Home Corporate Policies ETI Base Code

Version 1.0  |  Effective Date: January 1, 2026

Ethical Trading Initiative (ETI) Base Code

Our Commitment to Ethical Trade

Ensuring high-quality products are made by people treated with dignity and respect across our entire supply chain.

Based on the internationally recognized ETI Base Code, these 9 principles represent Saporina's minimum labor standards — applying to every authorized partner, supplier, and labor provider in our network.

Introduction & Applicability

At Saporina, we believe that high-quality products must be made by people who are treated with dignity and respect. We have adopted the Ethical Trading Initiative (ETI) Base Code as the minimum labor standard across our entire organization.

Applicability

This Code applies to Saporina and strictly extends to our entire supply chain, including all authorized partners, suppliers, and labor providers. Saporina will not work with any entity that fails to uphold these fundamental rights.

The 9 Principles

1. Employment is Freely Chosen

1.1

Absolute Prohibition

There shall be no forced, bonded, or involuntary prison labor.

1.2

Workers are not required to lodge deposits or their identity papers with their employer and are free to leave their employer after reasonable notice.

2. Freedom of Association & Collective Bargaining

2.1

Workers, without distinction, have the right to join or form trade unions of their own choosing and to bargain collectively.

2.2

The employer adopts an open attitude towards the activities of trade unions and their organizational activities.

2.3

Workers' representatives are not discriminated against and have access to carry out their representative functions in the workplace.

2.4

Where the right to freedom of association and collective bargaining is restricted under law, the employer facilitates, and does not hinder, the development of parallel means for independent and free association and bargaining.

3. Working Conditions are Safe & Hygienic

3.1

A safe and hygienic working environment shall be provided. Adequate steps shall be taken to prevent accidents and injury to health arising out of, associated with, or occurring in the course of work.

3.2

Workers shall receive regular and recorded health and safety training, and such training shall be repeated for new or reassigned workers.

3.3

Access to clean toilet facilities and to potable water, and, if appropriate, sanitary facilities for food storage shall be provided.

3.4

Accommodation, where provided, shall be clean, safe, and meet the basic needs of the workers.

3.5

Compliance Duty

Responsibility for health and safety must be assigned to a senior management representative at the manufacturing site.

4. Child Labor Shall Not Be Used

4.1

Absolute Prohibition

There shall be no new recruitment of child labor.

4.2

Companies shall participate in and contribute to policies and programs which provide for the transition of any child found to be performing child labor to enable them to attend and remain in quality education until no longer a child.

4.3

Children and young persons under 18 shall not be employed at night or in hazardous conditions.

5. Living Wages Are Paid

5.1

Wages and benefits paid for a standard working week meet, at a minimum, national legal standards or industry benchmark standards, whichever is higher.

Living Wage Principle

In any event, wages should always be enough to meet basic needs and to provide some discretionary income.

5.2

All workers shall be provided with written and understandable information about their employment conditions in respect to wages before they enter employment and about the particulars of their wages for the pay period concerned each time that they are paid.

5.3

Deductions from wages as a disciplinary measure shall not be permitted nor shall any deduction from wages not provided for by national law be permitted without the expressed permission of the worker concerned. All disciplinary measures should be recorded.

6. Working Hours Are Not Excessive

6.1

Working hours must comply with national laws, collective agreements, and the provisions of 6.2 to 6.6 below, whichever affords the greater protection for workers.

6.2

Working hours, excluding overtime, shall be defined by contract, and shall not exceed 48 hours per week.

6.3

All overtime shall be voluntary. Overtime shall be used responsibly and shall always be compensated at a premium rate. It shall not be used to replace regular employment.

6.4

The total hours worked in any 7-day period shall not exceed 60 hours, except where covered by clause 6.5 below.

6.5

Working hours may exceed 60 hours in any 7-day period only in exceptional circumstances where all of the following are met:

  • this is allowed by national law;
  • this is allowed by a collective agreement freely negotiated with a workers' organization representing a significant portion of the workforce;
  • appropriate safeguards are taken to protect the workers' health and safety; and
  • the employer can demonstrate that exceptional circumstances apply such as unexpected production peaks, accidents or emergencies.
6.6

Workers shall be provided with at least one day off in every 7-day period or, where allowed by national law, 2 days off in every 14-day period.

7. No Discrimination is Practiced

7.1

Our Commitment

There is no discrimination in hiring, compensation, access to training, promotion, termination, or retirement based on race, caste, national origin, religion, age, disability, gender, marital status, union membership, or political affiliation.

8. Regular Employment is Provided

8.1

To every extent possible, work performed must be on the basis of recognized employment relationship established through national law and practice.

8.2

Obligations to employees under labor or social security laws and regulations arising from the regular employment relationship shall not be avoided through the use of labor-only contracting, sub-contracting, or home-working arrangements, or through apprenticeship schemes where there is no real intent to impart skills or provide regular employment, nor shall any such obligations be avoided through the excessive use of fixed-term contracts of employment.

9. No Harsh or Inhumane Treatment is Allowed

9.1

Zero Tolerance

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

Enforcement & Reporting

How Saporina Enforces This Code

Scheduled & Unannounced Audits: Our internal Quality Assurance and Compliance teams conduct regular verification visits across the manufacturing network. We also engage independent third-party auditors.

Non-Compliance Consequences: Confirmed violations result in a corrective action plan with defined timelines. Failure to remediate, or severe violations (forced labor, child labor), lead to immediate termination of the business relationship.

Remediation First: Where possible, Saporina works with partners to remediate issues rather than simply withdrawing — sudden disengagement can harm the workers we are trying to protect.

Reporting Violations

If you witness or become aware of any violation of these principles — whether within Saporina's own operations or anywhere in our supply chain — you must report it. All reports are treated confidentially.

Web Platform (Anonymous)

saporina.com/ethics-channel

Phone Hotline (24/7)

+1 (000) 000-0000
For full details on reporting procedure, guarantees, and protections, see the Whistleblowing Policy. Retaliation against reporters is strictly prohibited.

Approved by:

The Compliance and Audit Committee

SAPORINA®