Galerie, Inc. is committed to fair labor practices throughout all our entities, including, but not limited to, our vendors and suppliers. We purposefully pursue responsible business behaviors and are devoted to maintaining a culture in which employees feel comfortable and supported in our stance against the use of forced labor in any part of our supply chain as prohibited by the Uyghur Forced Labor Prevention Act. Galerie prohibits retaliation against any employee who reports in good faith or who participates in any investigation of a possible violation of the code of conduct.
1.0 Introduction & Undue influence
This Vendor / Supplier Code of Conduct sets forth the commitment ofGALERIEto do business only with those manufacturers and suppliers that share its commitment to fair and safe labor practices. It applies to all suppliers and/or contractors providing products to GALERIE.
1.01 This Code of Conduct is divided into sections. Section 2.0 sets forth the general principles upon which the Vendor/Supplier Code of Conduct is based. Section 3.0 sets forth the standards that will be used in evaluating compliance and Section 4.0 presents methods for the evaluation of vendor/supplier compliance with the Code of Conduct.
1.02 The Vendor/Supplier Code of Conduct defines our minimum expectations. Since no Code can be all inclusive, we expect our vendors and suppliers to ensure that no abusive or exploitative conditions and practices or unsafe working conditions exist at the facilities where our products are manufactured.GALERIEwill not tolerate any vendor or supplier that directly or indirectly, through its subcontractors, violates the laws of the country where the product is manufactured or knowingly violates the standards established byGALERIE. GALERIEwill take appropriate action in accordance with its policy upon notification of such violation.
1.03 It is the responsibility of the vendor/supplier to insure a copy of this Code of Conduct is translated into the native languages of the workforce, and prominently displayed within each facility where GALERIEproduct is being manufactured.
1.04 Undue Influence, bribery and corruption are against the law. It costs suppliers, businesses, and customers billions of dollars and leads to a permanent loss of trust. It is not sustainable.
Many of our customers require social compliance audits by 3rd parties. GALERIE believes in conducting business in an open environment based on ethics and integrity. All of our business transactions should be straight forward and transparent. No money or other favors should be solicited by audit company associates nor offered by our vendor partners for any purposes. Vendors should report any solicitation made to them by audit company personnel directly to GALERIE Quality Assurance and that customer’s headquarters immediately.
2.0 General Principles & Employment Practices
2.01 Forced Labor - There shall not be any use of forced labor, whether in the form of prison labor, indentured labor, bonded labor or otherwise. Galerie, Inc. is committed to fair labor practices throughout all our entities, including, but not limited to, our vendors and suppliers. We purposefully pursue responsible business behaviors and are devoted to maintaining a culture in which employees feel comfortable and supported in our stance against the use of forced labor in any part of our supply chain as prohibited by the Uyghur Forced Labor Prevention Act. Galerie prohibits retaliation against any employee who reports in good faith or who participates in any investigation of a possible violation of the code of conduct.
2.02 Child Labor - No person shall be employed at an age younger than 16 (or 14 where the governing law allows such employment), or younger than the age for completing compulsory education if the age in the country of manufacture is greater than 16.
2.03 Harassment or Abuse - Workers shall be treated with respect and dignity. Workers shall not be subject to any physical, verbal, sexual or psychological harassment or abuse in connection with their employment.
2.04 Health and Safety - Employers shall provide a safe and sanitary working environment in order to avoid preventable work related accidents and injuries.
2.05 Nondiscrimination - Workers should be employed and compensated based upon their ability to perform their job, rather than on the basis of gender, race, religious or cultural beliefs.
2.06 Wages and Benefits - Employers should recognize that wages are essential to meeting their employees’ basic needs. Employers shall pay workers for all work completed and shall pay at least the minimum wage required by law or the prevailing industry wage, whichever is higher, and shall provide legally mandated benefits.
2.07 Overtime - It is understood that overtime is often required in the manufacturing process. In addition to compensation for regular hours of work, workers shall be compensated for overtime hours at such a premium rate as legally required or, in countries where there is no legal standard, at industry standards. In no event shall this be at a rate less than the regular hourly rate. Factories shall carry out operations in ways that limit overtime to a level that ensures productive and humane working conditions.
2.08 Work Hours - As part of normal business operations, workers shall be entitled to at least one full day off out of each seven-day week. Suppliers should not require in excess of a 60-hour work week on a regularly scheduled basis, and any such work week shall be subject to the laws regarding the payment of overtime. In the case of those countries where laws do not limit the hours of work, workers should not be required to work on a regular basis in excess of a regular work week plus 12 hours overtime. Workers shall not be asked or required to take work home or off premises.
2.09 Compliance with Laws – All Standards set forth in this Code of Conduct are subject to compliance with applicable local law. All vendors shall operate in full compliance with the laws of their respective country of manufacture. If any standard set forth in this Code of Conduct is, in the vendor’s judgment, deemed to violate an applicable local law it must adviseGALERIEpromptly in writing.
2.10 Subcontractors - All subcontractors must be disclosed toGALERIEprior to production, and all subcontractors and facilities must be pre-approved by GALERIE. Any subcontractor retained by aGALERIEsupplier must be in compliance with this Code of Conduct and each of GALERIE’ssuppliers is responsible for ensuring its subcontractor’s compliance.
2.11 Customer Standards – In the event that otherGALERIEcustomer requirements for social responsibilities or codes of conduct exceed the standards in this Code of Conduct, vendors / suppliers will follow the guidelines and requirements agreed to in those customer requirements.
3.0 Verification Standards
3.01 GALERIEwill use the following standards in its evaluations.
3.02 Age and Wage Verification –
3.02.1 Manual or electronic time cards should be used for hourly workers. Electronic time clocks should include a battery backup. For “piecework” workers, an industry recognized system, capable of audit verification, should be used.
3.02.2 Employers should provide to workers, for each pay period, a clear and understandable wage statement that includes days worked, wage or piece rate earned per day, hours of overtime, bonuses, allowances and a description of any and all deductions.
3.02.3 All facilities are required to maintain official documentation in order to verify each worker’s date of birth, as well as appropriate records documenting that the employer adheres to all restrictions under local labor laws that apply to juvenileworkers.
3.03 Health and Safety –
3.03.1 Factories should have adequate circulation and ventilation.
3.03.2 Free potable water should be reasonably accessible to all workers throughout the working day.
3.03.3 Workers should have access to reasonably clean and private toilet facilities in adequate numbers for each gender. We recommend that facilities maintain a toilet to worker ratio of 1 to 30.
3.03.4 There is to be no use of corporal punishment.
3.03.5 Work areas should be sufficiently lit so that manufacturing tasks may be safely performed. We recommend the following standards:
Cutting, Assembly and Finishing Operations: 50-80 ft. candles
Inspection: 80-100 ft. candles
Storage: 30-50 ft candles
3.03.6 All equipment should be tested regularly and properly maintained. Operational safety devices should be installed on equipment where appropriate.
3.03.7 Where appropriate, factories should make available personal protective equipment to workers performing hazardous tasks.
3.03.8 Hazardous and combustible materials should be stored in safe, secure and well ventilated areas.
3.03.9 Each factory building should have at least one well-stocked first aid kit. It is recommended that each floor of each building have at least one well-stocked first aid kit.
3.03.10 We require that each enclosed manufacturing facility have an adequate number of clearly marked, unlocked exits in order to provide for an effective evacuation in case of emergency. By adequate, it is meant that each work station should be within 200 feet of an exit. It is recommended that all exits have battery operated emergency lights placed above them.
3.03.11 Aisles, exits and stairwells should be kept clear of any obstructions that could prevent the orderly evacuation of workers. Exit stairwells and corridors and aisles leading to them are required to be at least 22 inches wide. It is recommended that they be at least 44 inches wide. Exits should be at least 33 inches wide
3.03.12 Each facility should have appropriate fire prevention capability based upon the size of the facility and number of workers normally occupying the premises. While we recommend that facilities install fire hoses, extinguishers, overhead sprinklers, alarms and other warning and control devices, our minimum standard, where fire hoses oroverhead sprinklers are not present, is one fully charged fire extinguisher within 75 feet of each work station.
3.03.13 Fire extinguishers should be properly maintained and/or serviced annually, tagged with the most recent service date, and properly deployed throughout the premises to be visible and accessible to workers in case of fire. Fire extinguishers should be inspected once each month and tags should note the date of the inspection and the initials of the person doing the inspections.
3.03.14 Factories should conduct a minimum of one emergency evacuation drill per year.
3.03.15 Emergency evacuation diagrams should be posted and clearly visible to employees.
3.03.16 Workers should not be exposed for extended periods to noise levels above 80 decibels without being required to use factory provided safety equipment.
3.04 Dormitories and Living Facilities –
3.04.1 The following standards shall apply where workers are housed in facilities provided by the manufacturer.
3.04.2 Facilities should have adequate ventilation and circulation.
3.04.3 Free potable water should be readily accessible.
3.04.4 Clean and private toilet and bathing facilities should be reasonably accessible.
3.04.5 Living spaces should be segregated by gender.
3.04.6 Each housing facility should have at least one well-stocked first aid kit. It is recommended that each floor of each facility have at least one well-stocked first aid kit.
3.04.7 Each housing facility should have an adequate number of unlocked and clearly marked exits for evacuation in case of emergency.
3.04.8 Aisles, exits and stairwells should be kept clear from any obstructions that could prevent orderly evacuation.
3.04.9 Each living facility should have appropriate fire prevention capability based upon the size of the facility and number of workers normally occupying the premises. The minimum standard, where fire hoses or overhead sprinklers are not present, is one fully charged fire extinguisher per 1000 sq. ft. of living space.
3.04.10 Fire extinguishers should be properly maintained and/or serviced annually, tagged with the most recent service date, and properly deployed throughout the premises to be visible and accessible to residents in case of fire. Fire extinguishers should be inspected once each month and tags should note the date of the inspection and the initials of the person doing the inspections
3.04.11 A minimum of one emergency evacuation drill per year should be conducted and documented.
3.04.12 Emergency evacuation diagrams should be posted and clearly visible to employees.
3.04.13 The living space per worker in their sleeping quarters must meet all minimum legal requirements. We recommend that each worker be provided with a minimum of 50 square feet of space exclusive of common areas and that individual mats or beds are provided to each worker.
4.0 Verification Methods:
4.1 GALERIEholds its suppliers accountable that the merchandise produced for it is manufactured in compliance with this Code of Conduct.
4.2 GALERIEexpects its suppliers to monitor their compliance to this Code of Conduct. It is recommended that suppliers conduct self audits annually. Those results should be reported along with corrective action plans, to GALERIE.
4.3 GALERIEwill utilize, where appropriate, internal as well as third party (unaffiliated) monitors to conduct on-site evaluations and inspections of its suppliers’ facilities, as well as those of its subcontractors.
4.4 GALERIEwill use the following methods to evaluate its suppliers and their facilities:
4.4.1 Each ofGALERIE’ssuppliers must sign and return a copy of this Code of Conduct, showing their understanding and commitment to compliance.
4.4.2 Acceptance ofGALERIE’spurchase orders and shipment of merchandise toGALERIErepresents a continuing affirmation of compliance.
4.4.3 GALERIErepresentatives may conduct pre-production evaluation of supplier facilities as well as any subcontractor’s facilities.
4.4.4 GALERIErepresentatives may conduct unannounced (without notice) and unaccompanied inspections to supplier and subcontractor facilities for the purpose of auditing compliance to this Code of Conduct. Inspections may be conducted byGALERIErepresentatives or by third parties retained byGALERIE. Inspections may include, but will not be limited to the following.
4.4.4.1 The ability to conduct interviews with employees, without fear of repercussion from employers.
4.4.4.2 Inspections of employee files, including time cards and wage statements.
4.4.5 Inspection results will be provided to the supplier and Corrective Action Plans will be required for all discrepancies found.
4.4.5.1 Corrective Action Plans must be provided toGALERIEQualityAssurance within 14 days of receiving the inspection results.
4.4.5.2 Inspection results and Corrective Action Plans may be provided toGALERIEcustomers when appropriate or required.
4.4.5.3 GALERIEand its customers may disqualify suppliers that do not meet brand expectations. Disqualification could result in the cancelation of orders and chargebacks for unsalable goods.