Swan Mill Group Ethical & Environmental Policy

The Swan Mill Group of companies encompasses the following:

Swan Mill Paper Company: Established in 1892 and has grown to be a large and diversified business based around the core principles of disposables, ink on paper and party with a particular specialism in all things Christmas.

Ling Design: One of the UK’s longest established publishers of premium greetings cards with a heritage that stretches back to the 1950s; supplying hundreds of retailers and charities throughout the UK and also to customers in 27 countries around the world.

The Great British Card Company: The Great British Card Company (GBCC) is one of the UK’s largest independent card publishers and card broker supplying customers including large UK supermarkets, high street specialists, garden centres and post offices both in the UK and via distributors overseas. Publishing and selling 20 million cards across every day and seasonal plus also now specialising in stationery lines.

Castleview Enterprises: A long established, market leading supplier of housewares, catering and retail disposables. Branded products provide exceptional quality and value and are widely used in households and businesses across the UK.

The Swan Mill Group recognises the impact its commercial activities can have on both the environment and people in its global supply chains and operations.  The Swan Mill Group is committed to taking responsibility for labour and environmental standards in its operations and supply chains.

This policy has been reviewed and endorsed by senior management.  Where policies and processes have been updated the management team commit to incorporate those changes, to publish and communicate them to customers and suppliers and, to consider this policy in future decisions on our business practises.

Scope of this policy

As part of our commitment to ethically and environmentally sound trade, we work with suppliers whose values align with ours.

This policy covers all businesses within the Swan Mill Group as set out above. Due to the varied nature of our supply chains, in the first instance we are focussing on suppliers to the Swan Mill Group who are directly involved in the manufacturing and production of “print on paper” products that are sold to consumers in a retail setting.

As we improve our knowledge and understanding of ethical and environmental issues and how to manage risk in our varied supply chains we will develop the scope of this policy and our minimum standards.    Our minimum standards for suppliers are contained in an Appendix to enable us to update as we progress.  Please see “Appendix (A) – Minimum Standards for suppliers”.

Beyond Audit/ Human Rights Due Diligence

While recognised third party ethical audits form part of our minimum standards, we understand that a compliance and audit-based approach has failed to identify, prevent or compensate for labour rights abuses in all cases.

At sites that are audited, issues continue to recur relating to working hours. Some workers choose to work overtime in order to increase their income.  

What is important is that:

• they have the right to choose whether to work overtime without fear of reprisal
• that those hours are not excessive
• that they are rewarded with a premium rate
• that they are not working overtime because what they earn in standard hours is less than they need to meet their basic needs

At Swan Mill we understand and accept our corporate responsibility to respect human rights as defined in the UN Guiding Principles on Business and Human Rights, a set of guidelines for preventing and addressing the risk of adverse human rights impacts linked to business activity.

For more information on the UNGP can be found at:

https://unglobalcompact.org/what-is-gc/mission/principles

We are engaging in the process of Human Rights Due Diligence, by taking the below key steps to prevent, manage and mitigate human rights abuse in our supply chain:

• Investigate/Assess (through robust risk assessment of countries, sectors and businesses the actual and potential human rights impact)
• Identify (leverage, responsibility & actions)
• Mitigate (risk and provide remedy for workers)
• Monitor Report/Review and improve

Senior Management/ Responsibility for beyond audit work/ broader policy

Swan Mill have defined the working group who will develop their human rights expertise, and senior management have given their support to the individuals with enough capacity to learn about the area of human rights due diligence and lead the implementation of this work. Company senior management proactively supports this work, and will track the links between core business decisions, risk management and gendered human rights impacts.

Labour Standards

As a supplier, manufacturer, and buyer we are committed to striving to meet the labour rights as detailed below or national laws; whichever affords the greater protection for workers. 

• Never using forced, bonded or involuntary prison labour or requiring workers to lodge deposits or identity papers. Allowing workers to leave freely after providing reasonable notice.
• Allowing women and men workers to join or form trade unions or other independent workers’ organisations of their own choosing and to bargain collectively. Not discriminating against workers’ representatives and enabling them to function in the workplace.
• Providing a safe and hygienic working environment; regular Health & Safety training; access to potable water, clean, safe and separate accommodation and toilets for women and men.
• Not recruiting children or employing under 18-year olds at night or in hazardous conditions.
• Paying women and men equal wages for equal work for a standard working week; wages that are enough to meet basic needs and provide discretionary income. Not making unfair deductions from pay.
• Ensuring that weekly working hours do not exceed 48 hours standard or 60 hours including overtime (that will not occur on a long term basis).
• Not discriminating against women or men workers on the basis of gender, race, caste, national origin, religion, age, disability, marital status, sexual orientation, union membership, political affiliation, medical condition etc.
• Providing regular employment and not avoiding obligations to employees through sub-contracting, home-working, apprenticeships or use of revolving short term contracts.

Buyer & Supplier Commitment:

Across the Swan Mill group, we deeply value our long-standing relationships with our manufacturing partners. We understand that building two-way communication is vital to overcoming conflicting messages and improve labour conditions. We appreciate our partner’s unique insights and see the manufacturers that we have partnered with as an extension of our UK based operations.

As a summary, we, as a supplier, commit to and expect all our third party suppliers who meet the definition in the main body of this policy to commit to the following:

• Complying with the minimum standards to trade, as defined in Appendix A.
• Complying with labour standards, as defined above.
• Operating within the laws relating to women and men workers and their working conditions and not engaging in corruption at any level.
• Treating women and men workers equally and with respect and consideration, upholding their dignity.
• Providing clear, understandable written information to workers on their wages, working hours, benefits, terms of employment and their rights as workers.
• Minimising the impact of the production process on the environment and on the natural resources of marginalised people.
• Informing customers if their purchasing practices are undermining the supplier’s ability to uphold decent working conditions.

As a buyer, we commit to supporting our suppliers to meet the required labour rights standards:

• Continuously working to improve our policies and practice to enable our suppliers to be able to meet their commitments as outlined in this code of conduct.
• We recognise that our suppliers may not be able to achieve all the labour and environmental standards immediately. We are committed to working with suppliers towards conformance within a reasonable timeframe. We will however, terminate supplier relationships where serious breaches of labour and environmental standards persist after reasonable attempts have been made to work with the supplier to implement improvements, and where there is no reasonable prospect of securing improvements. Such terminations will be carried out in a responsible way.
• Communicating clearly, promptly and accurately on all issues concerning orders. Ensuring that our requirements are adequately defined and specified in sufficient time to allow the suppliers to react to our requirements.
• Treating suppliers with respect and consideration in all our dealings and communications.
• Communicating clearly, promptly and accurately on all issues concerning orders.
• Never knowingly negotiating a price that is below the cost of production, as this will impact on the wages and working conditions of workers.
• Staying with our current supplier if a higher price will ensure decent wages and working conditions for workers, rather than moving our business elsewhere purely on the basis of price.
• Placing orders with lead times that do not trigger excessive working hours or sub-contracting.
• Refraining from changing orders repeatedly and with short notice. If changes are unavoidable, amending target delivery times accordingly.
• Providing material and practical support to our suppliers in striving to meet their obligations under this code of conduct.
• Sharing the cost of implementing and monitoring improvements in working conditions.
• Taking pay and working conditions of workers into consideration when reviewing our business relationship, rather than ending a business relationship purely on the grounds of price or quality.

Environmental

Across the Swan Mill Group we are continuously seeking to improve our business practices to minimise the environmental impact of our products and operations:

• Working with our suppliers to ensure that every card and paper product can be traced back to sustainably managed forests.
• Investing in technology to drive sustainability through our operations and manufacturing as we work towards reducing our carbon footprint by minimising our energy consumption:
  • Motion sensor technology
  • Rechargeable battery driven energy efficient warehouse machinery
• Conserving resources – striving to use materials and resources efficiently, as we work towards sending zero operational waste to landfill.
  • Treatment plant to remove ink residue in wastewater allowing it to be reintroduced to the environment
  • Integrated confetti cutter at our wrap facility to capture 100% of paper edge trims allowing it to be recycled
• Developing new finishes, using recyclable materials that allow the whole product to be recycled and/ or reused:
  • Paper engineering and die cutting
  • Paper based or reusable cracker content
  • Hand applied developments including:
    • Card attachments with water based glue
    • Reusable attachments such as book marks, and gift tags
  • Optimising packaging to minimise material use and/or make reusable:
    • Reducing impact by developing new solutions and prioritising sustainable materials
    • Developing packaging that can be reused one or multiple times before recycling
  • Promoting recycling
    • Clear communication of product recyclability for our retail customers and end customers on product and packaging
  • Encouraging reuse – innovative product and packaging design solutions to develop products that can be reused one or multiple times before recycling.

Appendix A – Minimum Standards for Suppliers

As a summary we expect the following from all suppliers who meet the definition on page 2 of the main body of this policy to comply with the following:

• Complete a Swan Mill supplier questionnaire.
• Have been visited by a member of the Swan Mill team
• Comply with ETI Base Code/ Code of Conduct
• Comply with both the letter and the spirit of the law, of the countries in which they operate
• Have an up to date SMETA Pillar 2 or BSCI audit
• Sign up to Swan Mill Groups Ethical and Environmental Policy (this document)
• Has a form of collective worker representation which is completely independent of the management
• Has grievance process in place and able to demonstrate that this is being used to address worker concerns
• Be able to provide an environmental statement or policy
• Be able to provide an anti-discrimination statements or policy
• Be able to provide a child labour statements or policy including forced labour.
• Where the supplier produces or distributes paper or wood products, those products are FSC accredited or equivalent thereof
• Provide a Modern Slavery statement (for UK based suppliers only and in compliance with UK law)