Transparency & Traceability

Kate Sylvester dresses Summer 2018

Code of Conduct


  • Partners shall provide a safe and healthy working environment for all employees, in order to prevent accidents and/or injury arising out of or occurring the course of work or as a result of the operation of facilities.
  • Partners shall comply with all applicable laws regarding workplace safety.
  • Employers shall ensure that workers have access to clean drinking water, sanitary washing facilities and an adequate number of toilets, fire extinguishers and fire exits and that workplaces provide adequate lighting and ventilation.
  • Employers shall ensure that the aforementioned standards are also met in any canteen, dormitory and rest and recreational areas that are provided for workers


  • No person shall be employed on a fulltime basis at an age younger than 16 years old, or younger than the age for completing compulsory education where the age is higher than 16 years old.  Employers must verify the age of their employees and maintain copies of their workers' proof of age. Employers must follow all applicable laws and regulations regarding working hours and conditions for minors.


  • No person shall be subjected to involuntary or forced labour.  Partners must ensure freedom of movement for all workers and respect their right to enter and leave employment willingly and voluntarily.


  • No person shall be subject to any form of discrimination in employment.  This includes gender, race, religion, age, disability, pregnancy, marital status, sexual orientation, political opinion, or social or ethnic identity.


  • No person shall be subject to any form of harassment, or coercion, including verbal, physical, sexual, and/or psychological abuse.  All employees are to be treated with dignity and respect.


  • All partners must recognise and respect the right of workers to freedom of association and collective bargaining, allowing workers to join organisations of their choice.  Partners must provide effective options for workers whereby any internal disputes can be respectfully addressed and resolved in a collaborative manner.


  • Partners must pay each employee /contractor at least the minimum wage according to the local laws, and regulations or match the prevailing local manufacturing or industry rates, whichever is higher. Overtime pay shall be calculated at the legally required rate, regardless of whether workers are compensated hourly or by piece rate. All people employed directly by us or by companies we partner with or who manufacture for us are paid at least minimum wage and recognise that wages are essential to meeting employee’s basic needs.


  • Employers shall not require employees to work more than 60 hours per week (including overtime) or more than any maximum number of hours per week established by applicable laws and regulations, whichever is less. Employers shall guarantee that employees receive at least one full day off in every seven-day week.


  • Partners must endeavour to minimise any negative impact to the environment through means such as minimising waste, increasing efficiencies, and eliminating hazardous substances from products and operations. This includes taking measures to reduce environmental impact in the areas of chemicals, hazardous waste, wastewater, water and energy usage.
  • Employers shall comply with all applicable laws and regulations in respect of protecting the environment and maintain procedures for notifying local authorities in the event of an environmental accident resulting from the employer's operations.


  • Any subcontractors that are used by primary partners and suppliers must agree to comply with this code of conduct, and must be monitored on a regular basis for compliance.


  • Employers shall familiarise employees with this Code of Conduct and display this Code of Conduct, translated into local languages, in a place readily visible and accessible to employees in their workplace.


  • Employers shall comply with all legal requirements applicable to the conduct of their businesses, including but not limited to, those set out above and all laws related to bribery, corruption and other prohibited business practices.


  • Employers authorise Conway Sylver Ltd. and its independent external auditors to conduct scheduled and unscheduled inspections and audits of their facilities for the purpose of ensuring compliance with this Code of Conduct. Auditors have unrestricted access and the right to review all employee-related books and records maintained by employers and to interview employees. Audits are carried out prior to commencement of contract with all factories and ongoing at least once every 18 months.


  • In the event of a violation, Conway Sylver Ltd and the employer concerned shall agree upon a corrective action plan to eliminate the problem in a timely manner. 
  • A period of one month is the stand-down for a re-audit. If the Code is breached on three occasions Conway Sylver Ltd will advise corrective action resulting in termination of the business relationship.
  • Conway Sylver Ltd is committed to long-term relationships with suppliers and manufacturers and shall in any way possible help to provide implementation assistance required for the process of continuous review and improvement of working conditions, including training and in-factory consultations.


  • Employers must, and must ensure each employee, officer and sub-contractor used for the supply of goods or performance of services under or in connection with this Code of Conduct: comply with all applicable laws relating to bribery and corruption; (a) not do or omit to do anything if such act or omission is likely to cause Conway Sylver Ltd to be in breach of any such applicable laws; and (b) not give or receive any bribes, including in relation to any public official.