Dear Friends and Partners,

At KIngly, we operate in proactive ways that enhance society, environment and the common good of all.

I am pleased to confirm that Kingly reaffirms its support of the Ten Principles of the United Nations Global Compact in the areas of Human Rights, Labour, Environment and Anti-Corruption.

In this annual Communication on Progress, we describe our actions to continually improve the integration of the Global Compact and its principles into our business strategy, culture and daily operations. We also commit to share this information with our stakeholders using our primary channels of communication.

We have a code and it’s based on the 6 pillars of Kingly:

PLANET: Reduced environmental impact through certifications and third-party auditors. To name just a few, we have a zero waste socks knitting facility. The oil that runs our machines is GOTS approved. The ground water is free of oil. Thanks to IS0 14001, whereby a separator holds back the oil and this way we can dispose of it responsibly. We send textile offcuts to a recycling plant that upcycle it into new yarn that we can use for knitting socks.

PEOPLE: Through our Smeta Pillar 4 audit and now approved factory, we have improved employee safety, health and benefits for all employees. In addition to that, a bonus system and rewards for all that makes this company feel like family. But this extends outwards to our supply chain where our suppliers are committed and share the same values as us. Each person has signed a Code of Conduct so they understand and abide by the correct work ethic.

MARKETPLACE: We abide by maximum respect for our staff, our customers and others involved. From signed NDA’s, legal, ethical and improved customer service, you name it we adapt, respect and abide by the rules. We are upfront honest. Any communication with customers and suppliers is confidential and truthful.

COMMUNITY: We support the greater good of society. We support the homeless, the under privileged, Charities, and hospitals. We are anonymous and don’t publish our donations on social media because we don’t need the recognition. We donate socks and apparel, sponsor events, get involved with the community and are always open to any new ventures.

CORE VALUES: We strive to offer the best value for your money based on our commitment to supply earth friendly products. Quality of products, service, quality of relationships and great customer service is what we aim for. We care about our customers, for this to happen we have to have talented, passionate and committed workers. Integrity and equality mean the earth to us. Our aim is long term business relationships and for this to happen we strive to improve our standards of excellence, organization and processes. The end game is a win-win relationship for all.

TRANSPARENCY & TRACEABILITY: We are the exact opposite to ‘Greenwashing’.
What we do is show our customers what happens behind the order, we expose the ethical and earth friendly supply chain, we issue third party transaction certificates and so on. It’s all backed up by third party evidence.
Enter the BCOME Cradle to Grave Sustainability platform where we are able to provide our customers with quality data quickly and safely. The BCOME Database is a private sector database that brings together more than 5,000 aggregate data from the textile sector. BCOME validates, classifies and verifies each of the sectoral data in its database in units of mass (kg).
The methodology of the sustainability platform includes procedures that make it possible to evaluate the degree of sustainability of a product from four areas of
IMPACT, PLANET, PEOPLE, TRANSPARENCY & CIRCULARITY.
It is built from a 360º vision of sustainability, understanding that behind each product there is a universe of development and processes with environmental, social, economic and ethical implications, and that they must be treated with equal importance. The intelligent QR Code system validates and displays the information!

In conclusion, we are proud that we have come this far but we must not be complacent but pro-actively move forward to maximize our value to society and the environment. There is no Planet B.

Yours faithfully

Rob Armour
Founder & CEO

Kingly believes that we have a responsibility to be a good corporate citizen. Having a significant position in the markets we serve, we believe we can help shape and influence standards wherever we do business.

We are 100% behind the values and principles of the Universal Declaration of Human rights.

This Code of Conduct document serves to outline the behaviours of Kingly when engaged in producing goods or services for or on behalf of our customers.

Kingly comply with:
• All applicable UK laws and regulations.
• All applicable European Union laws, directives and regulations (including those governing Public Procurement, where relevant)
• The relevant laws, regulations and so on of other territories in which we operate
• International laws, treaties and agreements to which the UK government is party (including, for example, any United Nations-approved trade sanctions)
Note: this includes not only those laws directly applicable to the selling of goods
and services - it includes amongst others the laws on:
• taxation – Kingly will not be a party to the evasion of income, sales, corporate, value added or other taxes, customs
• duties, or other charges, either by P&SM Professionals, their customers, or their Suppliers
• environmental regulations
• employment, health and safety
• bribery & corruption

Kingly is committed to the fair and effective application of laws and regulations. There is therefore a positive duty on Kingly and its Suppliers to report and refer any and all reasonably founded suspicions of illegal activity (for example, attempts at corruption, evidence of anti-competitive or cartel-like activity, breaches of employment or environment law).

Accountability and Auditability
Kingly expects Suppliers to maintain systems, whether manual or electronic, that will, for all purchases, contracts and commitments, record, identify and as appropriate provide records that can be audited at a later date.

Fair Business Practice
Kingly conduct their business and activities in a competitive manner and expect their Suppliers, subcontractors and agents do the same. Suppliers shall not violate applicable antitrust and anti-competition laws, rules and regulations, which, among other things, generally prohibit price-fixing, dividing territories and bid-rigging.
Kingly dealings and transactions with Suppliers will be at arms-length.

To that end, Kingly Suppliers and Kingly Staff must not be in a situation where a conflict of interests exists because of a family relationship, a personal relationship, a business relationship, an investment or due to some other connection or relationship. Any such relationship or investment that could possibly give rise to a conflict of interest must be promptly disclosed by the Supplier
Suppliers are expected to promptly report suspected and actual violations of these guidelines, and any other unethical or illegal activities to Kingly.

Employment Practice
Kingly expect Suppliers within their own factories and their direct supply chain to:

• comply with all applicable regulations regarding modern slavery and to take measure to identify and eliminate the risk of modern slavery within their own operations and that of its own supply chain.
• provide a safe and healthy environment for employees
• comply with all laws regarding maximum work hours, vacation time, leave periods, holidays and to provide payment/ benefits for overtime hours
• only employ workers with valid documentation that proves their right to work
• respect the rights of employees to freely associate, organise and collectively bargain
• base all conditions of employment on an individuals ability to do the job and not on personal characteristics or beliefs. Employment decisions should be based on lawful non-discriminatory factors which, depending on the specific employment decision at issue, may include, but are not limited to, some of the following factors: merit, experience, education, demonstrated performance, competency, assessment of performance, business needs, client needs, work levels, job titles, compensation ranges, company policies, practices, and guidelines or other lawful non-discriminatory factors applicable to the decision.
• not discriminate against employees or applicants because of their race, colour, gender, age, national origin, ancestry, religion, handicap, disability, sexual orientation or any other status or characteristic protected under the law
• treat all employees with respect and dignity and to promote an environment free from harassment and any form of physical pressures.
• Ensure child labour is not used in any operation

We have successfully implemented the SMETA PILLAR 4 system into our company.

There is a grievance and suggestions form for all employees to express their opinions and desires.

SMETA PILLAR 4 (SEDEX Member Ethical Trade Audit)

SMETA’s role is to align social audit standards and monitoring practices, to ease the auditing burden on suppliers by sharing reports and driving improvements in supply chain labour standards.

SMETA 4-Pillar audits add more extensive environmental management requirements as well as business practices.

Reporting can be done through the SEDEX database. How do you benefit?

• Working conditions are analyzed.
• An auditor physically attends our factory, enabling the auditor to assess the conditions on the ground.
• The Social audit enables our business to assess our suppliers, monitor health and safety of our workers, and signal zero tolerance of human rights abuses such as child and forced labour.
• Environmental sustainability of our factory is investigated and documented.
• Once the audit is complete, buyer and supplier businesses can work together to address any issues, based on a Corrective Action Plan (CAPR)

The SMETA PILLAR 4 system has this covered.

We all have periodic meetings with our employees to monitor all situations of grievance if any. If we do we find ways to make things better through the board. We review all the information periodically at 3 month intervals.

SMETA PILLAR 4 (SEDEX Member Ethical Trade Audit)

SMETA’s role is to align social audit standards and monitoring practices, to ease the auditing burden on suppliers by sharing reports and driving improvements in supply chain labour standards.

SMETA 4-Pillar audits add more extensive environmental management requirements as well as business practices.

Every year we have a re audit for Pillar 4 with a corrective measures plan.

Reporting can be done through the SEDEX database. How do you benefit?

• Working conditions are analyzed.
• An auditor physically attends our factory, enabling the auditor to assess the conditions on the ground.
• The Social audit enables our business to assess our suppliers, monitor health and safety of our workers, and signal zero tolerance of human rights abuses such as child and forced labour.
• Environmental sustainability of our factory is investigated and documented.
• Once the audit is complete, buyer and supplier businesses can work together to address any issues, based on a Corrective Action Plan (CAPR)

We exercise a ZERO TOLERANCE POLICY and we are in total agreement of:

Principle 3 - Businesses should uphold freedom of association & effective recognition of the right to collective bargaining
Principle 4 - The elimination of all forms of forced and compulsory labour
Principle 5 - The effective abolition of child labour
Principle 6 - Eliminate discrimination in respect of employment and occupation
Child Labour
Forced Labour
Migrant Workers

Again, with the Smeta Pillar 4 system and protocols we work against any form of forced labour, child labour, migrant labour, We exercise a zero tolerance against discrimination and we are all equal in the company.

Kingly is committed to encouraging equality, diversity and inclusion between our workforce, and eliminating
unlawful discrimination.

A suggestion box is made readily available.

We educate and hold monthly meetings to discuss:
To ensure the health and safety of all employees is guaranteed.
Describe how we prevent discrimination of all kinds and ensure comparable pay for comparable work
We consult with employees and our stakeholders
We allocate responsibilities to select people in our company for the protection of labour rights within our organization
We implement human resource policies and procedures supporting our Labour principles
We Participate in international framework agreements and other agreements. As we are a small company we do not have a labour union. So we have one employee who is tasked with the responsibility for reporting to us.

The Smeta Pillar 4 ensures we put all of this into good use.

The aim is for our workforce to be truly representative of all sections of society and our customers, and for each
employee to feel respected and able to give their best.

We are 25 people in the company of different sexes, ages, ethnicity. We are all equal.

We exercise a zero tolerance for violations of the Global Compact labour principles. We give out one warning. On the second warning they are repramded and warned not to commit the offence again. On the third is reaches the level of dismissal from the company.

We review everything every month to verify if we have any situations or negatives in the company. These meetings are with senior staff and employees.

WE ENFORCE THE SMETA PILLAR 4 (SEDEX Member Ethical Trade Audit)

SMETA’s role is to align social audit standards and monitoring practices, to ease the auditing burden on suppliers by sharing reports and driving improvements in supply chain labour standards.

SMETA 4-Pillar audits add more extensive environmental management requirements as well as business practices.
Once the audit is complete, buyer and supplier businesses can work together to address any issues, based on a Corrective Action Plan (CAPR)

At Kingly we are conscious of our social responsibilities with regards to helping the environment through our working practices. Our objective is not only to sustain our environment for our descendants but also to rehabilitate the damage previously done.

We believe that our corporate responsibility goes beyond our proprietary borders and therefore every effort is made to conserve resources throughout our operations.
This environmental policy has been in force since 2017 and in that time, we have made some significant positive changes to benefit the environment.
We have successfully implemented our environmental policy by producing eco sustainable products and packaging which now account for 85 % of our production. At
Kingly we do not try, we do. We have the proof behind us to demonstrate these achievements to any interested person or company. We aim to increase this percentage year on year to fulfil our obligations.

Kingly not only meet existing environmental laws and regulations, but we endeavor to go beyond the status quo and identify techniques and approaches that further protect the environment as well as positioning us ahead of our competition.

The growth of our company depends on our abilities to minimize or eliminate our negative impacts on our surroundings. Our ultimate success depends on the environment of the European Union and USA.

Without a beautiful planet, our customers will cease to come. Our company’s future and the future of our environment are interconnected. The following are our specific ideals:
Awareness and Commitment

Our policy towards the environment will be readily available and promoted to our customers. We will endeavor to ensure suppliers and customers are familiar with and implement our environmental commitment and objectives.

Practical Implementation: -Kingly environmental policy will be available to view on our website and via email when requested.

Kingly will reduce the impact on the environment where ever possible with respect to transport.

Practical Implementation: -Seek out and employ local products and services to reduce transport costs.
-We avoid unnecessary travel, and will use energy efficient vehicles and driving styles. Over 90% of all our raw materials are sourced locally.
-We will encourage the use of public transport, cycling and walking
-We will eliminate unnecessary and inefficient use of Kingly owned motor vehicles, and wherever possible, that of other vehicles (including supplier / logistics vehicles) associated with Kingly.

Energy & Water Consumption

Kingly accepts a share of Europe’s commitment to a reduction in carbon dioxide emissions both by gaining greater efficiency in total energy consumption and by continuing to examine the possibility of acquiring electricity from 'green' sources when finances permit, either through the purchase of 'green' electricity, or through an increased use of solar water heating, combined heat and power plants (CHP), or photo-voltaic.

Practical Implementation:

-Kingly makes every effort to use water efficiently and avoid pollutants entering the drainage system.
-Kingly use energy efficient products wherever practical, and monitor usage to achieve minimum energy consumption. Waste Generation on and Management Kingly will minimize the production of waste and pollution; including unnecessary packaging. Kingly will implement measures to reduce the volume of waste generated and to increase the proportion of that waste which is recycled. Practical Implementation:
-Kingly will look to compost organic waste.
-Kingly has implemented four separated recycle bins for glass, paper, plastic, and cans.

Materials and Resources

Kingly minimize environmental impact with regard to sourcing materials and resources. Practical Implementation: -Kingly avoid using materials which have an undesirable effect on the environment, and wherever possible use locally made recycled goods. -Kingly use contractors who also share a commitment to the environment, and take into account lifetime costs of materials when repairing, altering or rebuilding premises.
-Kingly maximize use of electronic communication and information storage as an alternative to paper, and take into account the environmental quality and impact of food, cosmetics, textile and other products and where possible to purchase them locally.

Natural Environment

Kingly help to protect and enhance natural habitats and wildlife, take appropriate opportunities to enhance them and be sensitive to landscape issues. We look to minimize impact on local wildlife, and to look for opportunities to work with the local community in caring for the local environment.
Kingly endeavor to be aware of local planning developments and take appropriate action where these are potentially damaging to the environment. Building awareness of environmental concerns Kingly is actively creating awareness of environmental concerns by using social media, trade fairs and publications. In addition, we sponsor events related to eco sustainability and environmental concerns.

Kingly upcycled revolution

We have been extremely active in introducing a closed circular loop in the production of certain textile products like knitted socks, sweaters, beanies and scarves. These upcycled products score the highest on the HIGG INDEX, in fact higher than Organic cultivated apparel. The higher the score, the more eco sustainable they are.

Thank you for helping us to help the environment

Sustainability intelligence and trusted technology in one place

The Kingly Sustainability Platform, underpinned by BCOME’s Impact Measurement tools, empowers us to build responsible supply chains that guarantee Cradle to Grave, 3600, sustainability. It enables us to maintain transparency and share information directly with the customer. Never before has it been so easy to be sustainable and transparent. Our processes and products are transformed into data.

The data demonstrates value. Kingly sustainability is real, transparent and here to stay.

At each step we’re strengthening our message: eco-friendly products are not just about the materials used, although that is naturally essential. It’s more than that. Our drive is to make sure everything and everyone in the process is treated with respect . So our value is in more than great products – it is in everything we touch, looking after today and looking after tomorrow

Methodology

Our traceability methodology includes procedures that make it possible to know and validate the history, location, conditions and trajectory of a product along the supply and value chains. Value chain data is recorded and classified by degree of coverage, from the point of sale at km Zero, through the four forms, for the validation and classification of data for the subsequent production of concrete results: Impact Measurement and the Sustainability Index and
Upgrading Environmental Assessment, Resources input, materials, energy consumption, emissions, impact on air, water and soil: what is assessed? Where does the data come from?

From ‘cradle to gate’ (from origin to factory gate), BCOME's Impact Measurement evaluates the environmental impact of a product from the production or extraction of materials to manufacture, including the transport and packaging used. It measures the environmental impacts generated at each stage, aggregating them to obtain a final result based on the ISO 14044 standard.

The objective is to obtain a better understanding of the environmental impact in relation to emissions, eutrophication (excessive chemical enrichment of water by minerals and nutrients), water consumption, and waste management at each of the stages considered.
Through the BCOME database, we are able to provide our customers with accurate data quickly and safely. The BCOME Database* is a private sector database that brings together more than 5,000 aggregate data from the textile and footwear sector. BCOME validates, classifies and verifies each of the sectoral data in its database in units of mass (kg).

Stepping up Sustainability for genuine transformation

The methodologies of the sustainability index make it possible to evaluate the degree of sustainability of a product from four areas of impact: planet, people, transparency and circularity. It is built from a 360º vision of sustainability, understanding that behind each product there is a universe of development and processes with environmental, social, economic and ethical implications, all of which must be given equal importance.
We’re revolutionizing the way we connect with the consumer in a simple and understandable way

An intelligent QR code takes the consumer straight to the key data for each product. This tool allows for the interpretation and graphical representation of the results, connecting the physical product with a digital experience supported by smart labelling. Through this index system we can display valuable information for our critical KPIs: PLANET, PEOPLE, TRANSPARENCY and CIRCULARITY.

Knowing the story behind the products
Value Chain Traceability

We monitor, define and score the components of the value chain from km Zero to point of sale, and all points between, measuring their condition through systematic data collection.

Sustainability Index
We rate the environmental, social and ethical performance of a product against its best sustainable potential along its value chain.
Life Cycle Analysis (LCA)
We assess the environmental impact of a product, process or system throughout the stages of its life cycle.

System Assumptions and Boundaries

The calculation system multiplies each associated impact by the weight of the product at each life cycle stage according to the set targets, assumptions and thresholds.
Due to the nature and complexity of the apparel supply chain, the following detailed assumptions, thresholds and targets, detailed by life cycle stage, are included:
• Raw materials: the extraction of raw materials, or the growing of the raw material product, along with energy inputs from the environment.
• Materials / Wet Processes: these are activities necessary to convert raw materials and energy into the desired material.
• Manufacture: activities necessary to convert materials and energy into the desired product.
• Retail: activities necessary for buying and selling the product to the end customer.
• Use: activities arising from the use of the finished product throughout its useful life.

End of use: final destination and emissions when the product and packaging reach end of life. You can request the complete Sustainability and QR codes by emailing us at service@wearekingly.com
How do we prove this is practice?

Kingly’s commitment to environmental and social responsibility is deep in our corporate DNA. It’s also evidenced through rigorous third party checks and our adherence to the highest internationally recognized standards and certifications: SMETA PILLAR 4, ISO9001, ISO14001, ISO45001, GOTS, OEKO-TEX, GRS and the use of the BCOME Cradle-to-Grave Platform.

All yarns and materials used in the production of our apparel use Oeko Tex certified materials. In addition to this, we are able to supply Transaction Certificates for our range of yarns and in particular to the GOTS accreditation standard.

We are market leaders in the use of recycled and upcycled materials throughout our production processes, including a commitment to closed loop manufacturing. Step by step, choice by choice, we are changing the direction of the fashion and garments industry. We sell more than the goods we make – we sell a new vision and a new reality of a sustainable lifestyle.

Who said “Cradle to Grave"?

Churchill, the British wartime prime minister, coined the phrase 'from the Cradle to the Grave' in a radio broadcast in March 1943, to describe the need for social insurance to give security to every citizen in the state – what’s now known as the Welfare State.
For the apparel industry, Cradle to Grave means a product’s entire life cycle, from creation to disposal. It is the full life cycle assessment from initial sourcing of materials ('cradle') to the use phase, and finally the disposal phase ('grave'). Cradle-to-gate is an assessment of a partial product life cycle from first sourcing (cradle) to the factory gate, i.e., before it is transported to the consumer.

A Life Cycle Assessment, or LCA, identifies opportunities for improvement by quantifying the impacts that a product has on the environment throughout its full life cycle – from production and manufacturing to the disposal phase. A full LCA is also known as a Cradle to Grave sustainability assessment.
The aim is to create demonstrably sustainable and ethical products, establish two-way communications, and practice appropriate promotions to maximize sales to customers at each phase of the product’s life.

Why the Cradle to Grave principle?
What is the first thing that you think about when you hear the term cradle to grave? The cradle is where you start life, and, of course, the grave is where you end it. In business, the term cradle to grave is used in reference to a firm's perspective on the environmental impact of their product and activities from the beginning of its life cycle to its end or disposal.

Analysing each stage in the cycle means we can maximise environmentally sound methods of production, and ensure safe working practices, fair pay and ethical business practices. Our aim is whole system sustainability and this includes not just materials but working practices too.
What are the detailed implications of the Cradle to Grave principle?

The term is best understood when thought of o as “From creation to disposal”. The best route to determine your cradle to grave patterns is to identify, accurately, a life cycle of the products seen through organizational processes. Only once you have understood and defined your processes will you be able to see precisely the waste streams or negative elements you have within your organization, and in each stage of the process from raw materials to disposal of the used product.
Each product will have a different cradle to grave story and this is where the organization can implement:

• proper identification of each risk
• necessary handling procedures and
• correct storage requirements.

Key goals are to increase sustainability of production and distribution and, importantly, is to assist an organization determine whether the waste stream can be recycled, perhaps even re-used. Landfill disposal should only ever be a last resort.

Why this works at Kingly

We have made deliberate choices to maximise ecologically responsible and ethical practices. And Kingly are well equipped to follow a disciplined approach to cradle to grave, through adopting and following the ISO 14001:2015 standard. This ensures all waste streams are treated with the necessary respect and that we are using the cradle to grave process to optimize ecological and social benefits.

The life cycles of ISO 14001:2015 are broken up into life cycle perspective, life cycle stages, and life cycle assessments.
When applying this analysis to our products and services, we are always in pursuit of whole system sustainability. Thus we always consider the following:
• the stage in the life cycle of the product or service.
• the degree of control it has over the life cycle stages, e.g., a product designer may be responsible for raw material selection, whereas a manufacturer may only be responsible for reducing raw material use and minimizing process waste; the user may only be responsible for use and disposal of the product.
• the degree of influence it has over the life cycle, e.g., the designer may only influence the manufacturers production methods, whereas the manufacturer may also influence the design and the way the product is used or its method of disposal.
• the life of the product.
• the organization’s influence on the supply chain.
• the length of the supply chain
• the technological complexity of the product.

Illustration of the general phases of a life-cycle assessment, as described by ISO 14040.
We first consider those stages in the life cycle over which we have the greatest control or influence; these are where we have the greatest opportunity to reduce resource use and minimize pollution or waste, while also maximising ethical business practices. From there we work hard to extend our scrutiny and standards to include the entire supply and value chain.

Let’s take an example to make it easy to understand: The Crew Organic GOTS certified Cotton Socks.
The entire supply chain is analysed. The cultivation of the cotton is GOTS certified. The manufacturer of the organic cotton yarn is GOTS certified and lastly Kingly is GOTS certified. This means that the entire supply chain and important validated data is inputted into the Cradle to Grave platform.

For a textile product to be able to call itself organic cotton, it must not have used any chemical pesticides, genetically modified seeds, or artificial fertilizers. Its production is supposed to promote and enhance biodiversity and biological cycles. This essential Information is also validated and put into the platform.

In addition to that, Transaction Certificates are generated proving that the socks are legitimate and GOTS certified. This results in truthful and validated information that is essential nowadays. Why? Because there is a resurgence of fraudulent producers claiming that they produce GOTS organic Cotton socks.

Kingly – a brand you can trust for quality and value, a brand you can trust with the future.

We have monthly meetings to discuss environmental policies.

In fact we are audited and have some important certifications and audits running in our company.

ISO 14001: 2015 – ENVIRONMENTAL MANAGEMENT SYSTEM

Environmental protection and sustainable development have become key factors for Kingly such as our customers, suppliers and the public. Like many, our organization may be increasingly challenged to demonstrate its commitment to the environment. Implementing an environmental management system can help us meet this challenge in several important ways. ISO 14001 helps to identify potential environmental issues and eliminate or reduce them.

An environmental management system (EMS) is a long-term investment for the viability of our organization and it can help us to become more effective in achieving environmental goals. Furthermore, by helping to keep existing customers and attract new ones, we have found that the development of an EMS can be a vehicle for positive change.

How do you benefit?

• Cost savings in waste, recycling and consumption • Advantage over competitors when tendering for business • Management of environmental risks • Compliance with individual countries environmental regulations • Demonstrates our commitment to improving the environment • Shows we are a responsible future focused organisation • We reduce insurance cover costs • We increase employee engagement in the knowledge that they are working in an environmentally friendly organisation. • Traceability and contamination risks can be managed better by certifying our management system and products

GOTS. GLOBAL ORGANIC TEXTILES STANDARD.

Version 6. Kingly is accredited with GOTS Vesrion 6 for our range of Organic cotton knitted socks with License number CU 1087797. Our socks are rich in Organic cotton. The composition of our socks is 80% Organic Cotton, 17% regenerated Post Consumer Polyamide (Nylon) and 3% Elastane. The Global Organic Textile Standard (GOTS) is an internationally recognized organic textile standard.

Since its introduction in 2006, GOTS has demonstrated its practical feasibility and is supported by the growth in consumption of organic fibers and the demand for a unified processing criteria from the industry and retail sectors.

GOTS ensures the organic status of textiles from the harvesting of the raw materials through environmentally and socially responsible manufacturing all the way to labelling, in order to provide credible assurances to the consumer.

The standard covers the processing, manufacturing, packaging, labelling, trading and distribution of all textiles made from at least 70 percent certified organic natural fibers. The final fiber products may include, but are not limited to, yarns, fabrics, clothes and home textiles. Through third-party verification, we motivate our quality claim independently towards our clients.

Furthermore, traceability and contamination risks can be better managed. How do you benefit? • We supply genuine GOTS certified socks. There are many fraudsters and opportunists out there who claim they offer Organic Cotton. If they cannot supply a GOTS certificate and Transaction Certificate, chances are it’s a fake. • Through the use of Transaction Certificates, we prove our product is legitimate.

• Labels, tags and promotional material can be used with our GOTS License number to validate our products

THE GLOBAL RECYCLE STANDARD (GRS)

The Global Recycle Standard (GRS) is an international, voluntary, full product standard that sets requirements for third-party certification of recycled content, chain of custody, social and environmental practices and chemical restrictions.

The GRS is intended to meet the needs of companies looking to verify the recycled content of their products (both finished and intermediate) and to verify responsible social, environmental and chemical practices in their production. The objectives of the GRS are to define requirements to ensure accurate content claims and good working conditions, and that harmful environmental and chemical impacts are minimized. This includes companies in ginning, spinning, weaving and knitting, dyeing and printing and stitching in more than 50 countries.

How do you benefit? • GRS ensures the traceability of the recycled materials we use and verifies their composition.

• Through the issuance of a TC / Transaction Certificate, we prove the legitimacy of our products. • It sets requirements for production in order to reduce harmful effects on humans and the environment

OEKO-TEX STANDARD 100 by OEKO-TEX® is one of the world’s best-known labels for textiles tested for harmful substances. It stands for customer confidence and high product safety. How do you benefit?

• If a textile article carries the STANDARD 100 label, you can be certain that every component of this article, i.e. every thread, button and other accessories, has been tested for harmful substances and that the article therefore is harmless for human health. • The tests are conducted by independent OEKO-TEX® partner institutes on the basis of extensive OEKO-TEX® Criteria.

In the test they take into account numerous regulated and non-regulated substances, which may be harmful to human health. • All of our suppliers have the Product class 1: This product class includes products for babies and has the strictest requirements and limit values

Widespread corruption deters investment, weakens economic growth and undermines the rule of law. We work to prevent corruption before it occurs and provides guidance and advice on what public officials can do to prevent corruption and how to manage specific corruption risk functions.

Purpose

The purpose of this policy is to establish controls to ensure compliance with all applicable anti-bribery and corruption regulations, and to ensure that the Company’s business is conducted in a socially responsible manner.

2. Policy statement Bribery is the offering, promising, giving, accepting or soliciting of an advantage as an inducement for action which is illegal or a breach of trust. A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage. 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.

We are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery. We will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate. However, we remain bound by the laws of the EU in respect of our conduct both at home and abroad. Bribery and corruption are punishable for individuals by up to ten years' imprisonment and a fine.

If we are found to have taken part in corruption, we could face an unlimited fine, be excluded from tendering for public contracts and face damage to our reputation. We therefore take our legal responsibilities very seriously.

3. Scope 3.1
Who is covered by the policy?

In this policy, third party means any individual or organization you come into contact with during the course of your work for us, and includes actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisors, representatives and officials, politicians and political parties. This policy applies to all individuals working at all levels and grades, including senior managers, officers, directors, employees (whether permanent, fixed-term or temporary), consultants, contractors, trainees, seconded staff, homeworkers, casual workers and agency staff, volunteers, interns, agents, sponsors, or any other person associated with us, or any of our subsidiaries or their employees, wherever located (collectively referred to as employees in this policy).

This policy covers: • Bribes; • Gifts and hospitality; • Facilitation payments; • Political contributions; • Charitable contributions.
Bribes Employees must not engage in any form of bribery, either directly or through any third party (such as an agent or distributor). Specifically, employees must not bribe a foreign public official anywhere in the world. 3.3 Gifts and hospitality Employees must not offer or give any gift or hospitality: GRA.POL014 Issue 01 • which could be regarded as illegal or improper, or which violates the recipient’s policies; or • to any public employee or government officials or representatives, or politicians or political parties; or • which exceeds $100 in value for each individual gift or $500 in value for each hospitality event (not to exceed a total value of $1000 in any financial year), unless approved in writing by the employee’s manager.

Employees may not accept any gift or hospitality from our business partners if: • it exceeds $100 in value for each individual gift or $500 in value for each hospitality event (not to exceed a total of $1000 in any financial year), unless approved in writing by the employee’s manager; or • it is in cash; or • there is any suggestion that a return favor will be expected or implied. Where a manager’s approval is required above, if the manager is below Director level, then approval must be sought from an appropriate Director. If it is not appropriate to decline the offer of a gift, the gift may be accepted, provided it is then declared to the employee’s manager and donated to charity. We appreciate that the practice of giving business gifts varies between countries and regions and what may be normal and acceptable in one region may not be in another. The test to be applied is whether in all the circumstances the gift or hospitality is reasonable and justifiable. The intention behind the gift should always be considered.

1. Update anti-bribery & anti-corruption policies

Most businesses have adopted anti-bribery policies - but it’s how they are implemented that will make a difference.
We make sure staff understand our company's rules and expectations around bribery and corruption.

They need to know what is and isn't acceptable concerning gifts, hospitality, donations, sponsorship and political donations. We provide regular bribery training to maintain awareness.

Alongside training, we establish processes that help them remember the dos and don’ts, such as checklists and travel guidelines.
Staff need to understand that any gift or hospitality they receive must have a legitimate business purpose, be proportionate, and be declared in the company’s Gift and Hospitality Register. Be sure to clearly outline what is meant by ‘legitimate’ and ‘proportionate’ - don’t leave it open to interpretation.

2. We get the tone right from the top

Staff awareness of anti-bribery policies is only half the story. Creating an anti-bribery culture needs a clear and consistent set of messages coming from the top.
Everyone from the board of directors, the business owner and the compliance function need to make it clear that they won't tolerate bribery and corruption and that anyone found guilty will face the highest sanctions.
However, the most vital thing is for people at the top to be seen to practice what they preach and believe in the importance of anti-bribery policies. Otherwise, staff won’t buy into the culture, and any dialogue around anti-bribery training won’t be taken seriously.

3. We Embed ABAC principles in corporate culture

Refer to Anti-Bribery and Corruption (ABAC) in company handbooks, reports, and training. Set ground rules upfront by including ABAC clauses in all supplier contracts, along with appropriate termination clauses for suspected breaches.
Finally, communicate to staff how important they are in preventing bribery and empower them to play a role in maintaining compliance - for example, by outlining whistleblowing procedures and red flags to look out for.

4. Ensure gifts & hospitality meet key criteria

Any gift or hospitality a person gives or receives must:
• Have a legitimate business purpose (there's a legitimate business purpose)
• Be proportionate (i.e., reasonable and not unduly lavish)
• Be transparent (declared in the company's Gift and Hospitality Register)

5. We Conduct due diligence on all third parties

Anti-bribery laws also apply to all your third parties, i.e., any agents, intermediaries, consultants and associates, and anyone else representing you or acting on your company’s behalf. You are responsible under the law for thoroughly checking and verifying these parties.
This means implementing adequate systems and controls to ensure third parties are whom they claim to be, have the appropriate credentials and are approved at the senior management level.

6. We watch out for bribery & corruption red flags

Non-compliance can manifest itself in both unintentional or deliberate acts. Of course, deliberate non-compliance is more alarming. But it can be easier to spot - as long as you’re watching.

Red flags for deliberate non-compliance include:
• Performing no service other than 'facilitating'
• Abnormally high fees or commission
• An insistence on urgency or confidentiality
• Having no track record
• An insistence on meeting without company representatives being present
• Requesting advance or cash payments
• Requesting payment via third parties
• Operating in a country or territory with perceived high corruption

An individual’s job can also heighten the risk of non-compliance. For example, those operating in a country or territory with perceived high corruption are likely to present more of a threat - whether or not the intent is there.

Identifying unintentional non-compliance is more difficult. But the good news is that preventing it is within your control. Training staff to make them aware of their responsibilities, the company’s expectations and the consequences of giving or receiving bribes is key.

7. We Add precautions for foreign public officials

When dealing with foreign public officials, we make it clear that employees must not offer cash or anything of value to a foreign public official or anyone closely related to them, including charities or voluntary organizations run by their spouses.

8. We avoid facilitation payments

We don't make facilitation payments to speed up the performance of a function by a government official unless you are physically threatened.
9. We report bribery & corruption concerns promptly

If staff have witnessed or suspect bribery, they need to know how and to whom to report it. They should be able to speak to their manager or report it via your company's established whistleblowing channels.

It should also be made clear to employees that it's not their job to investigate their concerns. They should leave the investigation to the appropriate channels instead.
Bribery is a very significant problem that can result in huge fines for companies and individuals and even imprisonment. Don't let this be a reality for your business.
10. We make anti-bribery training meaningful

Bribery prevention policies and procedures need to be embedded and understood by everyone in the organization. This is where a good quality anti-bribery training programmed is critical. Training needs to not only help people understand what is and isn’t acceptable - it must embed the appropriate behaviors.
With this in mind, it’s important that training is first personalized in our company. This is why we created bespoke training content that uses our company name, policy names, terminology our company uses and so on.

But most importantly, it’s crucial to remember that our staff don’t need to know the intricate details of the Bribery Act, clauses and all. Instead, they need to understand the human impact of bribery and their specific responsibilities to help prevent bribery in everyday situations they may come across. This gives training real meaning, and staff will be much more likely to remember their duties and act in the right way.

We stay up to date with Anti-bribery Compliance

We like to stay up to date with bribery best practices, industry insights and key trends across regulatory compliance, digital learning, EdTech, and RegTech news, subscribe to Skillcast Compliance Bulletin.

We navigate the compliance landscape and have collated searchable glossaries of key terms and definitions across complex topics, including GDPR, Equality, Financial Crime and SMCR. We also regularly report key learnings from recent FCA fines.
We follow our ongoing YouGov research into compliance issues, attitudes and risk perceptions in the EU workplace through our Compliance Insights blogs.

HOW TO MONITOR ANTI CORRUPTION

Companies are constantly evolving their business profiles, geographic footprints, channels to market, and clients served, and compliance programs must adapt as well.
As a result of these organizational and business changes in fast-paced companies, many practitioners are hard-pressed to periodically monitor and test the effectiveness of their anti-corruption compliance programs.

The U.S. Department of Justice (DOJ) recently restructured its 2017 guidance document on Evaluation of Corporate Compliance Programs to emphasize the importance of monitoring to determine whether compliance programs “work in practice.”

According to the 2019 Compliance Guidance, the DOJ will consider whether a company has taken “reasonable steps” to “ensure that the organization’s compliance and ethics program is followed, including monitoring and auditing to detect criminal conduct,” and to “evaluate periodically the effectiveness of the organization’s” program. To evaluate effectiveness, the 2019 Compliance Guidance asks two new questions: 1) What testing of controls, collection and analysis of compliance data, and interviews of employees and third parties does the company undertake?; and 2) How are the results reported and action items tracked?

There is little practical guidance on the steps that practitioners can take to monitor their compliance programs and test whether they are effective. In this article, we will describe the steps companies should undertake to design and operationalize anti-corruption compliance monitoring systems. We will begin by outlining an approach for the design of a compliance monitoring system (the why, who, what, how, and when), followed by practical recommendations on how to build and operationalize an effective system. While there are proactive ways to monitor compliance-sensitive areas—such as review and pre-approval of expenditures and payments—this article focuses on retrospective monitoring aimed at detecting compliance violations and identifying trends, outliers, and red flags.
Designing an anti-corruption compliance monitoring system

1. Why monitor?

Companies should first determine their overall strategies and goals for monitoring. Some companies may place an emphasis on data analytics, including evaluating trends and outliers, over more granular testing of compliance-sensitive transactions. The monitoring system should also be tailored to the company’s objectives for its compliance program. For example, a company may prioritize the monitoring of its third-party relationships over monitoring of business courtesies, particularly if the company goes to market primarily using channel partners and agents.

There are different philosophies of what it means to have a “best in class” compliance program, and the answer will vary from company to company and industry to industry:
• A program that aims at preventing all violations (programs that are heavy on automated controls that inhibit the ability of employees from exploiting loopholes). Typically, such programs are adopted by companies in highly regulated industries that are subject to rules and regulations that can change frequently and would have a potentially existential impact on the company’s operations.

• A program that is layered, rigid, and well-documented (programs that prioritize defensibility of the company’s compliance program against external investigations or actions). Such programs are often adopted by large companies with decentralized operations that are subject to laws and regulations that carry high penalties.
• A program that aims at detecting all violations (programs that put more emphasis on third-line detection of potential violations, sometimes through sophisticated data analytics). These programs are often implemented by companies that are centralized, are subject to regulations with high potential impact, and where the business moves quickly and often requires flexibility.
• A program that is culturally embedded in the company (employees know what the rules are, and the company has communicated its expectations). This type of program tends to be adopted by decentralized companies that are subject to lower-impact regulations.
• A program that is designed to respond quickly to daily challenges (programs that prioritize flexibility of the business). These programs can be adopted by centralized companies that are subject to lower-impact regulations.
For the purposes of this article, we will define an effective compliance program as one that fits the needs—both business and cultural—of the company it serves and is embedded in the company’s sustainability strategy. Therefore, the examples we give for the types of data to monitor will be based on whether the compliance program identifies the appropriate risks, identifies too many risks, applies its controls too broadly, or does not apply them broadly enough. In other words, the key inquiry is whether the compliance program is “right-sized” given the profile of the company at a certain point in time.
2. Who should monitor? Organizationally, companies should determine the level at which monitoring should occur (e.g., by country, region, or business line) and the cadence in which it should occur (e.g., monthly or quarterly), prioritize the countries, regions, legal or financial reporting entities, and/or business lines that should be monitored, and determine who should receive monitoring reports, and who will be responsible for analysis and follow-up.
3. What and how to monitor. The next step is to determine the areas to monitor based on the enterprise risk areas. What are the areas that would be most vulnerable to circumvention or that pose the greatest risks to the company? Within those areas, companies should determine what the appropriate baseline metrics should be. In other words, what is the basis for comparison? How are anomalies identified? Baseline metrics may include projected, estimated, or planned spend, against which deviations can be measured. This will differ from company to company, but some suggestions include:
• Compliance-sensitive payments: Compliance-sensitive payments refer to Accounts Payable (A/P) transactions that create an opportunity for potentially improper payments. Such transactions may include payments made to government entities or payments to commercial organizations that present a corruption risk. Changes or trends in compliance sensitive payments, when compared against other risk indices, may signal increased risk in certain areas. For example, an increase in payments approved after the fact in a certain location may indicate that the local team may need to receive additional compliance training. This type of data may also be valuable (and even surprising) to the business and serve to augment the role of compliance as a trusted business advisor. To monitor, companies could identify and designate high-risk accounts within their financial or accounting systems in a way that allows companies to generate reports on a periodic basis. These reports could be compared against the projected budgets and trends over time for the same designated high-risk accounts.
• Other compliance-sensitive spend: Compliance-sensitive spend refers to non-A/P company spend in areas such as gifts, entertainment, or travel involving government officials or commercial clients. This type of spend is incurred as part of companies’ travel and expense process and is typically reimbursed or incurred on corporate credit cards. Compliance-sensitive spend should be monitored for upticks and changes over time. For example, increased compliance-sensitive spend in certain locations or offices ahead of major deals or bids may indicate inappropriate use of perks used to influence decisions by government officials or by key commercial clients and warrant further investigation. To monitor, companies could earmark compliance-sensitive spend in their financial systems following the pre-approval or approval processes in a way that allows companies to generate reports on a periodic basis.
• High-risk third parties: Third parties are involved in over 80 percent of all Foreign Corrupt Practices Act enforcement actions and present a heightened corruption risk for multinational companies with high volumes of third parties. Evaluating spend on high risk third parties, e.g., those that are likely to interact with government officials or certain commercial clients, by geographical or business lines, can help identify lack of discipline in engaging unnecessary third parties, third parties that are unqualified, and third parties that are not performing services to the level necessary or are compensated in a manner that is not commensurate with the standard compensation in the respective region or industry. This type of data is often valuable in identifying areas where spend could be reduced. To monitor high-risk third parties, companies can look to the number of high-risk third parties engaged, the number and location of high-risk third parties involved in investigations or audits, and actual spend compared against the projected budgets for high-risk third parties.
• New market entry: Expansion into new territories or channels to market can create risks through new regulatory touchpoints, operational restrictions, and new partnerships. Inexperience in new markets could make companies vulnerable to inappropriate requests by local government officials or local commercial partners. Companies can use pre-entry projected timelines for key milestones and projected budgets as a baseline for comparing areas where companies’ expectations of entering a market are inconsistent with the reality of entering the market. Delays in achieving milestones or lower-than-expected financial performance can put pressure on the business to take shortcuts or create workarounds to ameliorate the gaps. Monitoring delays in processes, such as obtaining permits, licenses, or registrations, unexpected issues with commercial or government partnerships or ventures, or lower-than-expected financial performance can help identify potential pressure points that may warrant further examination.
• Investigations: Trends in investigations offer key insights into how companies’ policies are communicated and understood and into the effectiveness of the investigations function itself. For example, increased investigations could indicate a need for enhanced policies or additional or more targeted training, tone at the top issues, or challenges related to disciplinary sanctions imposed for substantiated violations. A decrease in investigations hotline reports may indicate fear of retaliation, issues with identifying potential violations, or a lack of trust that investigations will be handled fairly. Companies can monitor the sources of allegations, number of allegations by country, business line, and region, types of allegations, average time before allegations were identified, number of substantiated versus unsubstantiated allegations, and disciplinary actions imposed as a result of substantiated allegations.

• Training: Data related to companies’ training programs can offer insights into the effectiveness of companies’ communications around policies. Training data can also offer insight into whether management is appropriately communicating or demonstrating its commitment to compliance. Comparing training data against investigations data can offer insight into whether there is a need for more effective or targeted training in specific geographies or on specific topics. Companies can monitor the frequency of the trainings, subject matter and format of training sessions, average time to completion, and the effectiveness of quizzes across various training sessions.