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BUSINESS ETHICS POLICY

We are keen to do as little damage as possible to the planet, to treat customers, employees and suppliers fairly and run the business in an ethical way.

That is our philosophy in a nutshell but to cover all the practicalities and formalities for you our Corporate Social Responsibility Policy is detailed below.

Should you require any further specific information, factory certifications etc do just ask.

Table of Contents:

1. Overview
2. Our company values
2.1 Business Ethics Policy
3. Our employees
4. Our customers
5. Our supply chain
5.1 Laboratory testing
5.2 Production inspections
5.3 Factory & social audits
5.4 Benchmarking & Key Performance Indicators
5.5 Requirements of our direct manufacturing contractors
5.6 European & North American supply chain
6. The Environment
6.1 Transport
6.2 Packaging
6.3 Forest Stewardship Council
6.4 WEEE directive
6.5 RoHS
6.6 CE Mark
6.7 BS & BSI Kitemark
6.8 REACH
6.9 ZDHC
7. Health & Safety
8. Our Community

Version date: 07/09/2020

1. OVERVIEW
Like you, we at Insigniacare about where the products we supply come from that they conform to the required EU safety standards, that they are sustainable wherever possible, produced ethically, safely, with conscious awareness of the environment and fair treatment of workers.

We are continuously working to improve how we affect people and the environment and we are committed to managing our business using the triple
bottom line: People, Planet and Profit, also known as the 3 pillars of sustainability.

We are committed to a sustainable business model that doesn’t put profits before the environment and people’s wellbeing. We try wherever possible to contribute, albeit in small way, to the UN’s 17 Sustainable Development Goals (SGDs)*, which replaced the 8 Millennium Development Goals at the end of 2015. *There are active links underlined and in blue like this to stated documents or pages throughout this document.

We are currently ISO9001: 2008 UKAS certified, ensuring we can meet the needs of our customers and stakeholders whilst meeting our statutory and regulatory requirements in the products and services we supply, however we have started working on our transition to ISO9001: 2015 in order to ensure best practice.

We are still working towards ISO14001, an environmental management system, and had planned to apply after the 2015 revision, the publication of which was then delayed but have prioritized our transition to ISO9001: 2015 and once complete that, then we will formally apply for ISO14001. We trade ethically and adhere to the ETI base code (Ethical Trading Initiative).

We monitor our supply chain to ensure there is no recruitment of child labour or abuse of labour. We adhere to the UN Global Compact’s Ten Principles and have formally written to the UN Secretary General in support and stating our commitment to submit an annual Communication on Progress and hope to be included as a formal signatory in 2018 when the requirements for membership should be extended to companies with fewer than ten employees.

We adhere to the Ceres principles and support the Ceres mission to transform the economy to build a sustainable future for people and the planet, in all but completing a Ceres report, which we are considering for 2018.

We are B members of SEDEX, with membership number S00000074401, and take part in their annual conferences including the Sedex Global Audit
Conference 2017 ‘Continuous Improvement in Practice’ in April this year. We are members of the BPMA (British Promotional Marketing Association) and adhere to the BMPA code of conduct.

We practice business ethically and in line with UK company law and particularly the UK Bribery Act 2010 and UK Modern Slavery Act 2015. This year we have added our Business Ethics Policy within this document at section 2.1. See also our terms and conditions of business on our websites and day-to-day business documents.

Our CSR performance has been measured previously in 2015 by Ecovadis, at that time the only independent group that allowed members to reliably rate their CSR. We were awarded their 2015 Gold Recognition Level.

We work in partnership with specialist auditing and testing companies, Intertek and Asia Inspection and audit the non-EU factories we use directly unless they are able to provide an up to date and internationally recognised audit. We are working to identify Key Performance Indicators (KPIs) for the factories we use regularly so that we can track performance over time.

We make sure that our non-EU’s supply chain’s audit reports and testing of our products are kept up to date. We use a combination of time stamped audits & certification documents provided by the factories that we use or we commission specific audits ourselves to meet necessary compliance on a case-by-case basis. The internationally recognised audits we are able to use are:

SMETA (SEDEX Members Ethical Trade Audit)

SA8000 Standard (Audited social certification for workplaces).

ZDHC (Zero Discharge of Hazardous Chemicals) Audit

In addition to BSCi, Coca Cola Company and Disney Audits which many of our factories have attained.

Wherever possible we strive to move beyond compliance by measuring performance (Benchmarks & KPIs), and by sharing relevant documentation and certification on request.

Where possible we display and provide this policy to all customers, employees & sub-contractors via our web site.

This year we have published a CSR Report in 3 sections comprising:
1. Sustainable Procurement Report 2017
2. Labour Practices, Human Rights and Health & Safety Report 2017
3. Environmental Report 2017

2. OUR COMPANY VALUES

Customers First – first and foremost we seek to create affinity with our clients’ brands and work to their requirements.

Integrity – we manage our business honestly, openly and maintain the highest ethical standards in everything we do.

Simplicity – we strive to find simple, clear and workable solutions.

Innovation – we embrace change and constantly look for new ways to improve our business offering.

Passion – we live and work through knowledge, enthusiasm and dedication.

People – to respect our teammates and develop our talent.

Diversity – we embrace different cultures.

Social Purpose – to improve and not to exploit people and the environment.

Sustainability – we are committed to creating a sustainable future as the challenge of our generation

2.1 BUSINESS ETHICS POLICY

A. Overview:
Further to our second company value, Integrity, we conduct business ethically, fairly and in line with the British Promotional Marketing Association’s Code of Conduct but with some further provisions and in line with UK law.

Two recent UK laws are of particular relevance to our industry, the UK Bribery Act 2010 and the UK Modern Slavery Act 2015, and we are incorporating these in the way we operate as a matter of urgency.

This policy also aims to cover anti-corruption, anti-fraud and bribery, anti-competitive practices and anti-trust issues, conflicts of interest, money laundering, fiduciary, fraud and information security.

B. Legal & Regulatory Requirements

UK Bribery Act 2010
We have implemented procedures and training to prevent bribery as outlined in the UK Bribery Act 2010. Specifically that:

Proportionality & Risk Assessment – we are an SME mainly doing business in the UK and Europe but with some suppliers and clients from outside Europe. The risk of bribery is relatively low.

Specifically to our industry of Promotional Marketing, Corporate Gifts and Point of Sales Materials is that the UK Bribery Act 2010 and the UK Government allows genuine bona fide hospitality, promotional or other business expenditure that is reasonable and proportionate to the level of business and the level of influence of the person receiving if there was a business decision in question.

We do not allow facilitation payments of any kind as defined in the Act.

Top Level Commitment – The Ethics Officer is the Managing Director ensuring that business is conducted without bribery or corruption from the top down.

Due Diligence – We conduct due diligence on all new customers and suppliers and this process is carried out by the Accounts Manager and Managing Director (& Ethics Officer).

Communication – policies, procedures and awareness of regulations and law are communicated during training and also at Company Meetings. The next scheduled meeting and training in relation to Corporate Social Responsibility including

Monitoring & Review – Procedures and scope are regularly reviewed by the Ethics Officer and communicated to staff at least annually.

UK Modern Slavery Act 2015
We have implemented procedures in relation to the UK Modern Slavery Act and have identified that in our industry there could be unskilled jobs in the supply chain, namely of picking, packing, assembly and kitting work where it could be possible for a supplier to source labour in contravention of the law. In light of this, we use only suppliers who are accredited BPMA members unless we conduct our own due diligence. We have also attended seminars on the subject at the SEDEX annual conference 2017.

In terms of our legal obligation to disclose our actions in relation to the UK Modern Slavery Act we are below the turnover threshold of £36M, although we have implemented the procedures outlined above and will hold our first internal training with regards to the Act on 18th September 2017.

Anti-Corruption
We are monitoring with interest the government’s development of a single UK Anti-Corruption plan to address this subject which was due in 2016 but is currently overdue.

In the meantime we abide by and follow all UK laws and ethical and fair business practices.

Anti-Fraud
We are committed to the prevention, deterrence, detection and investigation of all forms of fraud and corruption.

We require all staff and associates and agents to act honestly and with integrity. All staff are requested to read and be familiar with this policy and the details in the company handbook.

Money Laundering
We operate transparently and in line with UK law and accounting practices. Our industry is one that does not require a Money Laundering Reporting Officer as we do not operate within a relevant regulated sector.

Fiduciary
We adhere to the BPMA Code of Conduct and operate ethically and within the law at all times with all parties that we do business with and internally with employees. This duty operates from the managing director, ie top down, then though all parties and relationships thereafter.

Information Security
We undertake our legal duty to maintain third party data and internal company data secure as outlined by UK law relating to each specific data set.

C. Whistle Blowing Procedure:
Further to the scope and steps detailed on page 22 of the company handbook relating to ‘Making a protected disclosure’ and the Public Interest Disclosure Act 1998, we have implemented the following additional whistle blowing procedure to cover more specifically the issues stated below:

Corruption & Bribery – public and proprietary corruption in the workplace including extortion, bribery, conflict of interest, fraud and money laundering.

Anti-competitive practices – practices that reduce market competition, such as price fixing and bid-rigging.
Responsible Information Management – including responsible marketing and the security of third party data.

Child & Forced Labour – child, forced, or compulsory labour issues within company owned operations.

Discrimination & Harassment – discrimination based on any grounds at any stage of business. Harassment may include physical, psychological and verbal abuse.

Fundamental Human Rights – inherent political, social, cultural and economic rights established in the Universal Declaration on Human Rights

Whistle Blowing Contact:
Dedicated line of communication: whistleblower@galpeg.com
Responsible employee: Paul Green, Managing Director

Anonymity and confidentiality is absolutely guaranteed and will be carried in line with the Public Interest Disclosure Act 1998.

It is guaranteed that no report made in good faith will carry the threat of retaliation against the reporter

D: Training & Communication of the Whistle Blowing Procedure:
Staff and Associate training on the whistle blowing procedure took place on 18th September 2017.

3. OUR EMPLOYEES
We operate an equal opportunities policy for all present and potential future employees and will offer our employees clear and fair terms of employment and provide resources to enable their continual development. We maintain a clear and fair employee remuneration policy with fair working hours.

We will ensure that all employees of whatever nationality, colour, race or religious belief are treated with respect and without sexual, physical or mental harassment.

We will provide, and strive to maintain, a clean, healthy and safe working environment in line with UK Government Health and Safety Executive (HSE) guidelines and safe systems of work.

Each employee is given a company handbook detailing the company’s extensive policies and procedures regarding their employment and standards expected.

4. OUR CUSTOMERS
We are currently ISO9001: 2008 UKAS certified, ensuring we can meet the needs of our customers and stakeholders whilst meeting our statutory and regulatory requirements in the products and services we supply, however we have started working on our transition to ISO9001: 2015 in order to ensure best practice.

We are still working towards ISO14001, an environmental management system, and planned to apply after the 2015 revision, the publication of which was delayed but have prioritized our transition to ISO9001: 2015 and once that is complete we will formally apply for ISO14001.

For products that we import ourselves we use independent auditors to ensure our supply chain and products are compliant and share factory audits and certification documentation on request. We QC our imports using independent testing companies like Asia Inspection and Intertek.

5. OUR SUPPLY CHAIN
One of the most important areas of how we operate is how we manage our supply outside of the European Union. To ensure high standards, clean
manufacturing technologies, fair treatment of workers, and impeccable product quality we employ an independently assessed tripartite system to ensure our non-EU supply chain meets our CSR criteria.

5.1 Laboratory Testing
We use Asia Inspection and Intertek to independently carry out laboratory testing to check that our products meet the safety requirements to allow import into the European Union and will be able to display the CE mark showing that the product’s chemical composition has been identified and is within EU guidelines.

We may also test more specifically that a product meets an EU safety requirements for a particular group. A common test we carry out is for the EN71 Safety Standard, which tests products safety that might be used by children, so
will cover all toys, and will give the item a certification that the toy is safe for children above a defined age group (e.g. 3+ years).

Another test we use is the Migration of 21 Heavy Metals (EU regulation is 1935/2004/EC Article 3) in relation to the testing of food safeness of metallic items likely to be in contact with food for consumption. Tripartite System of Compliance

We ensure that these product specific tests are kept up to date and repeated at regular intervals.

5.2 Product inspection
Quality Control (QC) is extremely important and ensures our continuing commitment to high standards. We can carry out 4 kinds of product inspections depending on what is required:

a) First Production Inspection is performed immediately after the manufacturer produces the first mass production samples. It checks our demands on the factory, the status and quality of the raw materials and components used in the production, it checks the production samples against our approved samples or specification, production processes, schedule and quality control.

b) Final Random Inspections (FRI), where we request an independent assessment of quality and conformity by either Intertek or Asia Inspection. This may take place at the dockside before shipping by sea Europe. Only consignments that pass this QC will be allowed to leave for import in to the UK and EU.

c) During Production Inspections (DUPRO), where we may send an independent assessor, again from Asia Inspection or Intertek, to visit a factory during production and inspect defined elements to ensure that the production will meet our specifications.

d) Container Loading Check (CLC) is the final inspection and ensures the final details of the product are correct and the actual ordered quantity is loaded securely onto the container before signing off.

5.3 Factory & Social Audits
If the factory we are working with does not already have satisfactory certification we will request that independent factory and social audits are
carried by Asia Inspection or Intertek using either SMETA or SA8000 audits and that they are carried out by certified local auditors.

The majority of the factories we use will have been previously audited (using audits such as SMETA, SA8000, BSCi, CCC etc.) and as long as the audits were carried within a reasonably recent time period these may be acceptable.

We work with our supply chain to ensure that their testing documents are up to date and available on request.

5.4 Benchmarking & Key Performance Indicators
We are increasingly able to measure our suppliers year-by-year and against industry and performance benchmarks identified by Asia Inspection; AI carry out 100,000+ Audits and Lab test per year and are therefore able to provide audit performance against their benchmark in addition to compliance to SMETA and SA8000.

Where appropriate we have or are implementing a programme of monitoring KPIs with the factories we use regularly so that we are able to track
improvements over time and identify any reduction in performance or compliance quickly.

We have published the findings of some of this data is our CSR Report 2017.

5.5 Requirements of our direct manufacturing contractors, a summary:
• Demonstrate they manage a business to high ethical standards.
• Have an up-to-date and well maintained manufacturing plant.
• Be accredited with, or working towards, a global quality management programme such as ISO9001.
• Be accredited with, or working towards, a global environmental management programme such as ISO14001 and be consciously trying to minimise their environmental impact.
• Respect staff and provide them with a caring community environment
• Provide good natural light, clean air and a healthy working environment
• Give workers up to three meals a day and, if necessary, provide them with accommodation
• Pay the minimum wage, and comply with the recent ‘125’ amendment to the ETI base code regarding labour hours whereby overtime is paid at a minimum of 125% of their basic wage.
• Offer opportunities for training and promotion.

5.6 European and North American Supply Chain
Products which we source from within the European Union are deemed to be in free EU circulation and do not require additional testing although we encourage our suppliers to share audits and documentation when necessary.

Where required by EU law we ensure that products sourced from North America carry the required EU certification such as is required by EN71 for example in relation to the safety of products that may be used by children.

6. THE ENVIRONMENT
We are still working towards ISO14001, an environmental management system, and planned to apply after the 2015 revision, the publication of which was delayed but have prioritized our transition to ISO9001: 2015 and once complete will formally apply for ISO14001.

In the meantime we have implemented the following:

  • Comply with current environmental legislation.
  • Display and provide this policy to all customers, employees & sub-contractors.
  • Review this policy annually, taking into account any audit findings.
  • Manage waste effectively and seek to reduce and recycle wherever
    possible.
  • Conserve water and energy.
  • Evaluate our use of IT, consumable and office materials in line with environmental objectives.
  • Ensure employees are aware of their own responsibility to the environmental well being, given training and information where
    applicable.
  • Ensure our purchasing policy and supply chain compliments our
    commitment to minimize our environmental impact.
  • Ensure responsible procurement of goods and services from ethical sources.
  • Suggest our employees car share or use hybrid cars to reduce our impact in travelling to and from work.
  • Recycle our office waste wherever possible.
  • Implement a central location for waste paper which is shredded and
    delivered to Barnet Council waste recycling centre.
  • We do not use hazardous materials as we do not manufacture on our premises.

6.1 Transport
We ship by sea wherever possible.

6.2 Packaging
The majority of our cardboard in our packaging is either recycled and/or certified by the Forestry Stewardship Council.
We reuse cardboard packaging wherever possible, we use the minimum packaging necessary and ensure that it is recyclable wherever possible.

6.3 Forest Stewardship Council (FSC) is an independent non-profit organisation that promotes the responsible management of the world’s forest. Many of the paper and wooden products are FSC certified and will carry one of the FSC labels showing that the product is FSC 100%, FSC Mix or FSC Recycled.

6.4 WEEE Directive
We have been signed up since 2008 and perform our required reporting in accordance with European Community directive (2012/19/EU0 on Waste Electrical and Electronic Equipment directive) WEEE Regulations 2013. Our Producer registration number is WEE/GC0309VW.

6.5 RoHS
The Restriction of Hazardous Substances Directive 2002/95/EC, (RoHS 1), short for Directive on the restriction of the use of certain hazardous
substances in electrical and electronic equipment, was adopted in February 2003 by the European Union and took effect on 1 st July 2006. RoHS restricts the use of the following six substances:
• Lead (Pb)
• Mercury (Hg)
• Cadmium (Cd)
• Hexavalent chromium (Cr 6+ )
• Polybrominated biphenyls (PBB)reach
• Polybrominated diphenyl ether (PBDE)

PBB and PBDE are flame retardants used in several plastics. Hexavalent chromium is used in chrome plating, chromate coatings and primers, and in
chromic acid.

The maximum permitted concentrations in non-exempt products are 0.1% or 1000 ppm (except for cadmium, which is limited to 0.01% or 100 ppm) by weight.
All products we import into the European Union, such as USB memory sticks and rechargeable powerbanks, are RoHS compliant.

6.6 CE Mark
The CE marking is the manufacturer's declaration that the product meets the requirements of the applicable EC directives. Where applicable and where we bring a product in the EU, we will independently assess and test the product in order to comply with and bear the CE mark.

6.7 British Standards & the BSI Kite mark certification symbol
British Standards are the standards produced by BSI Group which is incorporated under a Royal Charter (and which is formally designated as the
National Standards Body for the UK). Products are commonly specified as meeting a particular British Standard, and in general this can be done without any certification or independent testing. The standard simply provides a shorthand way of claiming that certain specifications are met, while encouraging manufacturers to adhere to a common method for such a specification.

If a product displays the BSI Kite mark, then the product has also been tested by the BSI to meet the required standard.

6.8 REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) is an EU regulation which came into force on 1 st June 2007 and will be phased over ten years until 2017. REACH addresses the production and use of chemical substances, and their potential impacts on both human health and the environment. Much of our supply chain is already REACH compliant.

6.9 ZDHC (Zero Discharge of Hazardous Chemicals) – Hazardous chemicals audit initiative, with the aim to achieve zero hazardous chemical discharge by 2020. This initiative is based on an auditing programme for chemicals and the environment.

All the manufacturers we work with directly are required not to use any of the chemicals on our restricted substance list. If required we can request Asia Inspection carry out this audit.

7. Health & Safety
We shall provide, and strive to maintain, a clean, healthy and safe working environment in line with our UK Government Health and Safety Executive (HSE) guidelines and safe systems of work. All employees are made aware of our Health & Safety Policy.

We have been assessed for fire safety by Victory Fire and are certified as such. Where necessary we ensure our products meet EN standards for health and safety, for example, EN71 in relation to products which may be used by children and EN471 the European Standard for high visibility work wear.

Health & Safety indicators form part of the audits which we require from many of our non-EU suppliers. We will be including the data from these audits in future CSR reports.