Code of Conduct — supplier ethics, anti-corruption and ESG in Italy
A binding code that every supplier in our Italy network signs annually — labour, human rights, anti-corruption, environment, governance.
Labour and human rights
No child labour (ILO Convention 138/182). No forced or bonded labour. Freedom of association. Living wage at or above legal minimum in the country of production. Maximum 48-hour work week with voluntary overtime capped at 12 hours. No discrimination on race, gender, religion, age, sexual orientation. Safe and clean workplace. We audit annually and require corrective action plans for any non-conformance.
Anti-corruption and anti-bribery
Zero tolerance for bribery, kickbacks, facilitation payments. Suppliers may not offer gifts above €50/year/person to our staff, and we apply the same standard to gifts received from our customers' procurement teams. All gifts above €30 must be registered. Sanctions screening (EU, OFAC, UK) on all new suppliers and annual re-screening.
Environment and ESG
Suppliers must comply with all applicable environmental laws, hold relevant certifications (ISO 14001 desirable), maintain waste-reduction programs, and disclose emissions data on request for our scope-3 reporting. We prioritise suppliers with renewable-energy contracts and water-recirculation in dyeing/finishing processes.
Italy — enforcement and whistleblowing
IVA 22% via SdI (Sistema di Interscambio). Whistleblowing channel [email protected] — confidential, GDPR-protected, retaliation-free per EU Directive 2019/1937. Annual supplier code attestation and on-site audit at Milano hub. Material breach = immediate contract suspension and remediation plan within 60 days.
FAQ
Can we audit your suppliers?
Yes — joint audit available for framework-agreement customers, annually.
Modern slavery statement?
Yes — annual UK/EU compliant modern slavery statement published on corp-merch.eu.
Anti-corruption training?
Mandatory annual training for sales and procurement staff, certified by Transparency International curriculum.
Sanctions screening?
All new suppliers and counterparties screened against EU/OFAC/UK lists at onboarding and re-screened annually.
What if we find a breach?
Email [email protected] — confidential investigation within 14 days, corrective action within 60.