Child Labour Policy

1. POLICY STATEMENT

1.1 H2O Logistics Limited (“H2O”) acknowledges the fact that child labour occurs in many countries. H2O condemns child labour in any form. The complexity of the child labour issue requires a consistent, long-term effort to create sustainable and broad-based solutions in order to reach our goal; that no products or services delivered to H2O involve child labour.
1.2 H2O respects different cultures and values in countries where H2O operates and sources its products but does not compromise on the basic requirements regarding the rights of children.
1.3 H2O Child Labour Policy has been established in order to make H2O position clear to suppliers and their co-workers, as well as any other parties. The requirements in this code of conduct are mandatory to all suppliers and their subcontractors.

2. GENERAL PRINCIPLE

2.1 H2O does not accept child labour. We support the United Nations (U.N.) Convention on the Rights of the Child (1989). This child labour policy is based on this Convention.
2.2 This policy is based on the International Labour Organisation (ILO) Minimum Age Convention no. 138 (1973). According to this convention, the word “Child” is defined as any person below fifteen (15) years of age, unless local minimum age law stipulates a higher age for work or mandatory schooling, in which case the higher age would apply. If, however, the local minimum working age is set at fourteen (14) years of age in accordance with exceptions for developing countries, the lower age will apply.
2.3 This Policy also incorporates the ILO Convention on the Worst Forms of Child Labour no. 182 (1999).

3. IMPLEMENTATION

3.1 All actions to avoid child labour shall be implemented by taking the child’s best interests into account. H2O requires that all suppliers shall recognise the U.N. Convention on the Rights of the Child, and that the suppliers comply with all relevant national and international laws, regulations, and provisions applicable in the country the work takes place.
3.2 Suppliers are obliged to take the appropriate measures to ensure that no child labour occurs at suppliers’ and their sub-contractors’ places of work.
3.3 If child labour is found in any place of work, H2O will require the supplier to implement a corrective action plan. If corrective action is not implemented within the agreed timeframe, or if repeated violations occur, H2O will terminate all business with the supplier concerned. The corrective action plan shall take the child’s best interests into consideration, i.e. family and social situation, and level of education. Care shall be taken not merely to move child labour from one supplier’s workplace to another, and facilitate more viable and sustainable alternatives for the child’s development.
3.4 The supplier shall effectively communicate to all its sub-contractors, as well as to its own co-workers, the content of H2O Child Labour Policy, and ensure that all measures required are implemented accordingly.

4. YOUNG WORKERS

4.1 H2O supports the legal employment of young workers, where appropriate and where supported by its clients relevant policies.
4.2 Young workers of legal working age have, until the age of 18, the right to be protected from any type of employment or work which, by its nature or the circumstances in which it is carried out, is likely to jeopardise their health, safety or morals.
4.3 H2O therefore requires all its suppliers to ensure that young workers are treated according to the law; this includes measures to avoid hazardous jobs, night shifts and ensure minimum wages. Limits for working hours and overtime should be set with special consideration to the workers’ young age.

5. LABOUR FORCE REGISTER

5.1 The supplier shall maintain documentation for every worker verifying the worker’s date of birth. In countries where such official documents are not available, the supplier must use appropriate assessment methods as per local practice and law.

6. MONITORING

6.1 All suppliers are obliged to keep H2O informed at all times about all places of work (including their subcontractors). Any undisclosed places of work found would constitute a violation of this code of conduct.
6.2 Through the General Purchasing Conditions for the supply of services H2O, H2O has reserved the right to make unannounced visits at any time to all places where services are provided (including their subcontractors). H2O furthermore reserves the right to assign, at its sole discretion, an independent third party to conduct inspections in order to ensure compliance with H2O Remediation.
6.3 If child labour is found in the supply chains of H2O it will seek to work in partnership with the supplier and appropriately qualified organisations to develop a responsible solution that is in the best long-term interests of the children. The supplier and H2O will agree a corrective action plan, which may comprise the following actions:
6.3.1 Collate a list of all potential child labourers and young workers;
6.3.2 Seek advice and help from a recognised local non-governmental organisation that deals with child labour or the welfare of children[1];
6.3.3 Develop a remediation plan that secures the children’s education and protects their economic well-being, in consultation with H2O and where possible a local NGO, and in consultation with and respecting the views of the child;
6.3.4 Explain the legal requirements and restrictions on working ages to the children and assure them that, if they wish, they will be employed when they reach working age;
6.3.5 Understand the children’s desires and explore the opportunities for them to re-enter education;
6.3.6 Whether the child contributes to the livelihoods of their family or they are self-dependent, his or her wage should continue be paid until they reach working age, or until an alternative long-term solution has been agreed with the child and their family (for example employment of an unemployed adult family member in place of the child labourer);
6.3.7 Ensure that the child worker has adequate accommodation and living conditions;
6.3.8 Document all actions; and
6.3.9 Develop processes to prevent recurrence.
6.4 Do not:
6.4.1 Expel any of the suspected or confirmed child labourers and/or young workers;
6.4.2 Threaten the children or their families or hamper the progress of investigation and remediation; and
6.4.3 Conceal or falsify any documentation.
6.5 Such actions will be considered by H2O as evidence that the supplier is not committed to child labour remediation, in breach of this Child Labour Policy.

[1] Save the Children (http://www.savethechildren.net/) has produced guidance on how to carry out interviews with child workers, and has contacts with local NGOs, with local knowledge and expertise in child labour issues, in many sourcing countries.

Anti Bribery & Corruption

1. ABOUT THIS POLICY

1.1 It is our policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships.
1.2 Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. Any Service Provider or supplier who breaches this policy may have their contract terminated with immediate effect.
1.3 This policy does not form part of any employee’s or worker’s contract of employment or engagement and we may amend it at any time.

2. WHO MUST COMPLY WITH THIS POLICY?

2.1 This policy applies to all persons working for, or providing services to us, or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.

3. WHAT IS BRIBERY?

3.1 ‘Bribe’ means a financial or other inducement or reward for action which is illegal, unethical, a breach of trust or improper in any way. Bribes can take the form of money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or any other advantage or benefit.
3.2 ‘Bribery’ includes offering, promising, giving, accepting, or seeking a bribe.
3.3 All forms of bribery are strictly prohibited. If you are unsure about whether a particular act constitutes bribery, raise it with a representative of the Management Team either in person or by email to compliance@h2ologistics.co.uk.
3.4 Specifically, you must not:
a)   give or offer any payment, gift, hospitality, or other benefit in the expectation that a business advantage will be received in return, or to reward any business received;
b)   accept any offer from a third party that you know or suspect is made with the expectation that we will provide a business advantage for them or anyone else;
c)   give or offer any payment (sometimes called a facilitation payment) to a government official in any country to facilitate or speed up a routine or necessary procedure;
3.5 You must not threaten or retaliate against another person who has refused to offer or accept a bribe or who has raised concerns about possible bribery or corruption.

4. GIFTS AND HOSPITALITY

4.1 This policy does not prohibit the giving or accepting of reasonable and appropriate hospitality for legitimate purposes such as building relationships, maintaining our image or reputation, or marketing our products and services.
4.2 A gift or hospitality will not be appropriate if it is unduly lavish or extravagant, or could be seen as an inducement or reward for any preferential treatment (for example, during contractual negotiations or a tender process).
4.3 Gifts must be of an appropriate type and value depending on the circumstances and taking account of the reason for the gift. Gifts must not include cash or cash equivalent (such as vouchers), or be given in secret. Gifts must be given in our name, not your name.
4.4 Promotional gifts of low value such as branded stationery may be given to or accepted from existing customers, suppliers, and business partners.

5. RECORD-KEEPING

5.1 You must declare and keep a written record of all hospitality or gifts given or received. You must also submit all expenses claims relating to hospitality, gifts or payments to third parties in accordance with our expenses policy and record the reason for expenditure.
5.2 All accounts, invoices, and other records relating to dealings with third parties including suppliers and customers should be prepared with strict accuracy and completeness. Accounts must not be kept “off-book” to facilitate or conceal improper payments.

6. HOW TO RAISE A CONCERN

6.1 If you are offered a bribe, or are asked to make one, or if you suspect that any bribery, corruption or other breach of this policy has occurred or may occur, you must notify a representative of the Management Team either in person or by email to compliance@h2ologistics.co.uk.