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Supplier Code of Conduct


CONNER HATS

SUPPLIER CODE OF CONDUCT

Preface

This Supplier Code of Conduct sets forth the commitment of Conner Hats to do business only with those suppliers and factories that share Conner Hat’s commitment to fair and safe labor, health & environmental practices.

WE REALIZE THAT EVERY PRODUCT MADE CAUSES ENVIRONMENTAL IMPACT TO SOME DEGREE.
IT IS OUR GOAL TO LIMIT THAT IMPACT.

The Supplier Code of Conduct defines our minimum expectations. Since no Code can be all-inclusive, we expect our vendors to ensure that no abusive or exploitative conditions and practices or unsafe working conditions exist at the facilities where our hats are manufactured. Conner Hats will not tolerate any vendor that directly or indirectly, through its subcontractors, violates the laws of the country our hats are manufactured.
A copy of this Supplier Code of Conduct, translated into the native languages of the workforce, should be prominently displayed within each facility where Conner hats are manufactured.


Contents

I. GENERAL EMPLOYMENT STANDARDS & PRACTICES
II. HEALTH & SAFETY STANDARDS & PRACTICES
III. ENVIRONMENTAL STANDARDS & PRACTICES
IV. VERIFICATION METHODS


I. GENERAL EMPLOYMENT STANDARDS & PRACTICES
1. Forced Labor:
There shall not be any use of forced labor, whether in the form of prison labor, indentured labor, bonded labor or otherwise.

2. Child Labor & Age Verification:
No person shall be employed at an age younger than 15 or younger than the age for completing compulsory education if the age in the country of manufacture is greater than 15. Young workers, under the age of 18, must not be exposed to hazardous, unsafe or unhealthy working conditions or materials. Adequate protection against such hazards must be provided to all young workers.
All facilities are required to maintain official documentation in order to verify each worker’s date of birth, as well as appropriate records documenting that the employer adheres to all restrictions under local labor laws that apply to juvenile workers.

3. Harassment or Abuse:
Workers shall be treated with respect and dignity. Workers shall not be subject to any physical, verbal, sexual or psychological harassment or abuse in connection with their employment.


4. Nondiscrimination:
No person shall be subject to any discrimination in any aspect of the employment, relationship including recruitment, hiring, compensation, benefits, work assignments, access to training, advancement, discipline, termination or retirement, on the basis of race, religious belief, color, gender, pregnancy, childbirth or related medical conditions, age, national origin, ancestry, sexual orientation, gender identification, physical or mental disability, medical condition, illness, genetic characteristics, family care, marital status, caste, socio-economic situation, political opinion, union affiliation, ethnic group, illness any other classification protected under applicable law. All employment decisions must be made based on the principle of equal employment opportunity, and shall include effective mechanisms to protect migrant, temporary or seasonal workers against any form of discrimination.

5.Freedom of Association and Collective Bargaining:
Workers must be free to join organizations of their own choice. Suppliers shall recognize and respect the right of employees to freedom of association and collective bargaining. All suppliers must develop and fully implement effective grievance mechanisms which resolve internal industrial disputes, employee complaints, and ensure effective, respectful and transparent communication between employees, their representatives and management.

6.Wages and Benefits:
Employers shall pay workers for all work completed and shall pay at least the minimum wage required by law or the prevailing industry wage, whichever is higher, and shall provide legally mandated benefits.
Employers should provide to workers, for each pay period, a clear and understandable wage statement that includes days worked, wage or piece rate earned per day, hours of overtime, bonuses, allowances and a description of any and all deductions.
Manual or electronic time cards should be used for hourly workers. For “piecework” workers, an industry recognized system, capable of audit verification, should be used.

7. Work Hours:
As part of normal business operations, workers shall be entitled to at one full day off out of each seven-day week. In the case of those countries where laws do not limit the hours of work, workers should not be required to work on a regular basis in excess of a regular work week plus 12 hours overtime. Workers shall not be asked or required to take work home or off premises.

8. Overtime:
It is understood that overtime is often required in the manufacturing process. In addition to compensation for regular hours of work, workers shall be compensated for overtime hours at such a premium rate as legally required or, in countries where there is no legal standard, in those countries where such laws do not exist, at a rate exceeding the regular hourly compensation rate by at least 125%.. In no event shall this be at a rate less than the regular hourly rate. Factories shall carry out operations in ways that limit overtime to a level that ensures productive and humane working conditions.

9. Compliance with Laws:
All Standards set forth in this Code of Conduct are subject to compliance with applicable local law. All factories shall operate in full compliance with the laws of their respective country of manufacture. If any standard set forth in this Code of Conduct is, in the factories’ judgment, deemed to violate an applicable local law it must advise Conner Hats promptly in writing.

10. Subcontractors:
All subcontractors must be disclosed to Conner Hats prior to production, and all subcontractors and facilities must be pre-approved by Conner Hats. Any subcontractor must be in compliance with this Code of Conduct and each of factories is responsible for ensuring its subcontractor’s compliance.

11. Animal Welfare:
Suppliers must respect animal welfare and work progressively towards adopting healthy and humane practices towards animals based on best available technology and standards.

II. HEALTH & SAFETY STANDARDS & PRACTICES
1. Health and Safety - Factories:
• Factories should have adequate circulation and ventilation.
• Free potable water should be reasonably accessible to all workers throughout the working day.
• Workers should have access to clean and private toilet facilities in adequate numbers for each gender.
• There is to be no use of corporal punishment.
• Work areas should be sufficiently lit so that manufacturing tasks may be safely performed.
• All equipment should be tested regularly and properly maintained. Operational safety devices should be installed on equipment where appropriate.
• Factories should make available personal protective equipment to workers performing hazardous tasks.
• Hazardous and combustible materials should be stored in secure, well ventilated areas.
• Each factory should have at least one well-stocked first aid kit.
• We require that each enclosed manufacturing facility have an adequate number of clearly marked, unlocked exits in order to provide for an effective evacuation in case of emergency. By adequate, it is meant that each work station should be within 200 feet of an exit.
• Aisles, exits and stairwells should be kept clear of any obstructions that could prevent the orderly evacuation of workers.
• Each facility should have appropriate fire prevention capability based upon the size of the facility and number of workers normally occupying the premises.
• Fire extinguishers should be properly maintained and inspected annually, tagged with the most recent inspection date, and properly deployed throughout the premises to be visible and accessible to workers in case of fire.
• Factories should conduct a minimum of one emergency evacuation drill per year.
• Emergency evacuation diagrams should be posted and clearly visible to employees.

2. Dormitories/Living Facilities:
The following standards shall apply where workers are housed in facilities provided by the supplier/facility:
• Facilities should have adequate ventilation and circulation.
• Free potable water should be readily accessible.
• Clean and private toilet and bathing facilities should be reasonably accessible.
• Each housing facility should have at least one well-stocked first aid kit.
• Each housing facility should have an adequate number of unlocked and clearly marked exits for evacuation in case of emergency.
• Aisles, exits and stairwells should be kept clear from any obstructions that could prevent orderly evacuation.
• Each living facility should have appropriate fire prevention capability based upon the size of the facility and number of workers normally occupying the premises.
• Fire extinguishers should be properly maintained and inspected annually, tagged with the most recent inspection date, and properly deployed throughout the premises to be visible and accessible to employees in case of fire.
• A minimum of one emergency evacuation drill per year should be conducted.
• Emergency evacuation diagrams should be posted and clearly visible to employees.
• The living space per worker in their sleeping quarters must meet all minimum legal requirements.

III. ENVIRONMENTAL STANDARDS & PRACTICES
1. Environmental Management System:
• The organization has an environmental policy
• A mechanism is in place to monitor changes in environmental laws and regulations to achieve and maintain compliance
• A member of the management team has been appointed and properly trained for the coordination of environmental management activities
• An emergency protocol to deal with environmental incidents has been developed – the emergency protocol should include an emergency plan, trained emergency team and regular drills
• Regular environmental training is provided to employees
• The organization has a corrective action procedure in place to address environmental non-conformance

2. Air Emissions:
• There is a complete written inventory of emissions sources identifying the source, type and amount of each pollutant
• Air emission sources are equipped with pollution control devices that remove or filter the contaminants prior to release when needed
• Maintenance of air emission control equipment is performed on a regular basis
• ODS (ozone depleting substances) containment equipment is inspected and maintained on a regular basis to prevent the accidental release of substances
• Appropriate permits/authorizations have been obtained as required by local and national regulations and the organization is in compliance with all permit/authorization parameters
• Local and national regulation air emissions limits are complied with
• Appropriate procedures are in place to take immediate corrective action in the event that air emissions limits are exceeded
• Regular air emissions monitoring (sampling and testing) as required by local and national regulations are conducted

3. Energy and Greenhouse Gas Emissions:
• There is a current and complete energy use inventory (e.g. energy consumption data from energy bills and meter readings, fuel bills, gas bills)
• There is a current and complete inventory of greenhouse gas emissions (direct and indirect)
• The organization meets all applicable energy and greenhouse gas emissions legal requirements

4. Solid (Non-Hazardous) Waste Management:
• All appropriate permits for on-site waste disposal required by local & national regulations have been obtained
• Waste containers and appropriate labels are maintained and kept in good condition
• Waste inventory and tracking records are complete and current
• Solid waste is free from hazardous waste contamination
• Solid waste collection areas are secured and protected
• The factory treats/disposes/recycles solid waste properly and documents the final destination of all solid waste

5. Water Consumption:
• Appropriate permits for water use/extraction required by local & national regulations have been obtained
• Data regarding water use consumption (e.g. water consumption data from water bills and meter readings) is recorded and maintained regularly

6. Wastewater Management:
• Appropriate permits for wastewater/effluents treatment and discharge as required by local and national regulations have been obtained
• Wastewater/effluent discharge limits required by local & national regulations are strictly complied with
• Appropriate procedures are in place to take immediate corrective actions in the event that discharge limits are exceeded
• Monitoring of wastewater discharges is undertaken as required by local and national regulations including sampling for analysis from point of discharge (or as instructed by permit requirements)
• Results of wastewater monitoring confirms the discharge meets permit/authorization parameters
• Wastewater monitoring records are kept on-site for review by outside personnel upon request
• Sanitary wastewater is appropriately either treated on site or discharged to an offsite treatment center (Publicly Owned Treatment Works, local municipality, etc.)
• If applicable, a drainage system is in place to convey wastewater to treatment and/or discharge points
• If applicable, on-site wastewater treatment plant is maintained in safe operating conditions to avoid any risks to environment and/or human health
• Drains are regularly cleaned and maintained
• Drainage layout must be made available upon request
• Wastewater personnel understand the processes, equipment and testing required to operate the on-site treatment plant correctly
• Rainwater is discharged to a location other than the treatment plant or is added at a time during the process that does not negatively interfere with the treatment process

7. Land Use and Biodiversity:
• The organization conducts an Environmental Impact Assessment and submits the results to competent authority for review and approval as required by local and national regulations
• Appropriate permits for land use and facilities construction required by local & national regulations are obtained
• All applicable local and national regulations regarding protected land are met

8. Noise Pollution:
• Appropriate permits for noise pollution as required by local and national regulations are obtained
• Noise pollution assessments as required by local and national regulations are performed
• Regular noise pollution monitoring as required by local and national regulations is conducted
• Noise pollution limits as required by local and national regulations are strictly complied with
• Immediate corrective actions are taken in the event noise pollution limits are exceeded

9. Raw Materials:
• Inventory records and production records demonstrating origin of incoming materials and traceability and place of product are maintained
• The organization must demonstrate through chain of custody documents (certifications) that raw materials (cotton, wood, etc.) were obtained from legal harvests consistent with international treaties and protocols in addition to local laws and regulations even if national regulations do not regulate harvests.

10. Hazardous Waste Management:
• Neither chemicals listed on the Restricted Substances List nor chemicals banned by local and national regulations are utilized in the production process
• Appropriate permits for hazardous substances handling and storage as required by local and national regulations have been obtained
• The organization has verified the existence of sensitive receptors (e.g. rivers, underground water, etc.) close to production facilities
• Effective procedures are in place to prevent contamination of people and the environment


IV. VERIFICATION METHODS
1. Conner Hats holds its factories accountable that the merchandise produced for it is manufactured in compliance with this Code of Conduct.
2. Conner hats expects its factories to monitor their compliance to this Code of Conduct. Conner Hats will utilize, where appropriate, internal as well as third party monitors to conduct on-site evaluations and inspections of its factories’ facilities, as well as those of its subcontractors.
3. Conner Hats will use the following methods to evaluate its suppliers and their facilities:
• Conner Hats representatives shall conduct pre-production evaluation of supplier facilities as well as any subcontractor’s facilities.
• Conner hats representatives shall conduct unannounced (without notice) and unaccompanied inspections to supplier and subcontractor facilities for the purpose of auditing compliance to this Code of Conduct. Such Inspections may be conducted by Conner Hats representatives or by third parties retained by Conner Hats. Inspections may include, but will not be limited to the following:
° The ability to conduct interviews with employees, on or off-site, without fear of repercussion from employers.
° Inspections of employee files, including time cards and wage statements.

WE CURRENTLY OPERATE OUT OF TWO HEADQUARTERS.

ST. AUGUSTINE, FLORIDA – USA
Home of our 1 acre food forest project

We decided to grow our own corporate responsibility right next to our original hat warehouse in St. Augustine, Florida. This food forest is a place for people to see Permaculture principals in action, a place to learn about food security, regenerative agriculture and more. The site was designed by world renowned permaculture designer Geoff Lawton.

>> See more here

On April 22nd, 2015 (Earth Day) we added 15KW (58 solar panels) to our St Augustine warehouse. Currently this is powering 100% of our electric needs. Powering business by the sun is a dream come true and because of you we were able to achieve this.

check our solar output here.

Ditching single-use plastic is one of our primary goals at all levels of Conner Hats. Americans use 1500 plastic water bottles every second. For us, this really drives home the fact that we need to do our part to limit the production of plastic.

Reducing single use plastics is important for many reasons. Huge amounts of plastic end up in our waterways and ocean. Birds and sea life mistake it for food and many die from ingesting or choking on plastic. It also breaks down into very small pieces which are eaten by fish. We then eat the fish and the PCB’s, dioxins and other toxic chemicals can end up in us.

Things we can do to help might seem small, but everything helps. Choose products that use no or minimal plastic packaging. Recycle everything you can. Say no to plastic straws. Use Reusable bottles and cups. Use reusable grocery bags. Let your favorite take-out restraint owner know that there are cheap alternatives to plastic and petroleum foam.

Besides a whole new line of hats made from recycled plastic bottles we have also stopped the use of single-use plastic connectors to connect our hang tags; we use a biodegradable string instead.

We asked our Conner Hats metal emblem supplier to stop individually bagging each tiny emblem in a plastic pouch, instead they are sent flat on sections of cardboard. This alone stops the production of thousands of tiny single use plastic pouches.

All of our packaging is single use plastic free including our new biodegradable backing tape.

Clothing/Hat garment labels are generally woven synthetic material that will last 1000+ years and pollute. We have recently chosen to use organic cotton printed with vegetable dyes for our inner labels, even our inner size labels ore now made from paper. These labels will eventually turn back into soil. We have been thinking about the end of life for our hats. After they have been used for many years and if they are made from biodegradable material like organic cotton, hemp, raffia straw or wool they could be composted and turn back into healthy soil for your garden. Stay tuned for a video on this soon. So now we are excited to sell many hats from biodegradable materials, no single use plastic, compostable tags and labels and even new biodegradable tape for our boxes, all of it will eventually and turn back into healthy soil!

It’s our job to care about what touches your head, that’s why many of the sweatbands and linings are made from third party tested organic cotton and are AZO dye free. All of our deluxe stretch terry hat bands have been third party tested and do not contain AZO dyes or Formaldehyde.

Further details on some of our hat materials:

Cruelty Free Wool
Starting March 2018 we will be changing our wool hat production to Cruelty Free wool. This means that we went back into our supply chain and only source wool from farms that do not practice Mulesing. Mulesing is the removal of chunks of skin on the buttocks of the sheep to stop a disease called Flystrike. Over 20 million Merino lambs are Mulesed in Australia each year. Hopefully by educating people on this topic Australia might consider the alternatives to this cruel practice.

Hemp
Hemp is very easy to grow and is three times stronger that cotton. Hemp crops don’t require much water and can be grown without herbicides, fungicides or pesticides.

Organic Cotton
We third party test our organic cotton to confirm OCS certified 100 and AZO Free.

Leather
We test our leather to confirm No Organic biocides, Azo Dye-Free, No Prohibited Metals, No Flame Retardants, Formaldehyde-Free, No Chromium (VI)

Some people may have a problem with leather for environmental or humane reasons. We use leather because it’s an excellent hat material. It’s extremely durable and some of our leather hats are still in use over 40 years later. Look for a link to our blog here on this subject in the near future.

Organic Raffia
The Raffia palm found in Madagascar has the longest leaves in the plant kingdom and can grow to eighty feet long. No need for water or pesticides, just cut the leaves needed and they grow back.

Paper
Toyo was originally made in japan from shellacked rice paper. We use 100% recycled paper with a non-toxic waterproof resin to keep them protected. It’s a machine made material made in China and hand woven into beautiful hats.

Repreve® Recycled Plastic
We use Repreve material for our recycled hats and they contain about 5 recycled plastic bottles worth of plastic. The fabric is light weight, UPF 50+ and waterproof. More importantly it’s made from recycled plastic bottles, straws and other single use plastics that could have ended up in our environment. It uses 70% less energy and 90% less water to produce our recycled fabric verses a virgin material.

>> Find out more about repreve® here

That’s right, most of our fabric hats have Bloom Algae Foam inside of the brims and some crowns. So instead petroleum based foam we use Bloom Foam that is made from cleaning algae blooms that pollute fresh water and turned into usable foam for many types of products including our hats. You may not see it, but it is there and goes with one of our slogans “ It’s what’s on the inside that matters”.

>> You can find out more hereHats made with Algae

Our safety standards are guided by the question:

“Is the hat safe enough for a baby to chew on?”

All of the dyes and paints used to color our hat materials are third-party tested, nontoxic lead free

Our USA wool felt hat production meets our non-toxic standards. The stiffener is made from food grade shellac and the color dyes are safe for the environment, all exhausted waters used are put in the public sewer for normal treatment.

Our wool hat production in China has been third- party tested and no Azo dyes are used and no toxic chemicals in the hat bodies. We trust our factories to keep our high standards but just in case we do third party tests from time to time to confirm both in USA and China.

Our packaging has recently improved with new biodegradable packing tape so all of our packaging is fully compostable and nontoxic.

First of all, it’s important to realize that the difference between organic and conventional cotton isn’t just the lack or use of pesticides and insecticides in the farming process. Conventional cotton is also subjected to numerous chemical baths and treatments when the fabric is loomed and prepared for cutting. Additionally, conventional cotton uses dyes that sometimes contain heavy metals. We use only nontoxic dyes in our organic cotton.

Conventional cotton farming takes a huge toll on our planet, being responsible for a full quarter of the insecticides used worldwide. Some of the most toxic pesticides are also used on cotton, and people consume those pesticides in foods containing cottonseed oil.

Choosing organic cotton helps to support organic farmers and gives motivation to conventional farmers who are trying to convert to organic practices. Spreading the word to friends and family also helps to raise global awareness about the benefits of choosing organic cotton. Hopefully, over time, this can reduce the amount of chemicals consumed by conventional cotton farming and help contribute to a healthier planet.

Byron Bay, N.S.W. – Australia
Home of our founders and design inspiration

Byron Bay is the home town of our founders and it’s famous original Australian hat brand, BC hats. Bill Conner, after a very successful 50 years decided to close his factory and retire to spend more time in the surf. His son, Will Conner still designs Conner hats from Byron Bay and both Will and Bill are very much involved in the local community. Bill planted 2000 native Hoop Pine trees on his 20 acre property nearby as a carbon credit for his business. He stayed true to an Australian made product and his hats are loved worldwide and landed on famous customers from Michael Jordan to Olivia Newton John and many more. His hats are sure to become collectors items as no new hats will be available after the last one sells.

>> Shop BC hats

We offset a percentage of our carbon footprint by planting and maintaining 2000 native hoop pines on our family owned property about 35km from the factory.

Our factory is a fume free zone. We use only nontoxic glues in our manufacturing. Australia is a very worker friendly country and we all have lots of fun creating shade for people.

Our small, family run operation uses mostly Australian and New Zealand raw materials.

We have received a Declaration of Conformance for all of our leather used:

Customer: B. C. Leather Pty Ltd
Bovine Leather suitable for Hats

Safety Standards: EC DIRECTIVE 91/173(CHLORINATED PHENOIS)
EC DIRECTIVE 2002/61 (AZO DYES)

No banned substances have been used in manufacture, and the leather shall not contain the following, including: Organic biocides (PCP or TCP) from fungicides Aromatic Amines from Azo Dyes Sensitising Disperse Dyes Prohibited Metals Arsenis, Nickel, Cadmium, Mercury or Chrome V1 (Hexavalent Chromium) Flame Retardants (Brominated) Formaldehyde