1. About this policy

1.1 Employees of Incodia International limited (hereinafter referred to as the “Company”), represent the Company and are expected to act in a manner that will enhance its reputation. This policy applies to all persons working for us or on our behalf in any capacity, including; employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third party representatives and business partners (collectively referred to as “Employees”).

1.2 Social Compliance is a continuing process in which organisations endeavour to protect the health and safety and rights of; employees, the community in which we operate, the environment in which we operate and the lives and communities of workers in our supply and distribution chains. The Association of Professional Social Compliance Auditors define Social Compliance as “Looking at wages and benefits, labour rights, discrimination against gender or vulnerable groups, health and emergency planning”. Social Compliance may also be referred to as sustainability, which includes ethics (or the treatment of people and animals), the environment, and the economy.

2. Objective

2.1 The objective of the social compliance audit is to ensure that:
(a) Working conditions are in compliance with local country laws and Incodia’s compliance standards
(b) No serious infractions are being committed by locations that produce Incodia or it’s clients products or materials.

2.2 In the event that local country laws are different from the Incodia compliance standards, Incodia expects all locations to meet whichever is more stringent.

2.3 Our Social Compliance Policy aims to improve both our social and environmental impact in the communities that we do business with throughout the world. While Incodia recognizes that there are different legal and cultural environments in which we operate throughout the country, the company’s Social Compliance Policy sets forth the basic requirements all locations must meet in order to do business. Incodia strongly encourages contractors, agents, and suppliers to exceed the Code of Conduct requirements and to promote best practices and continuous improvement throughout. Our goal is to use the Code of Conduct and audit results as an integral part of our supply chain strategy, influencing how we work now and in the future.

3. Scope

3.1 This procedure applies to all Employees of the Company.

4. Principles

4.1 Incodia ensures the following for all employees:

(a) Compensation & Benefits: Incodia and it’s associates shall provide wages, overtime compensation and benefits at not less than the minimum levels required by applicable laws and regulations or which are consistent with the prevailing local industry levels, whichever is higher. If local laws do not provide for overtime pay, suppliers will pay at least regular wages for overtime work.

(b) Working Hours: Incodia and it’s associates shall maintain employee work hours in compliance with the local standards and applicable laws of the jurisdictions. If local and/nor national regulations regarding the number of maximum overtime hours that may be worked by individual workers do not exist, then the working hours should not regularly exceed 60 hours per week consisting of a maximum of 48 hours of regular hours and 12 hours of overtime. One day off in every seven days should be given. Incodia will not use suppliers who regularly require workers to work hours in excess of the statutory requirements.

(c) Child Labour: Incodia respects the right of children to development and education. Exploitation of child labour is totally unacceptable. No person shall be employed at an age younger than the legal minimum age for working, 16 years of age. Employment of any individual below 16 years of age is strictly prohibited. In general, all employees under the age of 18 must: not be employed in hazardous work; must not work night shifts; and are entitled to more breaks than adults.

(d) Forced Labour: The use of forced or involuntary labour will not be tolerated by Incodia. Incodia will not work with suppliers who directly or indirectly use in any manner forced labour, indentured labour, bonded labour or prison labour.

(e) Human Trafficking: Incodia shall maintain and commit to maintaining a work environment that is free from human trafficking. Incodia will not tolerate employment practices that include the recruitment, transportation, transfer, harbouring or receipt of persons or through the use of force or the threat of force or through other forms of coercion, abduction, fraud, deception, abuse of power or by giving or receiving payments or benefits to achieve the consent of a person having control over another person for the purpose of exploitation.

(f) Non-discrimination, Harassment & Disciplinary Practice: Incodia recognizes that cultural differences exist and different practices apply in various jurisdictions; however, the terms and conditions of employment should be based on an individual’s ability to do the job, not on the basis of race, colour, religion, sex, age, physical ability, national origin, or any other protected characteristic. Workers should be treated with respect and dignity. In terms of disciplinary practices, they should be fair, arbitrary and effective. Employees of Incodia and it’s clients must not be exposed to physical punishment, threats of violence or physical, sexual, psychological or verbal harassment or maltreatment.

(g) Freedom of Association: Incodia and it’s associates should respect the rights of their employees to choose to associate with or not associate with or to establish any lawful organization including labour organizations.

(h) Health & Safety: Incodia and it’s associates must provide their employees with safe and healthy working environment, and where provided, a safe and healthy living environment. They shall comply with all applicable worker safety laws and regulations which includes: Building Integrity, Occupational Safety, Occupational Injury & Illness, Emergency Preparedness, Machine Safeguarding, Chemical Safety, Sanitation, Food & Dormitory.

(i) Environmental: Incodia and it’s associates shall comply with all applicable environmental laws and regulations. This shall include having processes in place to ensure compliance with those regulations relating to the handling, recycling, and disposal of dangerous or hazardous materials. Incodia favours suppliers and customers that share its commitment to sustainable business practices.

(j) Security: Incodia and it’s associates will maintain adequate security at all production and warehousing facilities and implement supply chain security procedures designed to prevent the introduction of non-manifested cargo into outbound shipments. Each Supplier facility must have written security procedures to document proof of adequate security controls.

(k) Gift & Gratuity Policy: Incodia employees are prohibited from soliciting or accepting any gifts, gratuities or other monetary incentives that are designed to improperly influence business decisions or as a condition of doing business. Employees have an affirmative duty to report any such request or demand immediately to Incodia. Certain business courtesies are not prohibited. Employees may accept gifts that are infrequent and nominal in value so long as the receipt of these gifts does not suggest a conflict of interest or give the appearance of an improper attempt to influence business decisions. We expect our employees to adhere to these gift giving guidelines.

5. Consequences

5.1 Failure to comply with the above procedures may result in disciplinary action and legal action being taken wherever appropriate.

Document Classification: Public

Version: V2

Approval Date: 24^th April 2020

Data Retention

We will normally keep your personal data for 10 years after your last interaction with us, or our Website.  If we consider that you are no longer an active user of our Website or our services we may delete your personal data sooner than this.

We expect to contact you at least every two years to ensure you are still happy to hear from us according to the preferences you have provided to us.

Transfer of your personal data outside of Europe

To provide our services to you, we may transfer personal data to our trusted service provider(s).  We have taken proper steps to ensure that it is protected in accordance with this Privacy Policy and applicable privacy laws.

Some of our Suppliers and Partners are located in regions outside of Europe. If you agree to us providing your details to our Suppliers or Partners, your data may be transferred to the relevant one to satisfy your requirements.

Changes to this privacy policy

Privacy laws and practice are constantly developing and we aim to meet high standards.  Our policies and procedures are, therefore, under continual review. We may, from time to time, update our security and privacy policies.  If we want to make any significant changes in how we will use your personal data we will contact you directly and, if required, seek your consent.

We will ensure our Website has our most up to date policy and suggest that you check this page periodically to review our latest version.

Updating and correcting personal data

You may update or correct your personal data by contacting us in writing or by telephone and asking us to do it for you. Please include your name and/or email address when you contact us as this helps us to ensure that we accept amendments only from the correct person.

We encourage you to promptly update your personal data if it changes.  If you are providing updates or corrections about another person, we may require you to provide us with proof that you are authorised to provide that information to us.

Your Rights

You have a number of legal rights in respect of your personal data.  These include:

• The right to receive a copy of the personal data that we hold about you. We will require proof of identity and proof of authority if the request comes from someone other than the person whose data we are asked to provide.  This will ensure we only provide information to the correct person.  We normally expect to respond to requests within 28 days of receiving them.
• withdraw consent to direct marketing. You can exercise this right at any time and can update your preferences yourself or ask us to do it for you.  See section ‘Updating and correcting your personal data’ above for details.
• withdraw consent to other processing. Where the only legal basis for our processing your personal data is that we have your consent to do so, you may withdraw your consent to that processing at any time and we will have to stop processing your personal data.  Please note, this will only affect a new activity and does not mean that processing carried out before you withdrew your consent is unlawful.
• If you consider any of your personal data is inaccurate, you can correct it yourself or ask us to do it for you (see section ‘Updating and correcting your personal data’ above for details).
• In limited circumstances you may be able to require us to restrict our processing of your personal data.  For example, if you consider what we hold is inaccurate and we disagree, the processing may be restricted until the accuracy has been verified.
• Where we have no lawful basis for holding onto your personal data you may ask us to delete it.
• In limited circumstances you may be entitled to have the personal data you have provided to us sent electronically to you for you to provide to another organisation.
• to complain to the Information Commissioner’s Office. If you have a concern or complaint we would prefer you to contact us (see the section ‘How to contact us’ above) and we will try to resolve it for you.  If you want to make a complaint to the Information Commissioner’s Office, you can find information on how to do this at ico.org.uk.