Ethical Trading Policy

Thomas Ferguson & Company Limited

Ethical Trading Policy for Outsourced Products

Our Commitment: At Thomas Ferguson & Company Limited, we believe that business is driven by people, for people. To offer our customers the best possible value, we outsource elements of our operations, but we maintain a highly responsible approach to our supply chain. We are committed to protecting human rights, ensuring the well-being of all workers, and upholding the highest ethical standards. Just as we strive to support our own employees, we expect our suppliers to do the same. Substandard ethical practices reflect adversely on our business, our people, and our customers.

1. Scope and Compliance

Thomas Ferguson & Company Limited requires all business partners—including manufacturers, contractors, subcontractors, and suppliers involved in the manufacture and finishing of our products—to share our ethical concerns and comply with these standards.

  • Mandatory Agreement: All major suppliers must formally sign and commit to these conditions prior to conducting business with us.
  • Legal Supremacy: Where local laws and this policy address the same subject, suppliers must apply the standard that affords the greatest protection to the worker.

2. Core Ethical Standards

2.1 Employment is Freely Chosen (Zero Tolerance for Modern Slavery)

  • We operate a zero-tolerance policy towards modern slavery, human trafficking, and forced, bonded, or compulsory labour.
  • Workers must not be required to lodge "deposits" or their identity papers with their employer and must be free to leave their employer after reasonable notice.

2.2 Eradication of Child Labour

  • We strictly prohibit the use of child labour.
  • No person shall be employed under the age of 15 (or 14 where local law allows in accordance with ILO exemptions), under the local legal minimum working age, or under the age for completing compulsory education—whichever is highest.
  • Exceptions may only be made for legitimate, legally compliant apprenticeship or work-experience programmes that do not interfere with the child's schooling or physical/moral development.

2.3 Safe and Hygienic Working Conditions

  • Suppliers must provide a safe, healthy, and hygienic working environment that complies with all local occupational health and safety laws.
  • Adequate steps must be taken to prevent accidents and injury to health arising out of, associated with, or occurring in the course of work.
  • Where provided, accommodation and residential facilities must be clean, safe, and meet the basic needs of the workers in full compliance with local laws.

2.4 Non-Discrimination and Equal Opportunity

  • We recruit and reward based on ability and merit.
  • Suppliers must not practice discrimination in hiring, compensation, access to training, promotion, termination, or retirement based on race, colour, nationality, ethnic origin, gender, gender identity, sexual orientation, religion or belief, age, disability, marital status, or pregnancy/maternity.

2.5 Fair Wages and Benefits

  • Wages and benefits paid for a standard working week must meet, at a minimum, national legal standards or industry benchmark standards, whichever is higher.
  • In any event, wages should always be enough to meet basic needs and provide some discretionary income (the "Living Wage" principle). All workers must be provided with written and understandable information about their employment conditions and wages.

2.6 Reasonable Working Hours

  • Working hours must comply with national laws, collective agreements, and international standards.
  • Standard working hours (excluding overtime) shall be defined by contract and must not exceed 48 hours per week.
  • Total hours worked in any seven-day period shall not exceed 60 hours, except in truly exceptional circumstances. All overtime must be voluntary, used responsibly, and compensated at a premium rate.

2.7 Humane Treatment and Fair Disciplinary Practices

  • Physical abuse or discipline, the threat of physical abuse, sexual or other harassment, verbal abuse, or other forms of intimidation shall be strictly prohibited.

2.8 Freedom of Association and Collective Bargaining

  • Workers, without distinction, have the right to join or form trade unions of their own choosing and to bargain collectively.
  • Suppliers must adopt an open attitude towards the activities of trade unions.
  • Where the right to freedom of association and collective bargaining is restricted under local law, the employer must facilitate, and not hinder, the development of parallel means for independent and free association and bargaining.

2.9 Business Integrity and Trade Compliance

  • Suppliers must not engage in deceptive practices or deliberately misrepresent the country of origin of any products to evade quotas, import restrictions, or duties on goods purchased by Thomas Ferguson & Company Limited.
  • All business must be conducted ethically, with zero tolerance for bribery or corruption.