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Due Diligence Policy 2025
Dear Partner,
We are committed to running a responsible and sustainable business. Ensuring that our products are produced under responsible conditions stands at the core of this commitment, and in fulfilment of our ambition, we expect our partners – suppliers, subcontractors, agents, and other business partners – to operate responsibly and act with integrity, fairness and responsibility in all aspects of their business. This policy is focused on our supply chain, however the due diligence process is also implemented and carried out at our Headquarter.
Our Due Diligence process is embedded in our 2024 ESG Strategy and seeks to uphold the principles of good governance and social and environmental sustainability and convey such corporate ethical culture to all our stakeholders, promoting respect for fundamental Human and Labour Rights across our supply chain partners.
Implementation of due diligence processes is the focal point of our work, and that means in practice that we will:
01. Identify areas where there is a risk that the business conduct may have negative impact on e.g. human rights, environment and climate conditions.
02. Prevent and/or remedy that the negative impact takes place.
03. Follow up on the measures that have been taken, are complied with, and have the desired effect.
04. Account for the effort to handle the negative impact.
The standards of the Policy are based on internationally agreed conventions, including but not limited to: the International Bill of Human Rights, the International Labour Organisation’s (ILO) Declaration of the Fundamental Principles and Rights at Work, the UN Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises, the OECD Due Diligence Guidance for Responsible Business Conduct, the UN Convention Against Corruption, the Rio Declaration on Environment and Development; and the UN Global Compact’s 10 Principles.
All suppliers are expected to comply with national legislation, regulations, and applicable practices and industry standards as relevant to their business.
Please refer to the enclosed Policy for more information about the specific requirements. If you have any questions regarding this policy, our Code of Conduct, or our supply chain manual in general, please do not hesitate to contact our offices.
With kind regards,
Konges Sløjd A/S
DUE DILIGENCE REQUIREMENTS
International guidelines call on businesses to exercise due diligence to detect, prevent, and mitigate any adverse impacts related to human and labour rights, the environment, including climate, and anti-corruption.
When a supplier is onboarded to our supply chain they go through a risk assessment in our IT system Qarma and must sign a supplier agreement, where they commit to upholding all KS policies. All policies, including the Code of Conduct, have been designed to incorporate best practices outlined by the UN Guiding Principles (UNGP) on Business and Human Rights, the International Labour Organization, (ILO) and the The Organisation for Economic Co operation and Development (OECD). The policies address specific human rights risks inherent in KSs supply chain.
We conduct annual risk assessments of our human rights risks and use those assessments to inform and update our policies, factory assessment criteria and methodology, and to inform decisions about where to invest resources in risk mitigation. This risk assessment is primarily concerned with the risk of adverse impacts on people that KS can cause, contribute to, or to which we are linked by our Tier 0 and Tier 1 business partners.
• Tier 0 are our traders or agents
• Tier 1 are the companies we do business with directly and work with product manufacture or processing
The scope of this assessment covers all sites where KS production takes place that is assessed and verified by KS. This includes cut, stitch, weave/link/knit, iron, pack embroidery, laundry, printing, dying, tannery, assembly, electroplating, casting, upper manufacturers, sample room, warehousing, and homeworker facilities. We consider the severity and likelihood of these issues and our leverage. We also draw on a range of sources such as data from our IT Qarma system, stakeholder and local NGOs and trade unions views, as well as desktop research such as analysis of external datasets like human rights indices.
Under the scope of this human rights risk and salient issues assessment, we have identified numerous issues.
THE HUMAN RIGHTS WE FACE ARE:
• Child labour
• Forced Labour
• Migrant labour
• Employment conditions
• Discrimination and harassment
• Freedom of Association and Collective Bargaining
• Working hours and leave
• Wages
• Occupational Health & Safety
ACTIONS WE TAKE:
With each of these risks, we review our policies, assessment methodology, remediation and mitigation efforts, to ensure they meet guidance on best practice, and dedicate resources. We recognise there is more to do to better understand human rights risk and measure impact to ensure our due diligence and action is really addressing these salient issues adequately. Risks to human and labour rights are not static, and advice on how to address them is continually evolving, so we will regularly review our human rights risk, our accompanying policies, and assessment methodology, as well as the impact of our mitigation efforts.
Child labour
Suppliers must not use child labour below the age of 15, even if permitted by national law.
All legal limitations regarding young workers between the age of 15 and 18 must be followed
and young workers are only permitted to carry out light work at reduced hours.
This means that they must be protected from any hazardous work, night shifts, and any kind
of work that might hamper their physical and psychological development or impose any harm.
If child labour is detected at a facility, the supplier is responsible for developing, participating in,
and contributing to policies and programmes that provide for transitional arrangements to enable
the child to remain in quality education until no longer a child.
Forced labour
Employment must be freely chosen.
Suppliers must not use or support any form of slavery and forced and bonded labour.
Employees must not be subject to recruitment fees or deposits, withholding of salary
and benefits, lodging of personal documents by the employer, or forced to overtime.
Migrant labour
At Konges Sløjd, we ensure fair treatment of migrant workers by conducting
thorough social audits during the onboarding process for all suppliers.
These audits verify compliance with our standards, including ethical recruitment,
fair contracts, and equal pay. We check that working conditions are safe,
accommodations meet proper standards, and workers retain access to their
passports and documents. Confidential interviews help confirm that workers’
rights are respected, and wage records are reviewed to ensure fairness.
By auditing suppliers at the outset, we ensure our values of dignity, equality,
and respect for migrant labor are upheld from the start.
Employment conditions
Obligations to employees under
international conventions and social security laws and regulations arising from
the regular employment relationship must not be avoided by using short-term
contracts, such as contract labour and casual labour. All employees, including
temporary and casual workers, must have written and legal employment letters in
a language they understand, specifying conditions of employment and
termination.
Discrimination and harassment
Suppliers must not engage in or support discrimination in recruitment and in employment.
Decisions about hiring, compensation, access to training, advancement,
discipline, termination or retirement must be solely based on the ability to
perform the job and not on the grounds ofgender, marital or parentalstatus, pregnancy, race, caste, colour, age, sexual orientation,
religion, political opinion, union membership, function as worker representative,
nationality, ethnic origin, health status, or disability.
All workers must be treated with respect and dignity. Suppliers must prevent,
not engage in nor support the use of bullying, intimidation, violence, threats of
violence, corporal punishment, or physical, sexual, psychological and verbal
harassment or abuse. Procedures to ensure punitive measures in cases of
harassment and/or discrimination must be put in place. Special measures must be
put in place to protect female workers against gender-based violence and
harassment in the workplace.
Freedom of association and collective bargaining
Suppliers must respect the rights of workers to join and organise associations of their
own choosing and to bargain collectively with no interference or sanctions from
employers. The supplier must implement mechanisms, such as worker participation
committees, for resolving disputes, including employee grievances, and ensure
effective communication with employees and their representatives.If the rights to freedom of association and
collective bargaining are restricted by national law, the supplier must allow
workers to freely elect their own representatives, and alternative forms of
worker representation must be supported.
Working hours and leave
Standard working hours must follow local regulations, collective bargaining agreements
and industry standards, but must not exceed 48 hours per week, excluding
overtime. All overtime must always be consensual and not requested on a regular
basis. Weekly overtime must not exceed 12 hours. Employees must be allowed a
minimum of 1 day off per week and paid annual leave. Maternity leave, sick
leave, and other types of leave must be provided to all employees in accordance
with relevant local regulations.
Wages
Wages for a standard working week must at a
minimum meet the legal minimum wage, in dustry standards or negotiated wages,
whichever is higher. Wages must be paid regularly and in a timely manner.
Suppliers should work towards providing a fair living wage, im plying that
wages are enough to meet the basic needs of employees and their families and
provide some discretionary income. All overtime work must be compensated at a
premium rate which is recommended to be no less than 125% of the regular pay
rate. Deductions are only permitted if and to the extent prescribed by law or
fixed by a collective agreement. It
may not be used as a disciplinary practice.
Occupational health and safety
A safe and hygienic working environment must be provided for all employees. To prevent accidents and injuries and promote a healthy and safe work environment, suppliers must – at a minimum –ensure that below listed initiatives are in place. The list is not exclusive but outlines the most critical aspects of a health and safety management system. Special measures must be put in place to ensure a gender-sensitive approach.
• Management representatives for occupational health and safety.
• Incident and risk management procedures proportionate to the type and size of business.
• Health and safety training on occupational risks. This includes training in firefighting and handling hazardous materials and chemicals.
• Provision of appropriate personal protective equipment (PPE), free of charge and in good condition. Training in the proper use of the PPE must be provided.
• All premises on site, including company provided dormitories, restrooms, changing rooms and canteen, shall uphold appropriate standards on hygiene, health and safety. This
includes adequate equipment for fire safety.
• Access to clean drinking water and access to sanitary facilities for employees at all times.
• Safe and healthy buildings. All relevant permits and certificates regarding building safety should be kept for review.
• Safe electrical installations installed and maintained by competent personnel.
ENVIRONMENTAL RISKS
Our supply chain is also where we have the biggest environmental impact, therefore, strong cooperation with our suppliers and incentivizing them to reduce the consumption of water, chemicals, energy and the production of waste, is vital to our success. To meet our targets on climate, water, and circularity our products need to be consolidated in suppliers that are willing to move forwards with us on this journey. By 2025, we have committed in our KS strategy that all textile products must hold a product relevant certificate like GOTS, GRS, OCS etc.
Under the scope of this environmental risk and salient issues assessment, we have identified numerous issues.
THE ENVIRONMENTAL RISKS WE FACE ARE:
• Chemicals
• Water
• Air Quality and climate
• Waste management
Chemicals
Suppliers must conduct their operations in accordance with below requirements on chemicals:
• The European Union REACH Regulation (EC) No 1907/2006 Annex XVII and later
amendments;
• The “substances of very high concern” (SVHC) i.e. the European Union REACH Regulation (EC) no. 1907/2006 Candidate List. Suppliers are requested to check the list on a regular basis as this list is continuously updated;
• The ZDHC Manufacturing Restricted Substance List https://mrsl.roadmaptozero.com/ MRSL3_0
• Country specific regulations on export markets. Local laws must be followed in the storage, handling, use and disposal of all chemicals and must comply with the Material Safety Data Sheet (MSDS) for each chemical product.
Water resources
Suppliers must carry out all operations in full compliance with all applicable laws, regulations, and industry guidelines on water conservation, waterquality, and wastewater.
Measures must be put in place to clear wastewater. Suppliers should work towards minimising the use of water during production processes, including introducing water saving techniques and waste- water recycling. This is particularly pertinent for suppliers with wet processing. Suppliers without wet processes are also expected to manage and measure water consumption. Suppliers should work towards measuring the impact of their operations on the local/regional water supply to avoid negatively contributing to water stress.
Air quality and climate
Suppliers must reduce and control emissions to air according to applicable regulations. This includes noise, odour, and dust emissions. Suppliers should work towards mitigating negative impact on climate change by carrying out the following measures: implementing energy efficiency measures in the value chain, starting with high-impact processes, using renewable energy sources if available; and calculating emissions and setting targets to reduce the emissions using recognized standard-setting tools.
Waste management
All waste must be managed responsibly and as a minimum according to applicable regulations. Hazardous waste must be handled by an authorized company/organisation.
Suppliers should minimize waste during production processes going to landfill, facilitate collection of waste to be re-used, reduce use of virgin raw materials, and
optimize use of re-cycled materials. The goal should be no waste to landfill. Local laws must be followed in the storage, handling, use and disposal of all chemicals and must comply with the Material Safety Data Sheet (MSDS) for each chemical product.
Signature
By, name, function:
Thomas Ernfeldt, COO