Ethical Supply Policy

At POM we are passionate about ethical business & we are committed to our ethical trading stance.

The guidelines below are based on the internationally recognised code of labour practice, they are pre-condition of supply for all suppliers and subcontractors. We work closely with our suppliers and regularly audit to set and maintain standards. Where any issues are found as part of our audit process, our first step is always to work in partnership to improve the issue, where we do not see improvement in a timely manner, we reserve the right to terminate contract.

Employment is freely chosen:

• There is no forced, bonded or involuntary prison labour
• Workers are not required to lodge "deposits" or their identity papers with their employer and are free to leave their employer after reasonable notice

Freedom of association and the right to collective bargaining are respected:

• The employer adopts an open attitude towards the activities of trade unions and their organisational activities
• Workers, without distinction, have the right to join or form trade unions of their own choosing and to bargain collectively
• Workers representatives are not discriminated against and have access to carry out their representative functions in the workplace
• Where the right to freedom of association and collective bargaining is restricted under law, the employer facilitates, and does not hinder, the development of parallel means for independent and free association and bargaining

Working conditions are safe and hygienic:

• 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.
• 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 potable water, and, if appropriate, sanitary facilities for food storage shall be provide
• Accommodation, where provided, shall be clean, safe, and meet the basic needs of the workers
• The company observing the code shall assign responsibility for health and safety to a senior management representative

Child labour shall not be used

• There shall be no new recruitment of child labour
• Companies shall develop or participate in and contribute to policies and programmes which provide for the transition of any child found to be performing child labour to enable her or him to attend and remain in quality education until no longer a child; "child" and "child labour" being defined in the appendices
• Children and young persons under 18 shall not be employed at night or in hazardous conditions
• These policies and procedures shall conform to the provisions of the relevant ILO standards

 Living wages are paid

• Wages and benefits paid for a standard working week meet, at a minimum, national legal standards or industry benchmark standards, whichever is 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

Working hours are not excessive

• Working hours comply with national laws 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 exceed 12 hours per week, shall not be demanded on a regular basis and shall always be compensated at a premium

No discrimination is practised

• 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

Regular employment is provided

• To every extent possible work performed must be on the basis of recognised employment relationship established through national law and practice
• Obligations to employees under labour or social security laws and regulations arising from the regular employment relationship shall not be avoided through the use of labour-only contracting, sub- contracting, or home-working arrangements, or through apprenticeship schemes where there is no real intent to impart skills or provide regular employment, nor shall any such obligations be avoided through the excessive use of fixed-term contracts of employment

No harsh or inhumane treatment is allowed

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

THE PROVISIONS OF THIS CODE CONSTITUTE MINIMUM AND NOT MAXIMUM STANDARDS, AND THIS CODE SHOULD NOT BE USED TO PREVENT COMPANIES FROM EXCEEDING THESE STANDARDS. COMPANIES APPLYING THIS CODE ARE EXPECTED TO COMPLY WITH NATIONAL AND OTHER APPLICABLE LAW AND, WHERE THE

PROVISIONS OF LAW AND THIS BASE CODE ADDRESS THE SAME SUBJECT, TO APPLY THAT PROVISION WHICH AFFORDS THE GREATER PROTECTION.

Bribery Policy

POM 925 prides itself on being fair, open and honest and we like to do business with those who feel the same. We are therefore totally committed to preventing bribery in any of our areas of influence. Suppliers must ensure that all workers are aware of and are committed to working to the POM 925 bribery policy and procedures.

POM 925 Bribery Policy and procedures: What is bribery?

POM 925 prides itself on being fair, open and honest and we like to do business with those who feel the same. We are therefore totally committed to preventing bribery in any of our areas of influence. Suppliers must ensure that all workers are aware of and are committed to working to the POM 925 bribery policy and procedures.

Working together we can ensure that everyone is committed to their role, in protecting company stock and assets

Why is this important?

Bribery blights lives. Its victims are not only those who lose out unfairly, but also a wider society where free and fair completion has been undermined.

Why now?

It has always been important, but recently the UK government has introduced a new Bribery Act 2010, effective from 1st July 2011. This creates an offence of offering or receiving bribes, bribery of foreign public official and failure to prevent a bribe being paid on an organization's behalf.

How do we implement?

We will ensure that we and those acting on our behalf understand this unwavering commitment and practice it consistently. We will train our staff, reinforce our policy to our staff through on going communication, and ensure that it is reviewed periodically by our management team. We will ensure that our suppliers are also clear on our policy, and that this forms a key part of our terms and conditions through our Supplier Manual. We will not tolerate anyone who does not uphold this policy within our organisation or amongst our partners.

What does it mean for Customer & Suppliers?

POM 925 will not conduct business with any Customer or Supplier who does not agree to adhere to this policy.

All supplier payments will be subject to independent scrutiny by the finance team.

Any Customer or Supplier dealing with POM 925 should ensure that they liaise with the representative of the Company if they are not sure regarding the Bribery Policy.