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Corporate responsibility



BRIGHTON HILL follows strictly the BSCI Code of Conduct 

In accordance with the ILO Conventions, the United Nations' Universal Declaration of Human

Rights, the UN's Conventions on children's rights and the elimination of all forms of

discrimination against women, the UN Global Compact and the OECD Guidelines for

Multinational Enterprises and other relevant internationally recognised agreements, the BSCI

Code of Conduct aims to attain compliance with certain social and environmental standards. By

signing the BSCI Code of Conduct companies are, within their scope of influence, committed to

acknowledge the social and environmental standards laid down in this Code and to take

appropriate measures within their company policy for their implementation and compliance.



1. Legal Compliance  

Compliance with all applicable laws and regulations, industry minimum standards, ILO and

UN Conventions, and any other relevant statutory requirements whichever requirements are

more stringent. In the agricultural context, ILO Convention 110 shall be respected. 


2. Freedom of Association and the Right to Collective Bargaining 

All personnel shall have the right to form, join, and organise trade unions of their choice

and to bargain collectively on their behalf with the company. The company shall respect this

right, and shall effectively inform personnel that they are free to join an organisation of

their choosing and that their doing so will not result in any negative consequences to them,

or retaliation, from the company. The company shall not in any way interfere with the

establishment, functioning, or administration of such workers’ organisations or collective

bargaining. In situations where the right to freedom of association and collective bargaining

are restricted under law, the company shall allow workers to freely elect their own

representatives. The company shall ensure that representatives of workers and any

personnel engaged in organizing workers are not subjected to discrimination, harassment,

intimidation, or retaliation for reason of their being members of a union or participating in

trade union activities, and that such representatives have access to their members in the


- In accordance with ILO Conventions 11, 87, 98, 135 and 154.  5


3. Prohibition of Discrimination 

No discrimination shall be tolerated in hiring, remuneration, access to training, promotion,

termination or retirement based on gender, age, religion, race, caste, birth, social

background, disability, ethnic and national origin, nationality, membership in workers’

organisations including unions, political affiliation or opinions, sexual orientation, family

responsibilities, marital status, or any other condition that could give rise to discrimination. 

- In accordance with ILO Conventions 100, 111, 143, 158, 159, 169 and 183. 


4. Compensation 

Wages paid for regular working hours, overtime hours and overtime differentials shall meet

or exceed legal minimums and/or industry standards. Illegal, unauthorised or disciplinary

deductions from wages shall not be made. In situations in which the legal minimum wage

and/or industry standards do not cover living expenses and provide some additional

disposable income, supplier companies are further encouraged to provide their employees

with adequate compensation to meet these needs. Deductions from wages as a disciplinary

measure are forbidden, unless this is permitted by national law and a freely negotiated

collective bargaining agreement is in force. Supplier companies shall ensure that wage and

benefits composition are detailed clearly and regularly for workers; the supplier company

shall also ensure that wages and benefits are rendered in full compliance with all applicable

laws and that remuneration is rendered in a manner convenient to workers. 

All overtime shall be reimbursed at a premium rate as defined by national law. In countries

where a premium rate for overtime is not regulated by law or a collective bargaining

agreement, personnel shall be compensated for overtime at a premium rate or equal to

prevailing industry standards, whichever is more favourable to workers’ interests. 

- In accordance with ILO Conventions 12, 26, 101, 102 and 131. 


5. Working Hours 

The supplier company shall comply with applicable national laws and industry standards on

working hours and public holidays. The maximum allowable working hours in a week are as

defined by national law but shall not on a regular basis exceed 48 hours and the maximum

allowable overtime hours in a week shall not exceed 12 hours. Overtime hours are to be

worked solely on a voluntary basis and to be paid at a premium rate. In cases where

overtime work is needed in order to meet short-term business demand and the company is

party to a collective bargaining agreement freely negotiated with worker organisations (as

defined above) representing a significant portion of its workforce, the company may require

such overtime work in accordance with such agreements. Any such agreement must comply

with the requirements above. 

An employee is entitled to at least one free day following six consecutive days worked. 

Exceptions to this rule apply only where both of the following conditions exist: 

a) National law allows work time exceeding this limit; 


b) A freely negotiated collective bargaining agreement is in force that allows work time

averaging, including adequate rest periods. 

- In accordance with ILO Conventions 1 and 14 and ILO Recommendation 116. 


6. Workplace Health and Safety 

The company shall provide a safe and healthy workplace environment and shall take

effective steps to prevent potential accidents and injury to workers’ 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 workplace environment, and bearing in

mind the prevailing knowledge of the industry and of any specific hazards. 

A clear set of regulations and procedures must be established and followed regarding

occupational health and safety, especially the provision and use of personal protective

equipment, access to clean toilet facilities, access to potable water and if appropriate,

sanitary facilities for food storage shall be provided. The company shall ensure that any

dormitory facilities provided for personnel are clean, safe, and meet the basic needs of the

personnel.  6

All personnel shall have the right to remove themselves from imminent serious danger

without seeking permission from the company. 

Workplace practice and conditions and conditions in dormitories which violate basic human

rights are forbidden. In particular young workers shall not be exposed to hazardous, unsafe

or unhealthy situations. 

- In accordance with ILO Conventions 155, 184 and ILO Recommendations 164 and 190. 

In particular, a management representative responsible for the health and safety of all

personnel and accountable for the implementation of the Health and Safety elements of the

BSCI shall be appointed. All personnel shall receive regular and recorded health and safety

training, moreover, such training shall be repeated for new and reassigned personnel. 

Systems to detect, avoid or respond to potential threats to health and safety of all

personnel shall be established.. 


7. Prohibition of Child Labour  

Child labour is forbidden as defined by ILO and United Nations Conventions and/or by

national law. Of these various standards, the one that is the most stringent shall be

followed. Any forms of exploitation of children are forbidden. Working conditions resembling

slavery or harmful to children's health are forbidden. The rights of young workers must be

protected. In the event that children are found to be working in situations which fit the

definition of child labour above, policies and written procedures for remediation of children

found to be working shall be established and documented by the supplier company.

Furthermore, the supplier company shall provide adequate financial and other support to

enable such children to attend and remain in school until no longer a child. 

The company may employ young workers, but where such young workers are subject to

compulsory education laws, they may work only outside of school hours. Under no

circumstances shall any young worker’s school, work, and transportation time exceed a

combined total of 10 hours per day, and in no case shall young workers work more than 8

hours a day. Young workers may not work during night hours. 

- In accordance with ILO Conventions 10, 79, 138, 142 and 182 and Recommendation 146. 


8. Prohibition of Forced and compulsory Labour and Disciplinary Measures

All forms of forced labour, such as lodging deposits or the retention of identity documents

from personnel upon commencing employment, are forbidden as is prisoner labour that

violates basic human rights. 

Neither the company nor any entity supplying labour to the company shall withhold any part

of any personnel’s salary, benefits, property, or documents in order to force such personnel

to continue working for the company. 

Personnel shall have the right to leave the workplace premises after completing the

standard workday, and be free to terminate their employment provided that they give

reasonable notice to their employer. 

Neither the company nor any entity supplying labour to the company shall engage in or

support trafficking in human beings. 

The company shall treat all personnel with dignity and respect. The company shall not

engage in or tolerate the use of corporal punishment, mental or physical coercion and

verbal abuse of personnel. 

- In accordance with ILO Conventions 29 and 105. 


9. Environment and Safety Issues 

Procedures and standards for waste management, handling and disposure of chemicals and

other dangerous materials, emissions and effluent treatment must meet or exceed

minimum legal requirements.  7


10. Management Systems 

The supplier company shall define and implement a policy for social accountability, a

management system to ensure that the requirements of the BSCI Code of Conduct can be

met as well as establish and follow an anti-bribery / anti-corruption policy in all of their

business activities. Management is responsible for the correct implementation and

continuous improvement by taking corrective measures and periodical review of the Code

of Conduct, as well as the communication of the requirements of the Code of Conduct to

all employees. It shall also address employees’ concerns of non compliance with this Code

of Conduct. 

The following annexes are integral part of this Code of Conduct: 

- Declaration of the supplier company 

- Terms of implementation 

- Consequences of Non-Compliance