HEAD CODE OF CONDUCT
Modern Slavery and human trafficking statement 2021
This statement is made pursuant to section 54 of the UK Modern Slavery Act 2015 and has been approved by HEAD UK’s Board of Directors. It sets out the measures that HEAD UK, Ltd and its affiliates (“HEAD”) have taken during the 2021 financial year and constitutes HEAD’s modern slavery and human trafficking statement and general approach to ethical and mindful behaviour.
HEAD is a leading global manufacturer and marketer of premium sports equipment with internationally recognized brands including HEAD, PENN, TYROLIA, MARES, SSI and ZOGGS. We are committed to comply not only with what is required but also with what is expected of a leader in this industry. As a truly international company that operates in a worldwide environment, we appreciate and value many different kinds of people, individual diversity and equal opportunity for each individual. Our business is based on mutual trust, fairness, honesty and teamwork.
HEAD is committed to maintaining appropriate safeguards against the mistreatment of persons within its business and supply chain.
1. OUR OWN BUSINESS
HEAD is proud to announce that about two thirds of its products are directly manufactured by itself in its own facilities, most of them located in Europe. Approximately one third of the production value is outsourced.
Our employees working in those facilities and elsewhere in more than 25 different jurisdictions are our most valuable asset. To ensure that those employees are guided by the same mindset, treat each other fairly, operate ethically and in compliance with applicable laws, rules and regulations in the same manner, HEAD has implemented a Code of Business Conduct (the ‘HEAD Business Code’) already in 2004.
The HEAD Business Code shall assist in improving the impact of our business on society with a clear commitment to social and cultural responsibility. Our policies and the HEAD Business Code are regularly reviewed and our employees are trained to ensure that the HEAD Business Code is implemented across the business. It needs to be adhered to by all employees upon their employment and annual affirmation statements have to be given, reminding our employees to continuously ensure compliance with the HEAD Business Code and to report any incidents they should come across immediately.
In addition to our HEAD Business Code, very strict health and saftey rules, regulations as well as business requirements apply in our own production facilities located in Europe. Outside Europe, our production facilities are supervised and controlled by Europeans based abroad to ensure that similar level of employment standards apply and that the HEAD Business Code is complied with.
Our Committment to Environmental Protection
It has never been more important to think about how we perform in terms of environment. It is not just about what we do, it is also about how we do it and we need to rethink everything we do in order to achieve the maximum sustainability in all our processes and products.
We continuously grow through our innovative use of technology; in terms of sustainability we are researching new materials and production processes and are working to create more sustainable products. Examples are our first tennis bag created using recycled PET bottles or swimwear made from recycled plastic bottles. Packaging is reduced (or avoided where possible) in all areas and plastic is eliminated by replacing it with sustainable materials across all divisions.
We are actively seeking to reduce our carbon footprint through different initiatives. All energy at our Austrian location in Kennelbach is supplied by an on-site hydro plant. At various other locations worldwide we are in the process or planning to install photovoltaic systems.
For our Austrian locations we are currently working on the implementation of ISO 14001:2015, which is the international standard that specifies requirements for an effective environmental management system defined as the part of the management system used to manage environmental aspects, fulfill compliance obligations and address risks and opportunities. We see the main benefits as improving resource efficiency, reducing waste, drive down costs, meeting legal obligations, gaining competitive advantage in supply chain design and providing assurance that environmental impacts are being measured. Certification is expected for 2023 with the goal to include further locations and the supply chain thereafter.
2. OUR SUPPLIERS
We seek business partners/suppliers who follow business practices consistent with our policies and values and share our commitment to the promotion of best practices and continuous improvement in working conditions, environmental protection and equal treatment for all employees.
While these principles establish the spirit of our partnerships, we also bind these partners to specific standards of ethical conduct.
Furthermore, HEAD has taken and is taking steps to monitor that slavery and human trafficking is not taking place in any part of its own business or its supply chains. By increasing supply chain accountability, more workers will be protected and consumers will have greater confidence in the goods and services they buy.
Supplier Employees - HEAD Code of Conduct
The HEAD Code of Conduct defines the major principles of the group’s business conduct, based on its values. HEAD fully respects and supports the principles proclaimed in the Universal Declaration of Human Rights and the fundamental labour principles that protect worker’s rights as defined by the Declaration on Fundamental Principles and Rights at Work of the International Labour Organization (ILO). These fundamental labour principles include:
· The prohibition of child labour
· The prohibition of forced labour in all its forms
· Freedom of association and the right to collective bargaining
· Fair compensation and working hours
· Safe and healthy workplaces
· Protection from discrimination, harassment and inhumane treatment.
The goal of the HEAD Code of Conduct is to build and maintain a working environment in which personal and business relationships are guided by high ethical standards.
Just as HEAD has committed to ethical business practices in its own facilities, HEAD therefore commits to achieve the same or similar standards at its supplier’s facilities. To define these practices and provide a means of monitoring adherence to these practices, HEAD has been guided by the principles laid out by the World Federation of the Sporting Goods Industry (WFSGI) in devising the HEAD Code of Conduct. The ideals of the WFSGI are the ideals of sport and the organisation seeks to promote fairness, honesty, mutual understanding and high ethical standards not only on the sports field, but also in the factories, which make sports products. Adherence to our Code will not only enhance the communities in which our products are manufactured, but will also strengthen the relationships with our mutual customers.
HEAD only allows employees to deal with suppliers who understand the essentials of the HEAD Code of Conduct. HEAD reviews its Suppliers on a regular basis and takes care that Suppliers agree to and sign the HEAD Code of Conduct with its standards as detailed below:
a) General Request to our Suppliers to adhere to the Code
The HEAD Code of Conduct applies to the Suppliers of essentially all products purchased by HEAD. It defines the minimum requirements for Suppliers who do business with HEAD. In all cases, the demonstrated actions should meet or exceed those that are required by the laws and regulations of the applicable country. In addition, HEAD encourages Suppliers to take additional steps not covered in this Code to improve working conditions, employment practices and environmental protection. We expect our Suppliers, at a minimum, to do the following:
· Comply with all applicable laws and regulations of the countries in which they operate. Local industry standards should prevail where these are higher than local legal requirements.
· Abide by fair and humane employment practices.
· Provide safe and healthy working conditions.
· Undertake reasonable measures to protect the environment.
b) Employment Standards
Suppliers shall comply with applicable laws and industry standards for all employment practices, including working hours, wages and employee benefits. Suppliers shall not use any prison, indentured, bonded or forced labour. No employee can be compelled to work through force, the threat of force or intimidation of any form. No person shall be subject to any discrimination in employment,
Our business partners/suppliers shall not employ children below the age of 15 or 14 (where the law of the country of manufacture allows) or younger than the age for completing compulsory education in the country of manufacture where such age is higher than 15. Where local standards are higher, no person under the legal minimum age will be employed.
Suppliers shall recognize and respect the rights of workers to join workers organisations and associations of their choosing and to bargain collectively to the extent permitted by local law.
A safe and hygienic working environment shall be provided. Factories shall comply with all applicable laws and regulations regarding working conditions and occupational health and safety practices which prevent accidents and injury to health shall be promoted.
This includes protection from fire, accidents, and toxic substances. Lighting, heating and ventilation systems should be adequate.
Work areas are to have both suitable and adequate lighting, effective and appropriate ventilation. Adequate and clean toilet and hand-washing facilities are to be provided.
c) Consequences in case of breach
At any time, with advance notice, HEAD reserves the right to inspect and/or authorise a third party to inspect and audit, without any restrictions, its Suppliers. If HEAD determines that any Supplier is in violation of these principles, HEAD, at its option, reserves the right to:
· Require corrective actions within an acceptable time period in order for the business relationship to continue or to resume; and
· In the case of violations of applicable law, or in the event that other violations of the principals in this Code continue after a reasonable opportunity to remedy such violations, to terminate the business relationship with the Supplier, including cancellation of outstanding purchase orders.
d) Documentation - Audits
Suppliers are to maintain on site all documentation that may be needed to verify compliance with the laws and regulations of the applicable country of manufacture and this Code. All such documentation is to be made available to HEAD and/or its designated third party inspector upon request.
Suppliers - Environmental protection
Sustainability has always been an important element of HEAD’s corporate policy and strategy and is a decisive factor in order to be successful in the long term. We act responsibly and ensure that future generations have the same opportunities as we have today.
At a minimum, Suppliers are to comply with all applicable environmental laws and regulations of the applicable country of manufacture. In the absence of any applicable laws, Suppliers are to take responsible actions to adopt procedures to ensure the proper protection of the environment through better management, policies, technology and equipment that promote responsible use of natural resources and minimization of pollution
With regards to Water Sports, our Blue Oceans (Plastic Free) movement supports the conservation and sustainable use of aquatic environments, including oceans, seas and coasts and their magnificent diversity of plant and animal species. As a result, we request our Suppliers to adopt concrete measures to reduce unnecessary plastic, focusing on eco-friendly packaging and neoprene and using recycled materials.
Suppliers – HEAD’s Enforcement Action
HEAD expects its suppliers and other contractual partners to implement appropriate measures to ensure that modern slavery and human trafficing do not take place within their scope or supply chain. HEAD has never knowingly supported and/or done any business with any suppliers who were or are involved in slavery.
HEAD holds the right to terminate any of its supply agreements in the event any such supplier is found to be in breach of its obligations and the HEAD Code of Conduct.
We will continue to review and update the policies and procedures periodically to ensure employees in HEAD and its supply chain are protected from mistreatment including forced labor and human trafficking.