Ethical Sourcing Policy 

  1. Purpose

Shine On Limited is committed to operating all of its business in an ethical manner and the improvement of social, ethical and environmental standards throughout our supply chain.

The purpose of this ethical sourcing policy is to set out Shine On’s expectations of how

suppliers of Shine On will operate in terms of maintaining and improving ethical standards. It also states how Shine On will manage the supplier relationships.

The policy is a supplement to, not a substitute for, all local laws and regulations applying to suppliers in their country of origin. Suppliers are expected to be aware of, and strive to adhere to, all laws and regulations governing their operations especially in regard to the employment of their workforce, health and safety, environmental protection, and the safety, quality, and legality of goods and services sold to Shine On. 

Shine On believes that everyone including its customers, employees and suppliers should benefit from their interactions with the business. The intent of this policy and the wider Ethical Sourcing Program is to ensure that Shine On merchandise is made in safe and healthy conditions, that workers are properly paid and their rights respected, that factories work to reduce their impact on the environment, and that our trading relationships occur within a context of transparency, trust, and integrity

  1. Expectations

Shine On has the expectation that its suppliers and subcontractors will demonstrate the same commitment to maintaining ethical standards as Shine On does.

Shine On expects its suppliers to comply with the minimum ethical standards outlined in this document, to fully cooperate with any audit processes conducted on behalf of Shine On and to take corrective action to rectify any breach of this policy. At Shine On’s Request to supply any current Audits for Shine on to Review. And to bring any ethical issues for Factories that Shine On works with to our attention and improvement plan.

Shine on reserves the right to terminate any business relationships with suppliers that do not meet the expectations outlined in this policy and fail to take corrective action to rectify any breaches of this policy.

  1. Ethical Standards

Shine On expects its suppliers to comply with the following ethical standards and all associated laws and regulations of the suppliers country in regards to employment, operations, manufacturing and environmental standards.

  • Bribery and Corruption
  • Suppliers must not engage in any acts of bribery or corruption. 

    Suppliers shall not offer gifts or money to any employee or service provider engaged by Shine On. Any attempts to change the outcome of the audit process will result in immediate termination of the supplier relationship.

  • Labour Rights
  • Employment must be freely chosen. Prison labor is prohibited.

    The times of employment must be mutually agreed to by both worker and employer.

    The worker must be free to leave at the end of their shift. Workers must be able to take leave from the factory for reasons of bereavement, illness, or significant family events and at any time when they are not working. Leave, including maternity leave, entitlements shall be upheld.

    Bonded labor is prohibited – suppliers shall not bind workers to their workplace through debt associated with recruitment fees, fines, loans, deferred payment or other means.

    Workers must not be required to lodge deposits or their identity papers with their employer and must be free to leave their employer after reasonable notice.

    Workers shall not be recruited or employed through human trafficking. 

  • Freedom of Association
  • Suppliers must respect that their workers have the right to join a union or a worker’s

    organisation of their own choosing and to bargain collectively.

    Where the right to freedom of association and collective bargaining is restricted

    under the local laws, suppliers must facilitate the development of alternative

    means of independent and free association and bargaining.

  • Health and Safety
  • Suppliers must provide workers with a safe and clean working environment. Suppliers shall ensure that residential facilities for workers, where provided, are clean and safe.

    The responsibility for health and safety should be assigned to a senior management representative.

    Workplace Hazards must be clearly identified and controlled through a working health and safety plan. Adequate steps must be taken to prevent accidents and injury to health

    occurring during the course of work. An accident and injury register is maintained and access to adequate medical assistance and facilities is provided.

    Suppliers must provide adequate safeguards against fire and shall ensure

    strength, stability and safety of buildings and equipment (including residential

    accommodation where provided) are met.

    Suppliers should have a natural disaster or emergency preparedness plan and training is in place. 

    Workers must receive regular and recorded health and safety training. Such

    training must be repeated for new or reassigned workers.

    Suppliers must ensure that personal protective equipment is available and

    employees are trained in its use. Safeguards on machinery must meet or exceed

    local laws.

    Suppliers must ensure that workers are not exposed to hazardous chemicals listed on the Manufacturing Restrictive Substance List.

    Suppliers must provide workers with access to clean toilet facilities, clean and

    drinkable water and if appropriate, sanitary facilities for food storage and

    preparation. Where suppliers provide worker accommodation, it must be clean,

    safe and meet the basic needs of the workers.

    The workplace and its recruitment practices must be free from harassment, or abuse.

  • Child Labour
  • Suppliers must not use child labour and must only employ workers who meet the

                local minimum age requirement. Suppliers must verify the age of their workers

                and maintain evidence of workers’ proof of age.

    Young workers (who are above the minimum employment age but still juveniles)  must be employed in accordance with local law and shall not be required to participate in night work or hazardous work.

    Children are not permitted in the workshop areas of the factory. 

    Where underage workers are detected during a compliance audit, Shine On expects the supplier to take responsibility for repatriating the child and ensuring the continuity of their education and welfare until they attain legal working age.

  • Remuneration
  • Wages and benefits paid must meet, as a minimum, any applicable local laws or

    benchmark industry standards, whichever is the higher. In any event wages qualify as a living wage, where it must always be enough to meet basic needs and provide some discretionary income.

    All workers must be provided with written and understandable information

    about their employment conditions with respect to wages before they enter


    Suppliers shall provide each worker pay slips in their local language detailing regular hours and wages, overtime hours and wages, any bonus paid, and any legally permitted deductions

    Deductions from wages as a disciplinary measure is not permitted, nor any

    deductions from wages not provided for by local laws without the express

    permission of workers. Wages shall not be withheld beyond due dates. All  

    disciplinary and performance management measures must be recorded.

    Where workers are paid by piece, the factory’s piece rate schedule should enable workers to achieve at least the minimum legal payment applicable to all regular and overtime hours worked.

    Where stipulated by law, the supplier shall provide work related injury insurance for all workers. 

  • Working Hours
  • Working hours must comply with local laws and benchmark industry standards,

    whichever affords greater protection.

    Overtime must be voluntary, may not be excessive and must be compensated correctly. It must not be demanded on a regular basis. Supplier must record workers’ regular and overtime hours accurately as the basis for controlling excessive working hours and providing correct compensation. 

    Seasonal peak or deadline based demand for overtime must be offset by rest days and reduced working hours 

    Workers shall be provided with at least one day off in every seven day period or two days off in every 14 day period.

    Suppliers shall comply with national/local laws for workers’ entitlements to

    public and annual holidays.

  • Regular Employment
  • To every extent possible work performed must be on the basis of a recognised

    employment relationship established through national law and practice.

    Obligations to employees under local laws and regulations arising from the

    regular employment relationship must not be avoided through the use of labour-

    only contracting, subcontracting, home-working arrangements or through

    apprenticeship schemes where there is no real intent to impart skills or provide

    regular employment. In addition, any such obligations must not be avoided

    through the excessive use of fixed-term contracts of employment.

  • Illegal Labour
  • Suppliers must not use illegal labour and must be able to verify the right of their

    workers’ (including sub-contractors’) legal eligibility and entitlement to work in

    the country of employment by reviewing original documentation.

  • Discrimination
  • Suppliers must not discriminate in hiring, promotion, compensation, access to

    training, termination or retirement, based on personal characteristics such as

    race, caste, national origin, religion, age, disability, gender, marital status, sexual

    orientation, union membership or political affiliation.

    Women must be able to enter and remain in the workforce without mandatory pregnancy testing, and must have access to all their maternity leave entitlements under local law.

    A written grievance procedure and training should be established for workers that ensures confidentiality, freedom from reprisal and a pathway to resolution. 

  • Discipline
  • Physical abuse or discipline, the threat of physical abuse, sexual or other

    harassment and verbal abuse or other forms of intimidation is prohibited. All

    disciplinary and performance management measures must be recorded.

  • Environment
  • Suppliers must comply with local environmental protection laws and regulations.

    Suppliers must maintain an environmental policy and management plan sufficient to control and minimize all Environmental Hazards, Wastes or Pollutants unique to the factory. 

    Suppliers need to ensure they are using chemicals in compliance with the standards set out by the Restricted Substance List. The Restricted Substance List (RSL) defines the permitted levels of chemical content and chemical exposure for final products being produced by a company. 

    Suppliers must have a water use and a wastewater plan to minimize water usage and water wastage. 

  • Subcontracting
  • All subcontracted production or processing must be disclosed and authorized.

    Facilities engaged by the supplier / factory for subsidiary processing must be disclosed at the time of factory registration. Subsidiary processing facilities may be inspected at any time at the discretion of Shine on. Shine On must be notified in writing of any changes to the approved subcontractors. 

  • Raw Materials Traceability
  • Suppliers should be able to trace the origin of all their primary materials and components and provide this disclosure to Shine On upon request. It is the responsibility of the supplier to ensure that the sources of their raw materials also comply with this policy in all areas including staff management and environmental damage.

  •  Air Polution Control 
  • Suppliers must comply with all relevant Air pollution control Acts and legal obligations as set out in their local laws and regulations.  Facilities should be monitored for any air pollution exposure risks to its employees and contractors.

  • Lighting
  •             Suppliers must provide adequate Lighting for employees to carry out their duties as per 

                Local authority standards.   


    1. Compliance with this Policy

    It is a supplier’s responsibility to ensure compliance with this Policy, and maintain

    adequate records of all aspects of the ethical standards set out in this Policy.

    Shine On’s employees, agents or representatives may visit supplier’s factories or facilities to audit a supplier’s compliance with this Policy.

    Non-compliance with this Policy will require the supplier to undertake corrective action,

    the extent of which will be dependent upon the nature of the breach. Shine On may

    terminate the business relationship where deemed appropriate if corrective action is not taken.

    1. Our commitment to responsible sourcing

    Shine On recognises the reciprocal part we must play to ensure suppliers can meet the expectations laid out in our Policies and Terms of Trade. Our sourcing practices and behaviours must not jeopardise our suppliers’ responsibilities to their workforce under local law and our Ethical Sourcing Policy.

    We provide clear purchasing plans that will provide suppliers with the clarity needed to match their production capacity to our final inspection and shipping deadlines. These plans are delivered at an agreed interval before production commences.

    Product changes made after order confirmation, will not result in penalties to the vendor, who may make proportionate adjustments to the original delivery times, especially if it were to have negative impacts on working hours or access to rest days. Other order changes post order confirmation are likewise done by agreement with supplier.

    Any questions in regards to this Policy please contact  Managing Director:

    The above expectations are a minimum but we would also encourage you to discuss with your suppliers that the company they are manufacturing for i.e. Shine On believes strongly that a successful business is created by treating its workers well and with genuine concern for their wellbeing. We would welcome any stories about positive changes or initiatives in your suppliers to be added to your company information section on our website which you can draw the factory owners  attention to, thus creating a cycle of positive reinforcement.