Ethical Trading
BTC Group are delighted to announce our acceptance as full members of the Ethical Trading Initiative (ETI), a unique achievement for a company specialising in the production and supply of promotional clothing and general merchandise.
    

We celebrated our 30th anniversary in 2007 and are proud to be the largest privately owned promotional merchandise & corporate clothing supplier in the UK with an excellent reputation for quality and customer service.  Membership of the ETI was the next logical step in expanding our corporate responsibilities after achieving ISO 14001 for our integrated Environmental Management System.
    

The ultimate goal of the ETI is to ensure that the supply chain working conditions of workers producing for the UK market meet or exceed international labour standards. BTC Group have agreed to do our utmost to comply with the ETI Base Code and to that end Managing Director Frank Murphy, Sales Director Paul Beirne and Senior Marketing Manager Jon Birrell have attended Supply Chain Management workshops at the ETI Headquarters in London.

Frank Murphy comments “Working with some of the best known brands in the world it is essential that our clients feel safe in the knowledge that every effort is being made to guard their reputation and prevent association with illegal labour practices.”

BTC Group are now able to sit alongside organisations that include Boots, Gap, Marks & Spencer, Next, Sainsbury’s and Tesco in helping to eradicate many of the bad practises and gross injustices that often occur in the supply chain of products and services to the UK.

Environmental Policy
The following is our internal Environmental Policy, which forms part of the BTC Group Staff Handbook:

1) BTC Group are committed to the principles and practice of protecting the environment from the result of the activities in creating products and services for our customers and wealth and employment for our employees and owners

2) We are also committed to continual improvement in the performance of our operations so that the environment is protected and ultimately enhanced by such operations

3) Our aims are to ensure we:
(a) Use energy efficiently generating emissions that are controllable and of the least harmful type;
(b) Use our raw materials economically, causing as little waste as possible;
(c) Collect waste and ensure that it is either reused or disposed of in as environmentally-friendly manner as possible;
(d) Abide by the requirements of the international environmental management standard ISO14001 in all respects in this connection;
(e) Attempt to alleviate carbon dioxide emissions by encouraging employees to share transportation on their journeys to and from work;

4) We have set and will continue to revise achievable standards in seeking to make our operations environmentally neutral and ultimately enhancing

5) In our employment relationship, we will brief employees on the affects of any raw materials, processes and end products and encourage staff at all levels to contribute to on-going discussions regarding ways in which our processes etc., can be made environmentally neutral and (ultimately) enhancing.  We will also foster a climate in which waste is virtually eliminated either by being avoided in the first place or by being used or ultimately by being disposed of safely.  Where required, suitable training and resources will be provided and all staff will be encouraged to consider ways in which they can be fully involved in and committed to all aspects of this policy.  Suggestions for improving our environmental performance will be suitably rewarded via the Suggestion Scheme.

6) We will endeavour to reach accord with every supplier so that in generating raw materials for our purposes their processes are also environmentally neutral, even if this requires our partial investment in new processes etc.

Why is ethical sourcing an issue?
Ethical trade became a growing issue during the 1990s because companies with global supply chains – in particular those in the clothing and food sectors – were coming under increasing pressure to ensure decent working conditions for the people who produce the goods they sell. A number of NGO and trade union campaigns raised consumers’ awareness of poor working conditions in factories and farms in developing countries – factories and farms that produced goods for leading companies in Europe and North America.
   

As a result, a growing number of companies have decided that they can no longer turn a blind eye, and have adopted some form of ethical sourcing policy to address growing public concern over supply chain labour issues. Pressure on companies has been maintained as NGOs and trade union organisations, both large and small, and both in developing as well as developed countries, have continued to campaign on these issues. Moreover, corporate investment companies are increasingly screening their investments according to a range of social and environmental criteria, including a company’s efforts in addressing supply chain labour conditions. Together, these trends are making it more and more difficult for companies to ignore ethical sourcing issues.

What does ETI membership  mean for BTC Group?
Membership of the ETI enables BTC Group to actively contribute to and learn from projects conducted in regions where the ethical rights of workers are of utmost importance. Members learn how to put ethical trade into practice and to increase their impact by working in collaboration with other ETI members.

Jon Birrell, Senior Marketing Manager at BTC Group, comments “It is becoming increasingly important for companies to consider the working conditions under which their promotional merchandise and corporate clothing are manufactured, and this is not just limited to multinational corporations.  BTC Group’s membership demonstrates our commitment to progressively improving conditions in our suppliers’ work places”.  
   

BTC Group also benefits in other ways from improved labour practices in their supply chain, for example, increased supplier productivity and better industrial relations – and from a reputation for fairness.

What does it mean in practice?
Companies take responsibility for their supply chain labour conditions in many different ways. That is, there are many different approaches to ethical sourcing, and while some approaches are undoubtedly more effective than others, there is no one “right way”.
   

Nevertheless, a company’s ethical sourcing strategy usually involves adopting a “code of practice”, that sets out minimum labour standards that they expect their suppliers to comply with. Ethical trade is still a relatively new field, and as yet there is little universally accepted “best practice” in terms of how to develop, monitor and implement a code of practice.
   

The ETI believes that there are a number of basic principles that underpin any effective and credible approach to ethical sourcing. These include the following:

• ETI considers voluntary codes of labour practice as complementary and not an alternative to the proper enforcement of national and international labour laws, and believes that such codes should be implemented in ways that help, and not hinder, the application of law.
 
• ETI believes that codes of labour practice should be based on internationally agreed labour standards, and that the most relevant standards are those set out in the Conventions of the International Labour Organisation (ILO).
 
• ETI believes that the tripartite structure of the ILO, involving both employers’ and workers’ representatives as well as governments, together with the technical expertise of this organisation in all matters relating to the world of work, make the ILO the authoritative and legitimate source of international labour standards. The ETI Base Code is based on the principles underlying key ILO Conventions.
 
• However, ETI’s experience also underlines the importance of involving local stakeholders – their perspectives, knowledge and concerns – in the implementation of the codes.
 
• ETI sees the adoption of a code as just a starting point. A true commitment to ethical sourcing also involves committing adequate resources, communicating the code throughout the sourcing company and the supply chain, ensuring that relevant staff have appropriate skills, monitoring your suppliers, helping suppliers make improvements, reporting on what you find in your supply chain, and supporting the verification of these findings.
 
• ETI believes that companies committed to ethical sourcing must require their suppliers to meet agreed standards within a reasonable time frame, and that performance in this regard should ultimately be a precondition for further business.
 
• However, ETI recognises that the observance of some provisions in the ETI Base Code may not be immediately realisable in all cases. Some suppliers may be unable to meet all the terms within a short time or, in some cases, they may be constrained by national law. Therefore, reasonable timeframes and the existence of any constraints not controllable by the supplier may be taken into account.
 
• Nevertheless, ETI believes that failures to observe certain standards require rapid corrective actions if the sourcing company is to continue any business relationship with the supplier concerned. These include the use of forced, bonded or involuntary prison labour, as well as physical abuse or discipline, and extreme forms of intimidation.
 
• ETI also believes that code implementation – from the design of an ethical sourcing strategy and monitoring and verification procedures, to the agreement and implementation of corrective action plans – is strengthened by the involvement of stakeholders other than companies. Key stakeholders are those organisations who represent workers (trade union organisations), and other organisations who work to defend workers’ rights and address workers’ concerns (e.g. relevant NGOs).

Is ethical sourcing the same as fair-trade?
ETI’s members include organisations from the fair-trade movement.  But ethical sourcing and fair-trade are different. Ethical sourcing tries to ensure that decent minimum labour standards are met in the production of the whole range of a company’s products. By contrast fair-trade is primarily concerned with the trading relationship. Fair-trade ensures that producers are paid a decent price that at least covers the true costs of production, despite often serious fluctuations in world commodity prices. Many consumers will always be prepared to buy special fair-trade products, while expecting that mainstream products are safely and decently produced.

Ethical Trading
The following is the ethical trading base code:

1. Employment is freely chosen
1.1 There is no forced, bonded or involuntary prison labour.
1.2 Workers are not required to lodge “deposits” or their identity papers with their employer and are free to leave their employer after reasonable notice.
 
2. Freedom of association and the right to collective bargaining are respected
2.1 Workers, without distinction, have the right to join or form trade unions of their own choosing and to bargain collectively.
2.2 The employer adopts an open attitude towards the activities of trade unions and their organisational activities.
2.3 Workers representatives are not discriminated against and have access to carry out their representative functions in the workplace.
2.4 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.

3. Working conditions are safe and hygienic
3.1 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.
3.2 Workers shall receive regular and recorded health and safety training, and such training shall be repeated for new or reassigned workers.
3.3 Access to clean toilet facilities and to potable water, and, if appropriate, sanitary facilities for food storage shall be provided.
3.4 Accommodation, where provided, shall be clean, safe, and meet the basic needs of the workers.
3.5 The company observing the code shall assign responsibility for health and safety to a senior management representative.

4. Child labour shall not be used
4.1 There shall be no new recruitment of child labour.
4.2 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.
4.3 Children and young persons under 18 shall not be employed at night or in hazardous conditions.
4.4 These policies and procedures shall conform to the provisions of the relevant ILO standards.

5. Living wages are paid
5.1 Wages and benefits paid for a standard working week meet, at a minimum, national legal standards or industry benchmark standards, whichever is higher. In any event wages should always be enough to meet basic needs and to provide some discretionary income.
5.2 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.
5.3 Deductions from wages as a disciplinary measure shall not be permitted nor shall any deductions from wages not provided for by national law be permitted without the expressed permission of the worker concerned. All disciplinary measures should be recorded.

6. Working hours are not excessive
6.1 Working hours comply with national laws and benchmark industry standards, whichever affords greater protection.
6.2 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 rate.

7. No discrimination is practised
7.1 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.

8. Regular employment is provided
8.1 To every extent possible work performed must be on the basis of recognised employment relationship established through national law and practice.
8.2 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.
 
9. No harsh or inhumane treatment is allowed
9.1 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.

BTC Group have developed strong relationships over the last 30 years with a large number of suppliers and factories, from the UK and mainland Europe to the Far East, allowing us to offer a state of the art search facility on our website that focuses on the customer’s specific requirements to narrow the product search from over 65,000 promotional items.  Below are a few Corporate Social Responsibility statements from a small selection of our suppliers.

FOTL
FOTL strives to implement and enforce the highest environmental and ethical standards through its global operations. The company has its own detailed Code of Conduct which is integral to its business. The Code of Conduct is based on current best practice with regard to employment, health and safety and the environment. FOTL requires that all workers receive salaries that are at or above the local minimum wage and are highly competitive. The minimum age for employees at FOTL plants is 18 years and refuses to work with any factories that employ under age workers or forced labour. All FOTL products have had Oeko-Tex 100 approval since 1998, certifying that they contain no substances that may be harmful to humans or the environment.

Gildan
Gildan firmly believe in labour practices that not only comply with the laws in effect but also correspond to industry best practices. In 2006 the Company updated its code of conduct to reflect, in a single code, compliance with Fair Labour Association (please visit fairlabor.org for further information) and Worldwide Responsible Apparel Product (WRAP) standards, as well as corporate social responsibility best practices in effect throughout the industry. Gildan renewed, for the third consecutive year, its Oeko-Tex Standard 100 certification. In 2006, to further enhance environmental, health and safety practices, Gildan developed an environmental management system (EMS) plan that will be implemented company-wide during 2007 and 2008. In 2004 Gildan adopted sustainable environmental practices by creating a highly efficient biological wastewater treatment system (biotope) that is being used at its textiles facilities in Honduras and the Dominican Republic.
Gildan is also presently working on a new project, the salt recovery system, which consists of recycling the salt from the wastewater and reusing it in the dyeing process. This new system, tested in 2007 and scheduled for implementation in 2008, will complement the biotope system. For the Comprehensive Corporate Social Responsibility policy report please visit www.gildan.com

Hanes
Hanes Brands Inc. (HBI) believes in doing business with those suppliers, manufacturers, contractors, joint venture partners, agents, distributors, and consultants who embrace and demonstrate high standards of ethical business behaviour. Suppliers will not employ individuals in violation of the local mandatory school age, or under the legal employment age in each country where they operate. Suppliers will not discriminate based on personal characteristics or beliefs. Hanes is committed to protecting the quality of the environment around the world through sound environmental management. HBI will meet or exceed applicable environmental laws and regulations and seeks to reduce waste and minimise the environmental impact of their operations. Hanes strives to continuously improve environmental performance through resource conservation, waste minimisation, water and energy efficiency and effective use of raw materials. Hanes will measure environmental
performance and work to promote environmentally friendly practices.

Kustom Kit
Kustom Kit adopts a rigorous selection process for garment manufacturers ensuring only those that are totally committed to exceeding high ethical standards become appointed suppliers. Children must not be employed below the legal minimum age required by the law of the individual country. Employees are to be paid no less than the legal minimum wage as required by the law of the individual country. Working hours must not exceed those set out by local legislation and overtime must be voluntary not compulsory. Manufacturers are frequently inspected and reported upon by local independent agents. Kustom Kit is also dedicated to protecting the environment and purposely seeks out suppliers who take positive action to minimise both waste and the impact of their manufacturing processes on the surrounding environment.


PF Concept
Will not accept goods on which children, younger than the age for completing compulsory education subject to local laws have worked. Require suppliers/manufacturers to ensure that wages and benefits paid to its employees are at least consistent with the local laws or legislation governing minimum wages and benefits. Require suppliers/ manufacturers to comply with all local environmental laws and legislation and be committed to improving and investing in environmental efforts.

Russell Europe
Complies with Oeko-Tex and WRAP continually working to become one of the first major clothing companies to have its factories fully accredited for the new Worldwide Responsible Apparel Production standard. By ensuring its compliance with stringent ethical standards such as Oeko-tex and WRAP Russell is able to give customers confidence that practices like child labour, unfair work conditions and environmental pollution are not used in the production of any of their garments.

Equal opportunities policy- Race and Gender
BTC Group is committed to a policy of equal opportunities for all employees, workers and applicants and shall adhere to such a policy at all times and will review on an on-going basis on all aspects of recruitment to avoid unlawful or undesirable discrimination. We will treat everyone equally irrespective of sex, sexual orientation, marital status, age, disability, race, colour, ethnic or national origin, religion, political beliefs or membership or non-membership of a Trade Union and places an obligation upon all staff to respect and act in accordance with the policy. BTC Group is committed to providing training for all its staff in equal opportunities practice.
    

BTC Group shall not discriminate unlawfully when deciding on any terms of employment or terms of engagement for temporary workers.

Disability discrimination
BTC Group will not discriminate against a disabled job applicant or employee on the grounds of disability - BTC Group will accordingly make career opportunities available to all people with disabilities and every practical effort will be made to provide for the needs of staff, candidates and clients.
    

BTC Group will make reasonable adjustments to hallways, passages and doors in order to provide and improve means of access for disabled employees and workers. However, this may not always be feasible.

Age discrimination
BTC Group is committed to recruiting and retaining employees whose skills, experience, and attitude are appropriate to the requirements of the various positions regardless of age. As far as is reasonably possible and in the most exceptional circumstances no age requirements will be stated in any job advertisements on behalf of the company.

Human Rights policy
BTC Group is committed to the advancement and protection of Human rights. Our policy has been influenced by the Universal Declaration on Human Rights which we believe best defines the responsibilities of National Governments in matters of Human Rights and the International Labor Organisations Declaration on Fundamental principles and Rights at Work.
    

Whilst BTC Group recognises that it is a very very small cog in a giant global wheel we believe in doing what we can to influence and educate our supply chain whenever and wherever we can in matters of Human Rights, Corporate Social Responsibility (CSR) and Ethical trading. We reserve the right to demand a copy of our suppliers policies at any time.
    

We do our utmost to only conduct trade with those suppliers that embrace our policies on Human Rights, CSR and Ethical Trading and we request them to communicate our policies to their workforce. We will work with any of our suppliers to rectify any breaches of our policies that they may make but we will not hesitate to de list them if they fail to correct them within a reasonable period.

Customer Service Policy
At BTC Group Customer Service is given the utmost priority and is considered to be the very cornerstone of our business. It has been proven to us that by offering our customers the very best levels of Customer Service in our industry we will retain their business and grow our market share.
  

We believe that excellent Customer Service begins at the point of contact and that clients should expect to have their queries responded to as quickly and efficiently as possible. We believe that our customers should receive their goods on time, on budget and that they are sourced ethically.
    

Should any problems or complaints arise we believe that they should be dealt with in a courteous and efficient manner. We are always very happy to work within any reasonable Service Levels Agreements that our customers choose propose.

Equal opportunities policy
BTC Group is committed to a policy of equal opportunities for all employees, workers and applicants and shall adhere to such a policy at all times and will review on an on-going basis on all aspects of recruitment to avoid unlawful or undesirable discrimination. We will treat everyone equally irrespective of sex, sexual orientation, marital status, age, disability, race, colour, ethnic or national origin, religion, political beliefs or membership or non-membership of a Trade Union and places an obligation upon all staff to respect and act in accordance with the policy. BTC Group is committed to providing training for all its staff in equal opportunities practice. BTC Group shall not discriminate unlawfully when deciding on any terms of employment or terms of engagement for temporary workers.

Health and Safety policy
BTC Group is committed to providing for the health, safety and welfare of all employees and to maintaining high standards and will observe The Health & Safety at Work Act 1974 and all relevant regulations and codes of practice made under it from time to time. BTC Group will take into account any recommendations made by the Health & Safety Executive with regard to health and safety issues, and where appropriate will liaise with the Health & Safety Executive on particular health and safety issues, which are of particular relevance to the company.
    

This commitment to health and safety is a management responsibility equivalent to that of any other management function.. It will be the duty of the Partners of BTC Group to ensure that the policy is upheld at all times, and to provide the necessary funds and staff required.

So far as it is reasonably possible BTC Group will:
• Assess the risk to health and safety of employees and others who may be affected, and identify what measures are needed to comply with its health and safety obligations.
• Provide and maintain locations, equipment, protective clothing and systems of work that are safe and without risks to health.
• Ensure that all necessary safety devices are installed and maintained on equipment.
• Provide information, instruction, training and supervision in safe methods and procedures.
• Provide and maintain a healthy and safe place of work and provide a means of access therefrom.
• Promote the co-operation of employees to ensure safe and healthy conditions and systems of work by discussion and effective joint consultation.
• Establish emergency procedures as required.
• Monitor and review the management of health and safety at work.
• Keep this safety policy under review and make any revision it deems necessary from time to time. All such revisions will be brought to the attention of the employees.
• Consult with employees on health and safety matters.
• Ensure that the workplace is properly ventilated.

The above policy needs the full co-operation of all employees, who are expected to give all possible assistance aimed at its successful implementation, to take reasonable care for their own safety and that of others. In order to achieve this end, it is the duty of every employee to:
• Comply with any safety instructions and directions issued by BTC Group
• Take reasonable care for their health and safety, and the health and safety of other persons (e.g. other employees, contractors, customers, workmen, etc.) who may be affected by your acts or omissions at work, by observing safety rules that are applicable to you.
• Co-operate with BTC Group to ensure that the aims of the Health and Safety
• Policy are achieved, and any duty or requirement imposed on the Firm by or under any of the relevant statutory provisions is complied with.
• Report and co-operate in the investigation of all accidents or incidents that have led or may lead to injury.
• Use equipment or protective clothing provided in accordance with the training you have received.
• Report any potential risk, hazard or malfunction of equipment to the appropriate authority.
• Any failure by an employee to comply with any aspect of BTC Group’s health and safety procedures, rules or duties specifically assigned to the employee with regard to health and safety, will be regarded by BTC Group as misconduct, which will be dealt with under the terms of the company’s disciplinary procedure.
• The partners are responsible for the implementation of health and safety policies in the areas under their control.
• All employees have the responsibility to observe all safety rules and to cooperate with the Partner charged with responsibility for the implementation of
• BTC Group’s health and safety policy, to achieve a healthy and safe workplace, and to take reasonable care of themselves and others.

Quality Assurance and Quality Control Policy
At BTC Group Quality Assurance (QA) and Quality Control (QC) are integral parts of our management activities and are incorporated into our planning, implementation, assessment, and corrective action to ensure that all our processes and services are of the type and quality needed and expected by our clients.
   

The objectives of our QA/QC policies are to ensure that when orders are received they are administered professionally, completed on time and are within budget. All BTC Group staff from our receptionists through to our production staff
and on to our delivery drivers are aware of our attention to both areas and in the absence of their line manager can if required take action to ensure our policies are met.
   

Our Sage administration system ensures that documentation is always available and our additional manual control systems enable all staff to monitor the progress of any order through the system. Within our print, packing and fulfilment
divisions safeguards are in place at a number of critical points to ensure that best practises are observed and standards maintained.
   

All production machinery is checked on a regular basis with inspections often exceeding manufacturers recommendations. BTC Group’s operations have been audited by a number of clients and have never failed to meet the required standards, we will continue to strive for excellence in all areas of QA and QC.

Social Responsibility Policy
BTC Group are a family owned partnership and take our social responsibilities very seriously. We are in regular contact with local schools and help them with their Student Placement Programme, this work involves us in taking students for 2-6 week placements and giving them experience of a working environment. Many of our staff involve themselves in fundraising activities, these include the London Marathon and local charities. As a company we always support these efforts both in financial terms and in allowing staff time to attend. We regularly send shipments of clothing to various charities in third world countries.

Sustainability Policy
BTC Group believe that sustainable development should meet the needs of the present without comprising the ability of future generations to meet their own needs. It means improving quality of life for people today, as well as thinking about those who will live after us.

• BTC Group believe that a Sustainable Community is dependent on people acting together to create healthy, safe places in which to live, work and play.
• BTC Group will work towards both a sustainable community and sustainable development through:
• Engagement- People should be able to contribute to decisions that affect their quality of life, and their environment.
• Equity- Resources should be used to provide for the needs of the whole community without exclusion or disadvantage to any group.
• Environmental Protection- We all depend on the Earth’s natural resources to live.
• These resources should be protected and enhanced.
• Economic Development -We all depend on a strong, broadly based local economy. This should be developed in partnership to provide opportunities for the whole community.

For further information about ETI please visit www.ethicaltrade.org