Child labour

Employment of children in any form is strictly prohibited. Suppliers must engage workers whose age should not be below the age for finishing compulsory schooling, and in any case not less than 15 years or of the legal minimum age for working in any specific country, whichever is greater. Further, workers below 18 years of age may not be employed in hazardous conditions or at night. The Supplier shall comply with all applicable local laws relating to employment of minors, including employment contracts, access to education, wages, working hours, overtime and working conditions. No children are allowed in the production area, even if they are not working.

Forced labour

All forms of forced, indentured and bonded labour are prohibited, including all forms of modern slavery and including compulsory overtime. The employer must cover any commissions and other fees in connection with recruitment employment. Workers passports or identity documents should never be retained by the employer, and withholding of bonds or deposits is not allowed. Workers must be able to voluntarily end their employment without any restrictions. Any restrictions on employees to voluntarily end their employment, such as excessive notice periods or substantial fines for terminating their employment contracts are prohibited. We do not accept the use of prison labour or illegal labour in the production of goods or services for GFG. Workers must have free access to toilets, water and breaks without any disadvantage, disciplinary action, discrimination or termination.

Harassment and abuse

Employees must be treated with respect and dignity and may not be subject to any form of physical abuse or discipline, corporal punishment, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation. Employees must be able to express criticism and concerns about conditions in the workplace to their supervisor or to management without fear of retribution, loss of employment or other reprisals.


All Employees must be treated equally and without discrimination. Employees must not be subjected to discrimination in employment, including recruitment, hiring, training, working conditions, job assignments, compensation, promotion or discipline, termination and retirement on the basis of gender, race, religion, caste, age, social background, diseases, disability, sexual orientation, pregnancy, marital status, nationality, political opinion, trade union affiliation, social or ethnic origin or other status protected by law. Effective measures are to be taken against the exploitation of migrant workers to protect them from all forms of discrimination and to offer them an appropriate support adequate to their special status. Migrant workers shall have exactly the same entitlements as local employees and be employed in line with the GFG’s Policy on the Responsible Recruitment and Employment for Migrant Workers, Agency Workers and Temporary Staff.

Freedom of association and collective bargaining

The rights of employees to lawfully associate or not to associate with groups of their choosing shall be respected, as per applicable laws, and without interference from management. The right of employees to engage in collective bargaining as permissible by law shall also be recognised.

Regular employment

To every extent possible work performed should be on the basis of a recognised stable employment relationship established through national law and practice. The Supplier shall not avoid obligations to employees under labour or social security laws and regulations arising from the regular employment relationship. Workers employed through an agent or contractors are the responsibility of the Supplier, and are thus covered by this CoC.

Migrant Workers

Migrant workers shall have exactly the same entitlements as local employees. The employer must cover any commissions and other fees in connection with employment of migrant workers. The employer must not require the employee to submit his/her identification documents. The withholding of bonds or deposits is not allowed. Workers employed through an agent or contractors are the responsibility of the Business Partner, and are thus covered by this CoC.

Wages and benefits

All employees must be paid in a timely manner and provided with a written statement they are able to understand. Wages paid to workers should be sufficient to cover for their basic needs and allow for some discretionary income. At a minimum, workers should be paid at a rate not less than the minimum wage as required by the industry standard or by local laws, whichever is higher. Employees must also be provided with legally mandated benefits, including holidays, leaves, and statutory compensations at the time of ending employment. There may not be any disciplinary deductions from their pay.

Working hours

Working hours, excluding overtime, shall be defined by contract, and shall not exceed 48 hours per week or as per legal requirements, whichever is lower. The duration of working hours including overtime shall not, on a regular basis, exceed 60 hours per week or as per legal requirements, whichever is lower. Suppliers must comply with applicable laws governing regular working hours and overtime hours. All overtime hours are voluntary and must be compensated at premium rate of no less than 125% of the regular pay rate, or as per legal requirements, whichever is higher. Employees must be provided with at least 24 consecutive hours of rest in every 7 days period, and must also be granted paid annual leave as per local employment regulations.

Housing facilities

Suppliers shall comply with relevant legal requirements for housing facilities. No restrictions shall be applied which interfere with the workers’ right to leave the housing facility during their free time. Separate toilets shall be available for men and women. Suppliers shall also ensure reasonable living space, cleanliness, privacy, quietness, safety, personal hygiene and access to drinking water. The infrastructure of the buildings shall ensure the personal safety of the Employees. Dormitories must be clearly separated from the production facility and/or warehouse.


Health and safety

Employees must be provided with a safe, healthy, hygienic and hazard free work environment that does not pose any risk to Employees’ health or life. Suppliers shall take steps to prevent accidents, injury and disease in the workplace by minimizing the cause of hazards. Employees must be provided with adequate safety training and equipment when handling hazardous material or working with dangerous tools. All production facilities must have trained personnel on first aid and be equipped with appropriately stocked first aid kits.

Fire, electrical and structural safety

All Suppliers must comply with local laws and regulations related to fire protection, electrical and structural safety at their offices and production facilities. Employees must be trained about physical safety, emergency evacuation and other basic training to cope with fire or structural hazards. Emergency exits must be unlocked during working hours, aisles and exits must be kept clear, and exits and evacuation routes must be sufficient to allow workers to exit safely. Employees must be allowed to raise concerns regarding unsafe working conditions to their supervisors or to management without fear of reprisals or disciplinary actions. Supplier must ensure that railings guard all stairs, platforms, and elevated floors.

Certification and record keeping

Suppliers shall obtain certification from relevant local authorities for all production or other facilities. A log of incidents and corrective action plans along with an updated status shall be maintained at all production facilities. Regular inspection records for potentially dangerous equipment, such as boilers, generator, pressure / LPG tank, must be kept accessible and up to date.


Environmental standards

Suppliers must undertake reasonable measures to avoid any adverse impact on human health and/or the environment by avoiding or minimising pollution from manufacturing activities, and promoting sustainable use of such resources as energy and water. All required environmental permits and licenses must be kept up to date.

Severe pollution

Suppliers shall manage all waste in a way that minimizes contamination of the environment, promoting programs to minimize the generation of waste, increasing recycling or reuse and disposing properly all wastes. Suppliers must keep up to date original copies of all relevant environmental permits and licenses for its operations. Suppliers shall ensure that all measures are taken to avoid severe pollution to the environment as a consequence of their business operations or that of their subcontractors.

Banned substances

Suppliers shall implement necessary controls to ensure that hazardous materials and substances that are banned by international organisations/regulation (e.g. European Union) are not be used in the manufacturing process.

Water Management and Wastewater Treatment

Water should be used as efficiently as possible. Suppliers shall ensure all outgoing wastewater from wet processes must be treated before it is discharged. The treated wastewater quality must meet the requirements set in local legislation, or the parameters found in BSR’s wastewater quality guidelines, whichever is stricter.


Local laws and regulation

Suppliers and their subcontractors shall comply with all local and national laws and regulations of the jurisdictions in which the suppliers are doing business as well as the practices of their industry. Suppliers and their subcontractors shall further work with suppliers who are committed to meeting required standards as per local and national laws.

Anti-Corruption and Anti-Bribery

Suppliers confirm that they comply with local, national and international regulations related to anti-corruption. Suppliers do not tolerate or participate in any form of corruption, whether it is bribery or accepting or granting advantages or benefits. The same applies for other forms of influence such as fraud, extortion, embezzlement or similar acts. Appropriate internal regulations are implemented across Suppliers to uncover relevant influences and to prevent them. In addition, Suppliers are obliged to report any act or suspicion of corruption.


Suppliers agree that representatives of GFG, its subsidiaries or an organisation nominated by GFG or its subsidiaries agent can inspect their or their subcontractors’ production facilities to implement and monitor standards specified in this Code of Conduct. Such inspections may, at GFG’s discretion, take place on an unannounced basis whereby the inspectors are granted immediate access to the facilities and related records. Trust and transparency are fundamental requirements in any supply relationship with GFG. Suppliers are required to be transparent during these inspections by informing GFG of all practices related to production (facilities locations, use of subcontractors, third parties and homeworkers, etc.) and providing accurate and truthful information and documentation.


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