Monica Vinader Human Rights Policy

Last updated on August 9, 2024 at 4:35 PM

1. Introduction:

Monica Vinader Ltd. (“MV”) is committed to respecting the internationally recognised Human Rights of all stakeholders, including but not limited to employees, supply chain workers, our communities, and consumers directly and indirectly affected by our operations. MV does this by ensuring that Human Rights are upheld across our operations, our supply chain, and in our business relationships.

2. Scope

This Policy applies to everyone working for MV worldwide regardless of location, role or level of seniority. This includes all employees, Managers, Executive Leadership Team Members, and Directors of MV.

MV requires that temporary and contract employees, consultants, agents and any other third party which acts in the Company’s name, comply with the principles of the Policy.

MV expects its supply chain to meet the human rights standards set out in this policy.

3. Legislation and Guidelines

MV is a signatory of the United Nations Global Compact and is committed to respecting Human Rights in line with UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises.

In the UK, Human Rights are enshrined in the Human Rights Act 1998, which incorporates the rights established under the European Convention of Human Rights. MV is committed to complying with this act.

In the USA, Human Rights are protected by the Constitution of the United States and its amendments as well as in the state legislature.

In New York, the New York State Legislature has passed numerous statutes and the New York Court of Appeals has issued rulings that protect human rights, such as the right to vote, the right to privacy, the right to a safe and healthy workplace, the right to be free from discrimination and excessive force, and the right to be free from cruel and unusual punishment. The New York State Division of Human Rights works to ensure that all persons in New York are provided equal protection of the laws and are protected from discrimination.
In California, the California state legislature has passed numerous statutes and the California Supreme Court has issued rulings that protect a range of human rights, such as rights to fair employment and housing practices; rights to free expression and the press; and rights to vote, assemble, and seek redress of grievances.
In Illinois, the Illinois Human Rights Act prohibits discrimination on the basis of race, colour, religion, national origin, ancestry, age, sex, marital status, order of protection status, disability, military status, sexual orientation, and unfavourable discharge from military service. Also, the Illinois Supreme Court has issued rulings that recognize a range of other human rights, such as rights to free expression and the press, freedom from discrimination and excessive force, and the right to a safe and healthy workplace.
In Texas, statutes and case law protect other human rights, such as freedom from discrimination, freedom from excessive force, the right to a safe and healthy workplace, and the right to be free from cruel and unusual punishment.
In Washington, the Washington State Legislature has passed numerous statutes and the Washington Supreme Court has issued rulings that protect a range of human rights, such as the right to free expression and the press; the right to vote and assemble; the right to a safe and healthy workplace; the right to be free from discrimination on the basis of gender identity, sexual orientation, familial status; disability; race; creed; colour; national origin; honourably discharged veteran or military status; sex; age; and marital status. The Washington State Human Rights Commission also investigates and enforces state statutes regarding discrimination and other civil rights violations.

In Hong Kong, Human Rights are protected by the Basic Law of the Hong Kong Special Administrative Region of the People’s Republic of China and its Bill of Rights Ordinance (Cap.383), and the International Covenant on Civil and Political Rights (“ICCPR”).

South Korea’s Constitution provides robust protection for basic human rights.

In Singapore Human Rights are codified in the Constitution of Singapore, however they do not tend to meet the same standards as the UK, the USA or the UN. MV is committed to meeting the same human rights standards in Singapore as we do across the other jurisdictions in which we operate.

In Canada Human Rights are protected under a number of acts. Canada is a signatory to the Universal Declaration of Human Rights, the International Covenant on Civil and Political Rights (ICCPR), the International Covenant on Economic, Social, and Cultural Rights (ICESCR), and the Convention on the Elimination of All Forms of Discrimination against Women (CEDAW). Human Rights are also protected under the Charter of Rights and Freedoms.

Ontario protects human rights under the Ontario Human Rights Code, which prohibits discrimination on the basis of race, ancestry, place of origin, colour, ethnic origin, citizenship, creed, sex, sexual orientation, gender identity, gender expression, age, marital status, family status or disability, in employment and in areas like housing, services and contracts.

4. Our Commitments:

MV is committed to the following:

To provide a secure working environment free from unlawful discrimination and harassment.
To comply with all applicable recognised human rights and relevant laws in countries where we or our business partners operate our business.
To honour the principles of internationally recognised human rights when faced with conflicting requirements.
To treat human rights as a legal compliance issue.
To identify, prevent and mitigate possible human rights risks and commit to undertaking appropriate due diligence to evaluate and ensure implementation.
To consult with any employee or third party who may be affected, in a manner that ensures free and informed participation taking into account language and any other potential barriers to effective engagement.
To ensure compliance through all supply chains.
To provide a transparent, fair and equitable grievance procedure which can be used for the remediation of any adverse human rights issues.
To be transparent about policies, activities and impacts, and report on human rights risks and issues where necessary.

Additionally, we aim to:

Avoid adverse human rights impacts resulting from our business by respecting the rights enshrined in the International Bill of Human Rights (Universal Declaration of Human Rights, the International Covenant on Civil and Political Rights, and the ICCPR) and the International Labour Organisation (ILO) Declaration on Fundamental Principles and Rights at Work;
Protect individuals and/or groups who are vulnerable to the adverse impacts of our direct and indirect operations on the basis of their age, disability, ethnicity, gender, gender identity, indigenous identity, marital status, migrant status, linguistic group, nationality, sexual orientation, religion and other characteristics as protected by international instruments and national laws; and
Promote positive human rights impacts by adhering and supporting the delivery of the UN Sustainable Development Goals.

5. The Fundamental Principles of this Policy:

5.1 Respect for Human Rights

MV respects and protects recognised human rights of our employees and those connected with all of our business activities, and commits to not acting in a manner that would jeopardise those rights.

5.2 Valuing Diversity

MV values the diversity of all employees and is committed to protecting our employees’ right to work in an environment where the working conditions and practices will not infringe on the employee’s physical, sexual, racial, religious and psychological rights; and will be free from any other form of harassment, threat or abuse.

MV’s diversity committee, WeBelong, is responsible for promoting diversity in the workplace, and MV’s People and Culture Team is responsible for ensuring that hiring practices are not discriminatory.

5.3 Freedom of Association

Employees will be free to form associations for the protection of their interests and to bargain collectively without fear of reprisal, intimidation or harassment.

5.4 Safe, secure and healthy workplace

Monica Vinader is committed to providing a safe, secure and healthy workplace. MV is committed to the health and safety of its employees, and the full extent of our health and safety efforts can be found in the Health and Safety Policy available in Bob, or you may contact our Health and Safety Advisor.

MV promotes positive mental health, and our mental health committee, the Feel Good Group, is responsible for these efforts.

5.5 Forced labour and human trafficking

MV prohibits any form of forced labour and human trafficking throughout its operations, including in its supply chain or any other related business partner.

MV reserves the right to terminate any business relationship if human trafficking is to be found in the business partners operations.

5.6 Child labour

Monica Vinader will not employ children under the age of 16 years old, however they may be offered the opportunity for work experience with the company under strict supervision.

No employee under the age of 18 will be:

tasked with work that they are physically and/or mentally capable of doing;
tasked with work which brings them into contact with chemical agents, toxic materials or any situation that can be classed as hazardous to their health including radiation; and
tasked with work which involves a health risk because of extreme cold, heat or vibration.
Monica Vinader will request proof of identity from all employees upon recruitment to establish the age of any employee ahead of their employment commencing.

MV’s prohibition of child labour is consistent with International Labour Organization standards (“ILO”).

MV reserves the right to terminate any business relationship if child labour inconsistent with the ILO standards is to be found in the business partners operations.

5.7 Work hours, wages and benefits

Monica Vinader operates in full compliance of laws applicable to wage, work hours and benefits.

All employees will earn equal pay for equal level and value of work.

5.8 Non-Discrimination

Monica Vinader is an equal opportunities employer.

All employees are treated equally and there will be no discrimination based on age, race, gender, political opinion, social origin, marital status, disability, sexual orientation, religious belief or lack of belief (“Protected Characteristic”) and any other characteristic protected by law, such as as some offending backgrounds (see section 5.9).

Discrimination occurs where a person is treated unfairly because of one, or more, of the Protected Characteristics. Discrimination can take many forms, including but not limited to direct or indirect discrimination, both of which are unlawful.

All employees have a personal responsibility to behave in a non-discriminatory manner at all times, including when outside of the workplace. Any allegation of discrimination by an employee or by MV as a company will be treated as serious and investigated in accordance with the Disciplinary Policy.

5.9 Recruitment of Ex-Offenders (UK)

MV complies fully with the code of practice published under section 22 of the Police Act 1997, which advises businesses on the recruitment of individuals who have a criminal record.

MV undertakes not to discriminate unfairly against any subject of a criminal record check on the basis of a conviction or other information revealed. MV does this by actively promoting equality of opportunity for all with the right mix of talent, skills and potential and welcomes applications from a wide range of candidates, including those with criminal records. MV selects all candidates for interviews based on their skills, qualifications and experience.

MV can only ask an individual about convictions and cautions that are not protected under the Rehabilitation of Offenders Act 1974 (Exceptions) Order 1975. MV may use criminal record checks processed through the Disclosure and Barring Service (DBS) where appropriate, and is committed to treating all applicants fairly.

An application for a criminal record check is only submitted to DBS if one is both proportionate and relevant to the position concerned. For those positions where a criminal record check is identified as necessary, all application forms, job adverts and recruitment briefs will contain a statement that an application for a DBS certificate will be submitted in the event of the individual being offered the position.

The roles that MV has determined require a criminal record check are those positions at C-suite level, or those in the finance team.

During screening, MV ensures that an open and measured discussion takes place on the subject of any offences or other matters that might be relevant to the position. Failure to reveal information that is directly relevant to the position sought could lead to withdrawal of an offer of employment. MVs pre-employment screening is conducted by a third party, Agenda.

MV makes every subject of a criminal record check submitted to DBS aware of the existence of the code of practice and makes a copy available on request.

MV undertakes to discuss any matter revealed on a DBS certificate with the individual seeking the position before withdrawing a conditional offer of employment.

This document can be made available on request to all applicants at any point in the recruitment process.

5.10 Harassment

Harassment is unwanted conduct, aggressive pressure, intimidation, or other conduct related to one or more Protected Characteristics, which has the purpose or effect of violating the dignity of individuals at work creating an intimidating, hostile, degrading, humiliating or offensive working environment.

Sexual harassment is unwanted conducted of a sexual nature.

Harassment can take many forms including but not limited to verbal, non-verbal or physical.

MV is committed to providing a secure working environment free from harassment, where the dignity of individuals is respected.

All employees have a personal responsibility to behave in an appropriate manner at all times, including when outside of the workplace. The company will take action against any employee who brings the company’s reputation into disrepute.

Any allegation of harassment will be treated as serious and investigated in accordance with the Disciplinary Policy.

6. Human Rights Due Diligence

6.1 Human Rights Risk

MV conducts ongoing due diligence across our business, supply chain, and business relationships, which includes regular audits, reviews of suppliers code’s of conduct, and our policies.

We regularly conduct human rights impact assessments to improve our understanding of our human rights risks and the effectiveness of our existing policies and processes.

7 . Tolerance Standard

If Monica Vinader becomes aware of any violations of this policy by a supplier or any business partner, the business relationship will be terminated immediately. If we have reason to believe the supplier or business partner was aware of the violation and willingly operated in violation of fundamental human rights, the supplier or business partner will be reported to the proper authorities.

8. Responsibilities


Board of Directors / C-suite	Have overall responsibility and accountability in; ensuring the implementation of the human rights policy. Review human rights performance regularly in board meetings; Promote and champion human rights commitments; and Ensure adequate resources are available to meet the human rights commitments.
Sustainability, Supplier and Risk Teams	Holds responsibility in implementing the Human Rights and Equal Opportunity Policy; Reports to the c-suite on human rights performance and guidance for continuous improvement; Ensure human rights recommendations from audits, employee engagement, supplier engagement, and any other channels are incorporated in improving existing policies and practices; Provides technical advice and guidance to other business functions; Acts as the liaison with external stakeholders on human rights issues; Monitors and reports on human rights performance in MVs direct and indirect operations; Liaises across different business functions to ensure the implementation of this policy; Conducts and reports on the human rights impact assessment and provides annual updates; Engages with suppliers on this policy (e.g. pre-contractual screening); and Trains internal and external stakeholders on this policy as relevant to their roles.
People and Culture Team	Maintain a high level understanding of this policy; and Ensure that human rights risks are incorporated in the pre- and post- contractual screening of candidates.
All other employees	To respect human rights in all parts of their daily role; and To immediately report any human rights risk or issue they are aware of to their manager, or via EthicsPoint.

9. Stakeholder Engagement

MV engages and consults internal and external stakeholders on our human rights risks and impacts in addition to our human rights performance. We work with our internal and external stakeholders (e.g. suppliers, consultants) to advance our human rights commitments.

Where its operations affect local communities, MV seeks to engage with community stakeholders to identify, mitigate and remediate adverse human rights risks.

10. How to raise a concern:

MV wishes to encourage open and honest communication amongst employees. If employees are aware of a human rights issue, or the risk of a human rights issue occurring, they must immediately report this via EthicsPoint, MVs grievance and whistleblowing reporting service.

These reports can be made anonymously or not, directly to MV or to our account manager, and either written or via phone call. If made to MV, the report will be received by the Director of People & Culture, the Group Risk Manager, or the Sustainability Manager, depending on the content of the report.

The full details of how to make a report can be found in the Whistleblowing Policy. The link to the whistleblowing hotline can be found below:

Whistleblowing Hotline

11. Remediation

If MV finds that it has caused or contributed to negative human rights impacts, the OECD and UNGP expect it would engage actively in remediation. There is no one-size-fits-all approach to remediation as it should be tailored to the offence or impact, but MV commits to supplying the appropriate resources and capabilities to carry out the remediation if required.

For example, MV may work with suppliers or local community groups to address the issues identified in an appropriate do-no-harm manner.

12. Governance and Review

While the Group Risk Manager is responsible for advising and guiding MV in upholding its human rights commitments, promoting and respecting human rights is the responsibility of all operational functions at MV. The c-suite holds accountability for the delivery of MVs human rights commitments.

This policy is owned by the Group Risk Manager and is reviewed annually. Each new version must be approved by the c-suite.