As a manufacturer and distributor to the skincare and hair care markets in US and Canada, ethical and social accountability plays an important role in Ostelia’s philosophy and business activities. Ostelia is committed to conducting its business in a sustainable, ethical and responsible manner, ensuring that the impact on the communities with which it has dealings is positive and that all who supply goods or services to Ostelia (‘Suppliers’) show integrity and respect for international human rights and the environment. It is our belief that good corporate practices are essential to long term sustainable success and must be reflected in our workplace and the workplaces of our Suppliers. Our reputation is important to us, but it is more than that; integrity and ethical behavior are part of our culture.
Accordingly, this Code of Conduct (‘Code’) and any subsequent versions published on Ostelia’s website, applies to all Ostelia Suppliers worldwide, including agents and distributors. It is the responsibility of all Suppliers to familiarize themselves with this Code and to take appropriate steps to ensure compliance by their organizations.
This Code is designed to outline the values we uphold in our own policies but should not be seen as exhaustive. We expect Suppliers to follow the spirit of this Code in the conduct of their business.
Recognizing that there are differences in laws, cultures and economic conditions that affect business practices around the world, Ostelia requires Suppliers to comply with the full requirements of the Ethical Trading Initiative Base Code (‘ETI Base Code’), and any amendments thereof, concerning best practice with regard to social accountability. The ETI Base Code, copies of which can be downloaded from http://www.ethicaltrade.org/resources/eti-base-code, is founded on the conventions of the International Labor Organization (ILO) and is an internationally recognized code of labor practice and provides provisions in respect of:
- Employment is freely chosen
- There is no forced, bonded or involuntary prison labor
- Workers are not required to lodge “deposits” or their identity papers with their employer and are free to leave their employer after reasonable notice
- Freedom of association and the right to collective bargaining are respected
- Working conditions are safe and hygienic
- Child labor shall not be used
- Living wages are paid
- Working hours are not excessive
- No discrimination is practiced
- Regular employment is provided
- No harsh or inhumane treatment is allowed
In addition to compliance with the provisions of ETI Base Code, Ostelia is committed to ensuring that modern slavery does not take place anywhere in our business or in any of our supply chains. Modern slavery may take various forms, such as slavery, servitude, forced and compulsory labor and human trafficking and is a crime and a violation of human rights, which exploits a person for personal or commercial gain. In accordance with our Modern Slavery Statement, found on our website, we are committed to tackling modern slavery throughout our business and we expect the same high standards from Suppliers in eliminating modern slavery. Ostelia will not support or deal with any business knowingly involved in modern slavery.
Ostelia hires, promotes, develops and compensates employees based on meritocracy and without regard to age, gender, disability, marital status, race, national origin, religion or sexual orientation or any other legally protected characteristics or status. Our Suppliers are also expected to recruit, employ and promote employees on the sole basis of the qualifications and abilities needed for the work to be performed, without regard to any protected characteristics or any other category not relevant to performance.
Health & Safety
The health and safety of employees is Ostelia’s number one priority. In addition, we seek to ensure the safety of all third parties, which attend our sites. Ostelia promotes a positive in-house health and safety culture through regular health and safety committee meetings, internal safety audits and extensive employee training, all of which lead to continuous improvement. Particular emphasis is placed upon the recording and assessment of ‘near misses’ and the resultant implementation of preventative measures.
Suppliers shall provide a safe and hygienic environment for its workers, which at the very least, complies with the ETI Base Code.
Good environmental practice is important in ensuring that we, and our Suppliers, operate responsible and sustainable businesses, which reduce their negative impact on the environment as much as practicable and comply with all applicable environmental laws, regulations and standards. Suppliers shall adopt any appropriate policy, standard, procedure and management system in order to ensure that its operations are managed ecologically and in a sustainable way and shall take necessary measures in order to prevent pollution, to conserve natural resources required for its operations and implement relevant emergency response plans and procedures.
Ostelia is committed to ensuring full traceability of raw materials to their source; supply chain transparency is essential in assessing and monitoring risks and is a strict requirement of our customers. We expect our suppliers to support full traceability by having robust traceability systems in place under which they take ownership and responsibility for their own supply chains back to the original source of materials.
We maintain and require Suppliers to maintain adequate business continuity plans to enable a continuation of services to a reasonable degree in the aftermath of any kind of operational crisis, whether caused by a natural disaster, equipment malfunction, power failure, terrorist act, cyber-attack, or so forth. Upon request by Ostelia, Suppliers will disclose in reasonable detail and discuss the elements of its business continuity plans and its information security systems and controls.
Anti-Bribery and Corruption
In all our dealings we are committed to complying with applicable anti-corruption laws including those relating to actions that could be considered bribery. These laws, including the UK Bribery Act and the US Foreign Corrupt Practices Act, and similar anti-corruption regulations throughout the world shall be complied with. Violations of anti-bribery laws can result in criminal convictions for the individuals and organizations concerned. Ostelia strictly forbids any form of bribery anywhere in the world by any Supplier.
Bribery is the giving, promising, offering, receiving, agreeing to receive, requesting or accepting of anything of value or any kind of advantage, to or from any person in order to influence them improperly in the performance of their duty. A thing of value or advantage might be money; it may also include loans, gifts, travel or favors.
Ostelia does not condone, encourage or support tax evasion, and is committed to implementing procedures to prevent anybody employed or contracted to Ostelia or acting on Ostelia’s behalf facilitating the evasion of tax. Any involvement by persons associated with Ostelia (broadly employees, contractors and parties acting for Ostelia) in such activities is considered damaging to our reputation and potentially the long-term sustainability of our business, therefore Ostelia will not engage in transactions which we know or suspect facilitates tax evasion, even if it may result in us losing business. Tax evasion is against Ostelia’s general business principles; Ostelia expects the businesses and people we engage with to comply with their tax obligations.
Gifts and Hospitality
Ostelia’s policies do not preclude the giving and receiving of gifts and hospitality; they are permitted where they are transparent, proportionate, reasonable and within the laws of the country in which they are given or received. They are expressly prohibited where they could influence or be perceived to be capable of influencing any material transaction. Ostelia employees must declare any gifts received which are above a nominal value and must not accept hospitality exceeding limits stated in our policy, without prior management approval. Suppliers are expected to abide by Ostelia’s policies in respect of the giving of gifts and hospitality to Ostelia employees in that they should be transparent, proportionate, reasonable and within the laws of the country in which they are given or received.
Ostelia has a Whistleblowing Policy which provides a confidential process by which all workers are able to raise concerns that they may have about the conduct of others in the business or the way in which the business is run, without fear of retaliation. Suppliers are expected to have regard for the importance of preventing and eliminating wrongdoing in their business and should have a communicated process for workers to express grievances without fear of reprisal and ensure concerns are appropriately addressed in a timely manner.
We reserve the right to audit Suppliers compliance with this Code and in the event that there is non-compliance, we reserve the right to request remedial action. In the event of continued non-compliance, we reserve the right to terminate contracts with those suppliers who do not comply with the standards of this Code.