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Vendor Code of Conduct

Clogau Gold of Wales Ltd is committed to operating in accordance with ethical trading standards
as set out in this document. Clogau will make every effort to work with its vendors in order to
reach the standards set out in this code.

There are 12 key principles to Clogau’s Vendor Code of Conduct and definitions of each are provided in this document;

1. Employment is freely chosen
2. Freedom of association and the right to collective bargaining are respected
3. Working conditions are safe and hygienic
4. Child labour shall not be used
5. Living wages are paid
6. Working hours are not excessive
7. No discrimination is practised
8. Regular employment is provided
9. No harsh or inhumane treatment is allowed
10. Responsible environmental practices
11. Zero tolerance of conflict products
12. Compliance to the 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

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 a 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, subcontracting, 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.

10. Responsible environmental practices.

Clogau believes that a business should protect, and where possible, improve the environment, promote sustainable development and prevent the wasteful use of natural resources. We expect our business associates to comply with all current local environmental laws and regulations. Additionally, we encourage our vendors to promote responsible environmental practices.

11. Zero tolerance of conflict products.

Clogau neither supports nor condones the purchase of so –called ‘’conflict diamonds.’’ Or any other conflict product ‘’. All suppliers must comply with the Kimberly Process. Clogau will not knowingly purchase or sell any products that originate from a group or a country which supports or engages in illegal, inhumane or terrorist activities.

12. Compliance to the code

Compliance to Clogau’s business ethics code is mandatory if you are going to do business with us. Clogau intends to monitor compliance by means of factory audits conducted by trained Clogau employees. Vendors are requested to provide Clogau with full access to their production facilities and to any documents pertinent to legal employment or environmental practices. Any vendor found to be in violation of this code will be notified of corrective action required to avoid termination of our business relationship.

Diagram outlining the business benefits of compliance for suppliers

• Identify risks
• Finding solutions
• Bringing your workplace into line with Clogau’s standards
• Reduced risk of harm to workers
• Reduced risk of accidents
• Reduced risk of delays
• More efficient workforce
• Able to attract & keep skilled workers
• The customers of Clogau Gold of Wales Ltd trust us to supply products that are made in good conditions, by people whose health, labour and human rights are protected
• Global purchasers want to buy from suppliers who can demonstrate good working conditions and labour standards
• Keep ahead of your competitors
• Create new opportunities for your business in the global market