The Ethical Trading Initiative (ETI) produces guidelines aimed at the promotion and the improvement of ethical trade. The code of conduct has been elaborated in the UK by an alliance of companies, non-governmental organisations (NGOs) and organisations.

It is composed of two key elements: the ETI Base Code and the accompanying Principles of Implementation. ETI has developed a code of labour practice - the 'Base Code' - reflecting the most relevant international standards with respect to labour practices which will be used as the basis of its work under the form of 9 statements.

ETI member companies are expected to adopt the Base Code, or to adopt their own code so long as it incorporates the Base Code. The Base Code, which is accompanied by a set of general principles concerning implementation, provides a foundation for ETI's philosophy of learning.

SA8000:

SAI is a non-governmental, international, multi- organization dedicated to improving workplaces and communities. It does this work with two principal types of tools; developing and implementing socially responsible standards, the first of which was SA8000; training and capacity building-- about specific standards and management systems for implementing social standards-- for workers, managers and auditors throughout the supply chain.

SA8000 is an auditable certification standard based on international workplace norms of International Labour Organisation (ILO) conventions, the Universal Declaration of Human Rights and the UN Convention on the Rights of the Child. This standard is the benchmark against which companies and factories measure their performance. Those seeking to comply with SA8000® have adopted policies and procedures that protect the basic human rights of workers.

There are a series of documents available to support auditors and implementers of the SA8000® Standard; these are: The SA8000® Guidance Document; The SA8000®:2008 Drafters' Notes; and the SA8000® Frequently Asked Questions (FAQs).

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Comparison of Codes: Reference ETI Base Code, SA8000 & GSCP

GSCP (Global Social Compliance Program):

The Global Social Compliance Programme is a business-driven programme for the continuous improvement of working and environmental conditions in global supply chains. The GSCP was created by and for global buying companies wanting to work collaboratively on improving the (social and environmental) of their often- shared supply base. To this end, these companies are working on harmonizing existing efforts to deliver a shared, global and sustainable approach based on consensus and best existing practice, to promote upward convergence and reduce duplication. The GSCP Reference tools, including the Reference Code used in this comparison, are the product of the identification of best existing practices in operating monitoring systems, and provide a common base of high-level labour requirements applicable across sectors and geographies.

The GSCP Reference Code is not a standard and the GSCP is not a monitoring system. The Programme and its tools are used by companies as a basis to develop their own supplier codes of conduct or as a benchmark for schemes owners (including initiatives or standard-setting bodies) to assess and improve their existing requirements for these to reflect best existing practice. The Reference Code is complemented by other GSCP Reference tools (available open source on www.gscpnet.com) which set out additional requirements for auditing (Reference Process and Methodology), for auditing bodies and auditors (Reference tool for Auditing Competence) and Social Performance Management Systems.

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Comparison of Codes: Reference ETI Base Code, SA8000 & GSCP

ETI Base code SA 8000 GSCP Intention of Code / Audit - Auditable Labour Standards Code – not - Third party accredited certification - Reference code for benchmarking Method certification scheme. scheme. - conducted by any parties as - Audits conducted by any parties as - Audits conducted by approved SA8000 agreed by the supply chain. agreed by the supply chain. auditors

Structure and General The ETI Base code is structured as The SA8000 code is structured as The GSCP Reference code is structured comments follows: follows: as follows: 1. ETI Base Code – 9 elements 1. Purpose and scope of the code 1.Objective 2. Appendices 2. Normative elements and their 2. Scope - Relevant international standards - interpretation – ILO conventions 3. Structure and Annexes UN Universal Declaration of Human 3. Definitions – of multiple terms 4. Compliance with international labour Rights, ILO etc. 4. Social standards and national legislation - - Definitions (specifically ‘a child’) Requirements(SA8000) – 9 elements including ILO conventions 5. Reference code – 7 elements

Differences (a) Code refers to ‘The Employer’. (a) Code refers to ‘The Company’. (a) Reference Code refers to ‘The Supplier’.

ILO Conventions / - Universal Declaration of Human Rights - ILO Code of Practice on HIV/AIDS and the This reference code shall not be used to International Standards - Guidelines for Multinational Enterprises World of Work prevent international labour standards or developed by the Organisation for - Universal Declaration of Human Rights national and/or local legislations from being Economic Co-operation and Development - The International Covenant on Economic, exceeded. (OECD) Social and Cultural Rights - Convention on the - The International Covenant on Civil and Rights of the Child Political Rights - The United Nations Convention on the Rights of the Child - The United Nations Convention on the Elimination of All Forms of Discrimination Against Women - The United Nations Convention on the Elimination of All Forms of Racial Discrimination

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Comparison of Codes: Reference ETI Base Code, SA8000 & GSCP

0 Scope and Objective (a) The code constitutes minimum not (a) The Reference code constitutes maximum standards. minimum not maximum standards (appears in ‘Compliance with international labour standards and national legislation’ section).

(b) All relevant legislation will apply to (b) All relevant legislation will apply to (b) ILO/national standard/local companies. companies (appears in ‘Compliance with legislation/GSCP Reference code will apply international labour standards and national (appears in ‘Compliance with international legislation’ section). labour standards and national legislation’ section). (c) Companies will apply the provision (c) Companies will apply the provision (c) Companies will apply the provision which affords the highest protection. which is most favourable to workers which affords the highest protection (appears in ‘Compliance with international (appears in ‘Compliance with international labour standards and national legislation’ labour standards and national legislation’ section). section). Additions Additions The code intends to protect and empower all Requirements in this Reference code apply to personnel within a company’s scope of control the whole supply chain (appears in ‘Scope’) and influence as well as control of its suppliers, - The principles and requirements should be subcontractors and sub-suppliers and home respected and implemented (appears in workers (appears in ‘Purpose and Scope’). ‘Compliance with international labour standards and national legislation’ section).

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Comparison of Codes: Reference ETI Base Code, SA8000 & GSCP

ETI Base code SA 8000 GSCP 1 Employment is freely (a) There is no forced, bonded or (a) The company shall not engage in or (a)1. All work must be conducted on a chosen involuntary prison labour. support the use of forced or compulsory voluntary basis with no threat of any prison labour (as defined in C29). penalty or sanctions. (a)2. No forced or compulsory labour in all its forms, including prison labour (as defined in C29). (a)3. Bonded labour prohibited. (b) Workers are not required to lodge (b)1. Personnel are not required to pay (b)1. Workers are not required to lodge deposits or identity papers. deposits or lodge identity papers. deposits or identity papers. (b)2. The company and any entity (b)2. Employers should not withhold any supplying labour should not withhold any part of the worker’s salary (outside a legal part of the worker’s salary, benefits, contractual agreement). property or documents. (c) Workers are free to leave their (c) Personnel are free to terminate their (c) Workers are free to terminate their employer after reasonable notice. employment provided they give employment after reasonable notice. reasonable notice. Additions Additions - Personnel have a right to leave their - Workers have a right to leave their workplace workplace at the end of their shift. at the end of their shift. - The company and any entity supplying - Suppliers must not permit or encourage debt labour shall not engage nor support by e.g. recruitment fees, fines. trafficking. ILO Convention 29, 105 and ILO Convention 29, 105 ILO Convention 29, 105 – Fundamental Recommendation 35 principle

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Comparison of Codes: Reference ETI Base Code, SA8000 & GSCP

ETI Base code SA 8000 GSCP 2 (a) Workers have the right to join or form (a) All personnel have the right to join, (a) Workers have the right to join or form and the right to collective trade unions and to bargain collectively. organise or form trade unions and to trade unions and to bargain collectively. bargaining are respected bargain collectively. (b) Members or representatives are not (b) Any workers engaged in collective (b) Any workers engaged in trade unions discriminated against. bargaining, are not subject to any (incl. worker representation) and harassment, discrimination, intimidation collective bargaining, are not subject to or retaliation. any discrimination or otherwise (c) The employer must adopt an open (c) The company shall not interfere with (cpe)n aSliuspepd.liers shall not interfere, obstruct attitude. the establishment, functioning or or prevent such activities. administration of the collective bargaining (interfere includes: includes company interference in workers’ organizations and collective bargaining). (d) Where the right is restricted by law, (d) Where the right is restricted by law, (d) Where the law is restrictive, supplier the employer facilitates a parallel means. workers are allowed to freely elect their shall not hinder alternative form of own representatives. independent and free worker representation and negotiation. (e) Members shall have access to carry (e) Company shall ensure that (e) Suppliers shall give representatives out trade union function in the workplace. representatives have access to their access to the workplace in order to carry members in the work place. out their function. Additions - The company shall effectively communicate this right to workers. ILO Convention 87, 98, - core conventions ILO Convention 98, 87, 135 ILO Convention 87, 98 – Fundamental ILO Convention 135, 154 and principles Recommendation 143 – relevant to ETI ILO Convention 135 - other applicable standards

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Comparison of Codes: Reference ETI Base Code, SA8000 & GSCP

ETI Base code SA 8000 GSCP 3 Working conditions are (a) A safe and hygienic working (a) A safe and hygienic working (a) A safe and hygienic working safe and hygienic environment is to be provided. environment is to be provided. environment is to be provided. (b) Steps are to be taken to prevent (b)1. Steps are to be taken to prevent (b)1. Steps are to be taken to prevent accidents arising out of, associated with, accidents arising out of, associated with, accidents arising out of, associated with, or occurring in the course of work. or occurring in the course of work. or occurring in the course of work. (b)2. Establish systems to detect, avoid (b)2. Provide adequate safeguards and respond to potential threats & against fire. maintain written records of all accidents. (b)3. Suppliers shall establish and follow a clear set of procedures regulating H&S. (c) Workers shall receive regular and (c) Workers shall receive regular and (c) Workers shall receive regular and recorded H&S training. recorded H&S training. recorded H&S training. (d) Clean toilet facilities and potable water (d) Clean toilet facilities and potable water (d) Clean toilet facilities and potable water to be provided & if appropriate sanitary to be provided & if appropriate sanitary to be provided & if appropriate sanitary food storage facilities. food storage facilities. food storage facilities. (e) Accommodation shall be clean, safe & (e) Accommodation shall be clean, safe & (e) Accommodation shall be clean, safe & hygienic. hygienic. hygienic. (f) There should be a senior management (f) There should be a senior management (f) There should be a senior management representative for H&S. representative for H&S. representative for H&S. Additions Additions - Appropriate PPE, first aid and follow-up - Appropriate PPE provided by suppliers and medical treatment for accidents at the workers access to medical assistance and company's expense shall be provided. facilities. - Assess risk for new & expectant mothers & - Adequate fire safety, safe buildings and ensure risk is reduced. equipment. - Workers have the right to remove - Workers to be trained in waste management themselves from imminent danger without (handling & disposal of chemicals & other permission. dangerous materials). - Suppliers to provide access to adequate medical assistance & facilities. ILO Convention 155, 190, 183 and ILO Convention 155, 183 and ILO Convention 155, 161, 164 - other Recommendation 164 – relevant to ETI recommendation 164 applicable standards

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Comparison of Codes: Reference ETI Base Code, SA8000 & GSCP

ETI Base code SA 8000 GSCP 4 shall not be (a)1. No new recruitment of child labour. (a) The company shall not engage nor (a)1. No new recruitment or exploitation of used (a)2. These policies and procedures shall support the use of Child labour. child labour. conform to the provisions of the relevant (a)2. Suppliers shall comply with national ILO standards. min age, age of completion of compulsory education or otherwise specified exceptions however no less than 15, whichever is higher. By ILO 138 exception 14 may apply. (b) Develop, participate & contribute to (b) Effectively establish & communicate (b) Sensitive and satisfactory solution with policies and programmes for transition procedures for remediation, with child's best interest first. enabling them to attend and remain in adequate financial and other support to education. remain in school. (c) Young workers not to be employed at (c) The company shall not expose (c) Young workers not to be employed at night or in hazardous conditions. children or young workers to night work, night or in hazardous conditions which any hazardous conditions or work unsafe compromise their health, safety, moral to mental/physical development. integrity, physical, mental, spiritual, moral or social development. Additions Additions - The children or young workers shall not be - This applies for children working both exposed to these conditions in or outside of the directly and indirectly for the supplier. work place. - Work only outside of school hours, no more than combined 10 hours/day (including school, work and travel). - Young workers shall work for no more than 8 hours/day. ILO Conventions 138, 182 and ILO Convention 138, 182 and ILO Convention 138, 182 – Fundamental Recommendation 146, 190 recommendation 146 principles ILO Convention 190 - other applicable standards

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Comparison of Codes: Reference ETI Base Code, SA8000 & GSCP

ETI Base code SA 8000 GSCP 5 Living wages are paid (a) National legal standards/industry (a) Living wage stated requirement, (a) National legal standards/industry benchmark standards (income should meet national legal standards/industry benchmark standards/collective bargaining basic needs & provide discretionary benchmark standards (income should meet agreements (income should meet basic income). basic needs & provide discretionary needs & provide discretionary income for income). workers and their families) whichever is more favourable. (b) Written & understandable employment (b) Wages & benefits are written & detailed (b) Written & understandable employment conditions in respect to wages before clearly for each payment period. conditions in respect to wages before employment & each payment period. employment & each payment period.

(c) No deductions as a disciplinary means (c) No deductions as a disciplinary means (c) No deductions as a disciplinary means (except legal deductions). (except legal deductions & freely (outside legal deductions). negotiated collective bargaining agreement). (d) All disciplinary measures should be (d) All disciplinary actions recorded recorded. (appears in ‘Discrimination Harassment and Abuse’ section). Additions Additions - Only disciplinary deductions with the - Only disciplinary deductions only when both; expressed permission of the worker concerned. permitted by law and collective bargaining. - Paid in cash/check (convenient for workers).

ILO Convention 100, 111, 81, 122 and ILO Convention 100 ILO Convention 100 – Fundamental principle Recommendation 90 & 111 – Core ILO Convention 95, 131, 135, 85 - other conventions applicable standards ILO Convention 131 – Relevant to ETI

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Comparison of Codes: Reference ETI Base Code, SA8000 & GSCP

ETI Base code SA 8000 GSCP 6 Working hours are not (a) Working hours shall comply with (a) The company shall comply with national (a) Suppliers shall set working hours that excessive national law & industry benchmark law & industry benchmark standards comply with national law & industry standards (whichever provides more (whichever provides more protection) benchmark standards (whichever provides protection). including public holidays. more protection). (b) No more than 48 hours per week. (b) No more than 48 hours per week. (b) No more than 48 hours per week excluding overtime. (c) Overtime voluntary and no more than (c) Overtime is voluntary and no more (c) Overtime shall be voluntary and no 12 hours/week, not regular. than 12 hours/week, not regular. more than 12/week, not regular. (d) One day off for every 7 day period. (d) One day off for every 7 day period. (d) One day off for every 7 day period. (e) Overtime at premium rate. (e) Overtime shall be paid at a premium (e) Overtime shall be paid at a premium (appears in ‘Remuneration’ section). (appears in ‘Wages, benefits and terms of Employment’ section). Additions Additions - exception to (d) if national law allows work - Suppliers will respect workers right to public time averaging and collective bargaining and annual holidays. agreement is in place. - Respect workers right to breaks during work - If short-term business needs must still shifts. comply with collective bargaining agreement. ILO Convention 175 – Relevant to ETI ILO Convention 1, 116 ILO Convention 1, 14, 116 – other applicable standards 7 No discrimination is (a) There is no discrimination, on hiring, (a) No engagement in discrimination on (a) No engagement, support or tolerance practised compensation, promotion, termination, or hiring, compensation, promotion, of discrimination on hiring, compensation, retirement etc. termination, or retirement etc. promotion, termination, or retirement etc. Additions Additions - No interference with the exercise of - Suppliers shall respect equal opportunities. personnel's rights to observe practices which - Base all terms & conditions of employment on could give rise to discrimination. an individual’s ability to do the job. - The company shall not subject any personnel to pregnancy/virginity tests. ILO Convention 159 and Recommendation ILO Convention – 100, 111, 102, 131, 159, ILO Convention 111 – Fundamental principle 168 – relevant to ETI 169

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Comparison of Codes: Reference ETI Base Code, SA8000 & GSCP

ETI Base code SA 8000 GSCP 8 Regular employment is (a) As much as possible, work must be (a) Work must be performed on a provided performed on a recognised employment recognised employment relationship relationship (according to law). (according to law) (appears in 'Wages, Benefits and Terms of Employment’ section). (b)1. Obligations to employees shall not (b)1. Obligations to employees shall not (b)1. Obligations to employees shall not be avoided by: labour-only contracting- be avoided by:- labour-only contracting- be avoided by:- labour-only contracting- sub-contracting- home-working sub-contracting- home-working false- sub-contracting- home-working agreements - apprenticeship schemes- apprenticeship schemes- where there is agreements - apprenticeship schemes- or where there is no real intent to impart no real intent to impart skills or repeated where there is no real intent to impart skills or provide regular employment. fixed term contracts (appears in skills or provide regular employment (b)2. Obligations include meeting Labour ‘Remuneration’ section). (appears in ‘Wages, Benefits and Terms of and social security laws. (b)2. The company should supply all Employment’ section). legally required benefits (appears in (b)2. Supply all legally required wages, ‘Remuneration’ section). overtime pay, benefits and paid leave which respectively meet or exceed legal min. and/or industry benchmark standards and/or collective agreements, whichever is higher (appears in ‘Wages, Benefits and Terms of Employment’ section). ILO Convention 177 and Recommendation ILO Convention 177 ILO Convention 184 - other applicable 184 – Relevant to ETI standards

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Comparison of Codes: Reference ETI Base Code, SA8000 & GSCP

ETI Base code SA 8000 GSCP

9 No harsh or inhumane (a) There shall be no physical or threat of (a)1. No bullying/harassment/abuse of (a) No bullying/harassment/abuse of treatment is allowed abuse nor harassment, verbal abuse or any kind (appears in ‘Discrimination’ any kind (appears in ‘Discrimination, other forms of intimidation. section). Harassment and Abuse’ section). (a)2. No harsh or inhumane treatment (appears in ‘Disciplinary Practices’ section). Additions Additions - Personnel are to be treated with respect & -Workers are to be treated with respect & dignity (appears in ‘Disciplinary Practices’ dignity (appears in’ Discrimination, section). Harassment and Abuse’ section). - Written disciplinary procedures established and effectively communicated (appears in ‘Discrimination, Harassment and abuse ’section) 10 Management systems NIL Additions NIL - Policy. - Management Representative. - SA8000 Worker Representative. - Management Review. - Planning & Implementation. - Control of Suppliers, Sub-contractors and Sub-suppliers. - Addressing Concerns and Taking Corrective Action. - Outside Communication and . - Access for Verification and Records.

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Comparison of Codes: Reference ETI Base Code, SA8000 & GSCP

Legend:

Indicates each comment. Each letter (across all three codes) indicates an (a) agreement. Where a single ETI paragraph (a)1. includes more than one comment, the (a)2. comments have been split There shall be no physical Similarities (Arial Font) Personnel are to be treated Additions (Times New Roman Font) Where the comment is detailed under (Disciplinary Practices section) a different section of the code (Italics).

This Code Comparison Document has been produced by Sedex to give members guidance on the scope of 3 common codes (ETI Base Code, SA8000 and GSCP Reference Code). The author has used interpretation to simplify and align the language used by these codes. Hence opinions expressed in this document are the subjective opinions of Sedex and do not necessarily represent the opinions of other companies referred to in this document. The inclusion or reference to external companies or codes does not constitute endorsement, recommendation, or approval of those companies, codes or their contents. This document bears no responsibility for the accuracy, legality or content of the external parties or for the content of their codes and publications. The document is not designed for compliance, rather a tool to see the overlap of requirements for the codes. Please see the individual websites for the full codes: 1. ETI Base Code – www.eti.org.uk 2. SA8000 - www.sa-intl.org 3. GSCP Reference Code – www.gscpnet.com Material in this document, including text and images, is protected by copyright. It may not be copied, reproduced, republished, downloaded, posted, broadcast or transmitted in any way except for your own personal, non-commercial use. Please note these materials may be changed without notice.

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