Ethical Trading Policy

1.Purpose

To define Celtic Chemicals Ltd values on Ethical trading

2. Scope

All employees working for Celtic Chemicals and suppliers of Celtic Chemicals.

3. Policy

3.1. Introduction

Celtic Chemicals Ltd recognise the responsibility that we share with our suppliers to source, buy,
produce and sell products in an ethical manner. We want our customers to be confident that people
are treated fairly, are not exploited and are not exposed to unsafe working conditions. Our Ethical
Trading Policy requires all our suppliers to comply with our ethical code which is based on the
International Labour Organisation (ILO) and national and international laws

3.2 Ethical trading code (ETC)

The requirements of the Celtic chemicals ETC constitute minimum and not maximum standards and
should not be used to prevent the company and its suppliers from exceeding these standards.

3.2.1 Forced, bonded or involuntary labour

Employment is freely chosen and there is no forced or indentured labour, bonded labour, involuntary
labour, involuntary, unpaid prison labour or usage of slaves.
Workers should not be required to lodge “deposit” or their identity papers with their employer and
are free to leave their employer after reasonable notice.
No harsh or inhumane treatment is allowed

3.2.2 Child labour

The term “child” refers to any person under the age of 15, or under the age for completing
compulsory education, or under the minimum age for employment in the country, whichever is
greatest.
There shall be no new recruitment of child labour.
Young persons under 18 shall not be employed at night or in hazardous conditions.
Policies and procedures relating to Child Labour shall conform to the provisions of the relevant
International Labour Organisation (ILO) Standards.

3.2.3 Discrimination & harassment

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

3.2.4 Working conditions

A safe and hygienic working environment shall be provided, bearing in mind the prevailing knowledge
of the industry and of any specific hazards.
Adequate steps shall be taken to prevent accidents and injury to health arising out of, associated
with, or occurring in the course of work, by minimising, so far as is reasonably practicable the causes
of hazards inherent in the working environments.
Workers shall receive regular and recorded health and safety training and such training shall be
repeated for new or reassigned workers.
Workers shall be provided with access to clean toilet facilities and to potable water, and, if
appropriate sanitary facilities for food storage shall be provided.
Accommodation, where provided, shall be clean, safe and meet the basic needs of the workers.
Working hours must comply with the national laws and benchmark industry standards, whichever
affords greater protection. Workers should not be required to work more than 48 hours per week (or
less in accordance with local/national laws); should not work more than 12 hours of voluntary
overtime; and should get one day off in seven.
Overtime should not be demanded on a regular basis and should always be compensated at a
premium rate.
Where the company is partly to a collective bargaining agreement freely negotiated with worker
organizations it may require overtime work in accordance with the agreement to meet short term
demand.

3.2.5 Remuneration

Workers should be paid at least the national/local minimum wage for a basic working week and this
should be sufficient to cover basic needs and allow some discretionary income.
All workers should be provided with written and understandable information about their pay before
they start employment and should be given a pay slip or other understandable information about
their wages for the pay period concerned each time that they are paid.
Deductions from wages as a disciplinary measure shall not be permitted nor shall any deductions
from wages not provided for by national law be permitted without the expressed permission of the
worker concerned. All disciplinary measures should be recorded.

3.2.6 Regular Employment

To every extent possible work performed must be on the basis of recognised employment
relationship established through national law and practice.
Obligations to employees under labour or social security laws and regulations arising from the regular
employment relationship shall not be avoided through the use of labour-only contracting, sub-
contracting, or homeworking 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.

3.2.7 Freedom of association and the right to collective bargaining

Workers without distinction are free to join a trade union of their choice and to bargain collectively
on wages, benefits and working conditions without fear of harassment or intimidation. Workers’
representatives are not discriminated against and have access to carry out their representative
functions in the workplace.

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.
Unacceptable disciplinary practices such as those based on corporal punishment, physical or mental
coercion, verbal abuse or deducting money from wages due to a worker will not be tolerated in any
form.

3.2.8 Bribery

Bribery is the practice of offering something (money, gifts, hospitality or services) in return for or in
expectation of more favourable treatment. Employees must conduct must not seek to gain
competitive advantage by means of unethical or dishonest practices including without limitation:
bribery, corruption, kickbacks, the provision of gifts, favours or services.

3.3. Supplier acceptance of Celtic chemicals ETC

Celtic Chemicals seeks to develop long-term trading relationships with suppliers based on the
principle of fair, open and honest dealings at all times.
All suppliers are required to comply in all respects with our ETC.

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