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HI-TEC EUROPE LTD CORPORATE GOVERNANCE

CORPERATE GOVERNANCE

ETHICAL TRADING POLICY

General Commitment

Hi-Tec demands that our agents, factories and sub-contractors respect and adhere to the basic principles, rules and regulations required in supporting an ethical code of conduct for its employees and their workplace.  This will extend to an expectation of all key contractors involved in the manufacturing of products through Hi-Tec Europe Ltd, to ensure adherence to these same principles. The business relationship(s) shall be built on a foundation of mutual respect, trust, teamwork and the following of certain procedures expected of a Code of Conduct.  These shall include, but are not limited to:

The prevention of Slavery, human trafficking

Hi-Tec Europe Ltd is committed to a zero-tolerance approach to any aspect of modern slavery or forced labour. The bulk of this Ethical Policy already covers the most vulnerable employees that could be at risk from exploitation. If any of our employees or trading partners suspect any use of forced labour, we would ask you contact Hi-Tec Europe Ltd. We will treat any correspondence in strict confidentially and follow up with utmost seriousness.

Child Labour

Use of child labour is strictly prohibited in the Hi-Tec Europe Ltd supported workplace or by any of the key factory contractors associated with Hi-Tec Europe Ltd product.  Child labour is defined as any worker who has not yet reached the age at which compulsory schooling has ended, or 16 years of age whichever is greater.  Workers under the age of 18 cannot be involved in any jobs that have demonstrated incidences of injuries or developmental risks because they involve processes or tasks that are physically demanding and difficult to perform.

Prison, Forced or Compulsory Labour

The use of prison, forced or other compulsory labour is strictly prohibited and must not be used.

Conflict Minerals

The use of ‘Conflict Minerals’ is strictly prohibited. ‘Conflict Minerals’ include the likes of tin, tantalum, tungsten and gold.

Benefits

Benefits must comply with all provisions for legally mandated employee benefits including but not limited to housing, meals, transportation and other allowances such as health care, child care, sick leave, emergency leave, pregnancy and menstrual leave; extends to religious observances, bereavement, and annual holiday leave; and contributions as required by law for social security, life health, worker’s compensation and other required insurances.

Hours of Work and Overtime

Working hours must and will comply with legally mandated work hours for the country of labour performed.  Employees working overtime are to be fully compensated according to said local laws.  An employee must be informed at time of hire if mandatory overtime is a condition of employment. An employee is entitled to one day off in seven on a regularly scheduled basis and must be informed of this at the time of hire.  Also, the employee is required to work no more than the prescribed amount of hours per week within the locally mandated limits.

Health and Safety

All agents and all key contract factories manufacturing product for Hi-Tec Europe Ltd must provide a working environment, which is safe.  This commitment includes adequate fire exits and well-lit workstations.  Contractors must also certify they have, and comply with, written health and safety guidelines.

Treatment of Employee

Every employee must be treated with respect and dignity.  No employee may be the subject of any physical, sexual, psychological or verbal harassment or abuse.

Legal

Manufacturers making products for Hi-Tec Europe Ltd must observe all laws of the applicable country including the laws that relate to employment, discrimination, safety and health.

Discrimination

Hi-Tec Europe Ltd recognizes and respects the cultural differences of the people.  Hi-Tec Europe Ltd also believe that workers should be judged based upon their ability to do their jobs and not upon their physical and/or personal characteristics.  Hi-Tec Europe Ltd will favour manufacturers who endeavour to recruit, train, promote, retire and terminate workers on equal terms based on suitability for the job and without discrimination.

If a violation of any of the above is discovered within the workplace of any of the key contractors responsible for the manufacture of Hi-Tec Europe Ltd products, Hi-Tec Europe Ltd reserves the right to undertake a variety of measures including on-site inspections of production facilities and living facilities in order to monitor and investigate any alleged violation(s).  If a violation is found to have taken place in the workplace, corrective action must be taken immediately by the contractor.

The undersigned assures that the operations conducted at its facilities comply together with those of its key contractors and partners of the aforementioned codes of conduct. Hi-Tec Europe Ltd expects full co-operation from said contractors, and will ensure there is adequate monitoring of the key facilities’ workplaces.  It is further understood that failure to abide by this Code of Conduct may result in punitive action and in the case of the non-performing key contractors, refusal to conduct future business.

Ethical Auditing

To support our ethical code of conduct, we may require suppliers to provide evidence of their ethical standards i.e. in the form of an independent 3rd party ‘Ethical Audit’ of their operation. These audits carried out by such agencies as Bureau Veritas can help assure Hi-Tec Europe Ltd and our customers that our suppliers operate in accordance with our ethical principles or International recognized standards such as SA8000 (Social accountability) or SEDEX.

Confidential Communication

If you have reason to suspect that any of our suppliers, staff or trading partners are failing to meet   Hi-Tec Europe ethical standards. We strongly encourage you to contact us in confidence.

In writing: Executive Secretary, Hi-Tec Europe ltd, Aviation Way, Southend, Essex SS2 6GH, UK

ANTI-SLAVERY POLICY STATEMENT

This policy statement sets out the Company’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains.

Modern slavery is the severe exploitation of other people for personal or commercial gain and is a crime resulting in an abuse of the human rights of vulnerable people from the UK and overseas.

Modern slavery can take various forms, including:

  • Human Trafficking: the process of trapping people through the use of violence, deception or coercion and exploiting them for financial or personal gain.
  • Forced Labour: any work or service which people are forced to do against their will, under threat of punishment. Almost all slavery practices contain some element of forced labour.
  • Bonded Labour: also known as debt bondage or debt slavery, it occurs when a person is forced to work to pay off a debt. They are tricked into working for little or no pay, with no control over their debt.
  • Child Slavery: the enforced exploitation of a child for someone else’s gain, meaning the child will have no way to leave the situation or person exploiting them.
  • Child Marriage: this can be referred to as slavery if the child has not genuinely given their free and informed consent to enter the marriage, if they are subject to control in the marriage (particularly through abuse and exploitation), or if they cannot realistically leave or end the marriage.
  • Descent-based Slavery: where people are born into slavery because their ancestors were captured into slavery and their families have ‘belonged’ to slave-owning families ever since.
  • Domestic Slavery: domestic workers in private homes where the circumstances and conditions of their work amounts to slavery e.g. their employer stops them from leaving the house, does not pay their wages, uses violence or threats, withholds their identity documents, limits their contact with family and forces them to work.
Slavery in Supply Chains

Long and complex supply chains make it challenging to oversee who is working where and under what conditions, from the extraction of raw materials, the manufacturing of goods or the shipping and delivery of those goods to customers.

Slavery in the UK

Modern slavery is present in every area of the UK and can take many forms. The most common form of slavery in the UK is forced labour, more often found on farms and in construction, shops, bars, nail salons, car washes or manufacturing.

The Company has a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity and transparency in all of its business dealings and relationships and to implementing and enforcing effective systems and controls to ensure that modern slavery and human trafficking are not taking place anywhere within either its own business or in any of its supply chains, consistent with its obligations under the Modern Slavery Act 2015.

The Company also expects the same high standards from all of its suppliers, contractors and other business partners.

Identifying potential victims of modern slavery can be a challenge because the crime can manifest itself in many different ways. In addition, some suppliers may go to great lengths to hide the fact that they are using slave labour. However, the Company accepts that it has a responsibility through its due diligence processes to ensure that workers are not being exploited, that they are safe, and that relevant employment, health and safety and human rights laws and standards are being adhered to, including freedom of movement and communications.

The Company uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency, for example ensuring that the agency does not charge job seekers recruitment fees.

This policy applies to all individuals working for the Company or on the Company’s behalf in any capacity, including employees, directors, officers, agency workers, agents, contractors, consultants and business partners.

Responsibility for the Policy

The Board of Directors has overall responsibility for ensuring that this policy complies with the Company’s legal and ethical obligations.

Line Managers are responsible for ensuring that those reporting to them understand and comply with this policy.

Compliance

The prevention, detection and reporting of modern slavery in any part of the Company’s business or supply chains, is the responsibility of all those working for the Company or under the Company’s control. Employees are required to avoid any activity that might lead to a breach of this policy.

If anyone believes or suspects a breach of or conflict with this policy has occurred or may occur, they must notify their Line Manager or report it in accordance with the Company’s Whistleblowers Policy. Everyone is encouraged to raise concerns about any issue or suspicion of modern slavery in any part of the Company’s business or supply chains as soon as possible.

If anyone is unsure about whether a particular act, the treatment of workers or their working conditions within any of the Company’s supply chains constitutes any of the various forms of modern slavery, again it should be immediately raised. Matters can also be raised by contacting the government’s Modern Slavery Helpline on 0800 0121 700, who are able to provide further information and guidance on modern slavery.

The Company aims to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. The Company is committed to ensuring no one suffers any detrimental treatment or victimisation as a result of reporting in good faith their suspicion that modern slavery is or may be taking place in any part of its business or in any of its supply chains.

The Company’s zero tolerance approach to modern slavery must be communicated to all suppliers, contractors and other business partners when entering into new or renewed contracts with them.

Breach of the Policy

Any employee who breaches this policy will face disciplinary action, up to and including summary dismissal for gross misconduct.

The Company may terminate its commercial relationship with suppliers, contractors and other business partners if they breach this policy and/or are found to be involved in modern slavery.

 

ISO 14001 ENVIRONMENTAL MANAGEMENT POLICY

Hi-Tec Europe recognises the importance of environmental protection and is committed to operating its business responsibly and in compliance with all legal requirements.  Hi-Tec Europe is committed to carry out all reasonable and practical measures to meet, exceed or develop our environmental standards.

Care for the environment is one of our key responsibilities and an important part of the way in which we do business. In this policy statement, we reiterate our commitment to:

  • Complying with all relevant environmental legislation, regulations and approved codes of practice;
  • Protecting the environment by striving to prevent and minimize our contribution to pollution of land, air, and water;
  • Seeking to keep wastage to a minimum and maximize the efficient use of materials and resources;
  • Develop new products, materials, packaging to reduce negative impact on the environment
  • Managing and disposing of all waste in a responsible manner;
  • Providing training for our staff so that we all work in accordance with this policy and within an environmentally aware culture, 
  • Regularly communicating our environmental performance to our employees and other significant stakeholders;
  • Developing our management processes to ensure that environmental factors are considered during planning and implementation;
  • Monitoring and continuously improving our environmental performance. Initiating improvement action plans to put ideas into practice.
  • Improve our environmental impact by encourage our supply partners to improve their environmental performance so that TOGETHER we improve our collective performance
  • Hi-Tec Europe Ltd Executive Directors fully endorse this policy and remain committed to its implementation

ISO 9001 QUALITY MANAGEMENT POLICY

ISO 9001 is an Internationally recognised ‘Gold’ standard which helps ensure a Company manages its Products, Services and Operations to produce a good consistent product for its customers and ensure its staff have the support and leadership required to do their jobs effectively and well.

ISO 9001 QUALITY MANAGEMENT

The company is committed to providing our customers with the highest quality products in the most competitive way.

‘Fashion, Quality and Value’ is of fundamental importance to the continued success of the company.

Our Product Design & Technical Management teams ensure the highest standards of design and technical control throughout the design-development and production of company product.

Regular and detailed performance monitoring is in place to help ensure consistent quality of product and drive improvements.

Every employee is expected to take responsibility for the quality of their work and expect similar commitment and performance from colleagues and suppliers.

The company continues to provide educating, training and resources to our employees to ensure that their work continues to support the service we provide our customers.

The company remains committed to ensuring that the Quality Management system meets the requirements of ISO 9001, our customers, any regulatory standards and is regularly reviewed to ensure continued improvement and effectiveness

Scope of our certified system

‘The design, sourcing, procurement, warehousing and distribution of footwear, accessories and apparel; including protective occupational and tactical products certified to relevant CE/UKCA standards, for clients within the UK’

Note relevant to SAFETY product/services

This company undertakes to supply only safety equipment and/or related services that fully comply with the standards and regulations and claims made relating to those products and/or related services. Where appropriate, this company will maintain up to date technical files and associated documentation to ensure that regulatory compliance information can be supplied upon request. Where products are sourced from external organisations which hold technical files relating to the products being offered, this company will request confirmation that these files are current, complete, contain appropriate conformity assessment information and, where relevant, regulatory compliance certificates and will take all necessary steps to confirm the validity of the compliance documentation held by that external supplier in respect of the products being sourced. Where services are provided related to safety equipment sourced from external organisations, this company will maintain approval from the manufacturer that the services provided are assessed and approved by the external organisation.