Code of Conduct

Contents

  • Our Brand

  • Our Approach to Social Compliance

  • Code of Conduct Development

  • Who is the Code of Conduct for?

  • Management Systems

  • Validity

  • Laws

  • Zero Tolerance List

  • Expectations of our Suppliers

  • Monitoring

  • Failure to comply

  • Commitment

Code of Conduct

Our Brand

Pas Normal Studios is a Copenhagen-based brand of contemporary, technical cycling clothing. The concept of Pas Normal Studios is to create technically perfect apparel, combined with visionary aesthetics. Through innovative designs, brand collaborations, and sourcing of new production methods, Pas Normal Studios strives to bring out collections that define modern cycling in a different context.

Our Values

As with any club it is all about coming together and sharing a passion. In this case our relentless desire to ride bikes. Our club is about being out on the road, exploring with friends, both old and new. What started as a local Copenhagen phenomenon has now evolved into international group rides across six continents.

Our mission is to provide high-end technically perfect cycling apparel, combined with visionary aesthetics through honest, fair and transparent business.

Cycling has the potential to create lasting and meaningful positive change for communities and the environment. We have a responsibility to promote this sport in the best way possible by pushing the boundaries and making the right choices. Our aim is to become an industry leader in sustainable practices and reporting. We want to ensure that everyone involved with Pas Normal Studios is safe, healthy, and working in a responsible way.

Our Approach to Social Compliance

Our Code of Conduct (‘Code’) is an outline of the expectations we hold of our suppliers. As a brand we require our suppliers to follow all local laws and regulations. We build relationships with our suppliers through trust and communication. The Code is a way of ensuring that our suppliers know exactly what we ask for in a partnership.

We believe honest and responsible practices in sourcing our products and services are critical for the success of our company, to protect our brand and advance better social and environmental conditions in global supply chains. This means that all our products must be produced under humane and responsible conditions, and in respect of international social, environmental and ethical standards and laws. This commitment to responsibility has implications for how we source our products and therefore we believe in cooperation and dialogue with our suppliers on compliance with this Code.

Code of Conduct Development

The Code specifies the ethical requirements that suppliers to Pas Normal Studios must comply with. The provisions that follow are derived from international declarations, conventions and frameworks such as the Universal Declaration of Human Rights, the Core Conventions of the International Labour Organisation (ILO), the UN Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises, the UN Global Compact’s 10 Principles, and the United Nations Convention Against Corruption.

Who is the Code of Conduct for?

This Code is intended to apply to all entities engaged in a commercial relationship with Pas Normal Studios supplying finished goods and/or materials within the supply chain of our products.

These entities will hereafter be referred to as ‘suppliers’.

This Code applies to the primary supplier facility as well as:

  • subcontractors

  • home workers

  • employees employed directly and indirectly by our suppliers, including contractor, seasonal, temporary and part-time workers.

Management Systems

As a supplier of Pas Normal Studios, we expect a commitment by the supplier to the development of all aspects of the organisation including facilities, welfare and education. This is expected to be implemented through appropriate management systems that can support development and the implementation of this Code.

Validity

This Code has a two-year validity from the date of signature, after which we will request suppliers for a renewal of commitment. We reserve the right to update this Code and suppliers are bound by the latest version of this Code as found on our website.

Laws

Any supplier with a commercial relationship with Pas Normal Studios is obligated to ensure that the conditions of this Code are respected and applied in accordance with local laws and regulations.

Zero Tolerance List

The Code includes below a list of zero-tolerance issues. Revelation of these issues will result in immediate cancellation of all orders at the expense of the supplier, and immediate termination of any relationship and contracts.

Corruption or attempted bribery of Pas Normal Studios staff / auditor

Use of forced labour in any form

Use of prison labour

Use of child labour

Failure to pay minimum wage

Inhumane, harsh treatment and physical punishment

Lacking or inadequate fire- and emergency safety

Overall health and safety conditions leading to unacceptable risk to workers

Severe environmental negligence and pollution

Any evidence or suspicion of these such cases can be communicated to us via the email address: impact@pasnormalstudios.com

Expectations of our Suppliers

Community Engagement

We strongly encourage the development of community within our company. We expect our suppliers to encourage and foster a positive and inclusive community in the workplace. We also expect suppliers to encourage employees to become involved with charity commitments and initiatives.

Diversity & Inclusion

We endorse a diverse working environment in regards to skill, age, cultural heritage, nationality, sexuality, and gender. We praise all diversity and want to encourage it in every part of our business. We expect our suppliers to provide a working environment where all employees feel included and are respected, and to celebrate diversity.

Equal Employment Policy

We expect our suppliers to ensure that men and women receive the same pay for doing the same task.

Equal Pay

We expect our suppliers to comply with local laws and regulations relevant to wages, working hours and employee benefits. Suppliers should not defer, delay or withhold wages legally due to its employees. Overtime hours should be voluntary and fully compensated based on prior arrangement.

Discrimination

We endorse a working environment free from harassment, discrimination and victimisation. We believe in treating each individual equally before, during and after employment. No individual should be discriminated against due to gender, identity, appearance, race, religion, age or any other factors. We expect our suppliers to ensure that employees are not subject to any form of discrimination.

Harassment & Violence

We believe in a zero tolerance approach towards physical, harassment, sexual harassment, psychological harassment, violence, verbal abuse or bullying. We expect our suppliers to ensure employees are all treated with respect and dignity. Suppliers must ensure employees are not subject to, or threatened by abuse of any kind, violence or harassment.

Child Labour

We expect our suppliers to not employ; anyone under the legal minimum age of employment; under the minimum age for completing compulsory education in that country; anyone under the age of 18 for work which is likely to negatively impact their health, wellbeing, safety or morals.

Contracts & Terms of Employment

We expect our suppliers at a minimum that they are respecting and safeguarding their employees in line with national and international laws and regulations. Our suppliers must inform employees of the terms of employment in their own language regarding wages, hours and holidays. The working week of an employee must not exceed the local law of the country. All overtime must be consensual and compensation must be paid. Overtime must not be requested regularly by the employer.

Anti-bribery, Corruption & Presentation of False Information

We do not tolerate the making or receiving of corrupt payments or bribes in any form. We expect our supplier to ensure that all applicable anti-corruption laws, rules and regulations are followed. Suppliers must immediately inform Pas Normal Studios if they suspect bribery in any form.

Freedom of Association, Right to Presentation of False Information

We expect our suppliers to allow employees to join trade unions or other types of employee organisation. We expect suppliers to allow employees to engage in collective bargaining and retain the right to strike. We encourage communication between employees and their managers and representatives to resolve disputes and create a more positive and safe working environment for all.

Human Rights

We expect our suppliers to respect the rights of employees and comply with all human rights and relevant labour legislation and regulations.

Health & Safety

We expect our suppliers to provide a safe and healthy workplace for employees. This ensures the risk of accidents and injury is minimized. We expect suppliers to be proactive when dealing with issues regarding health and safety. As a minimum requirement all suppliers must abide by local laws and regulations regarding health and safety. We encourage suppliers to promote wellbeing, and to ensure employees have support available if they wish to use it.

Living Conditions/ Dormitories

We expect our suppliers providing housing to employees, to ensure the standard of the accommodation meets the employees needs, and are clean and safe.

Maternity Rights / Parental Leave

We expect suppliers at a minimum to comply with local laws regarding maternity, paternity, parental leave and special leave arrangements. We encourage suppliers to support employees with caring responsibilities and health requirements by offering flexible hours.

Forced or Bonded Labour

We expect our suppliers to not take part in forced or bonded labour. Human trafficking is prohibited. Suppliers must monitor any suppliers assisting the employment of employees, ensuring they are following all local laws, and not engaging in forced or bonded labour, or human trafficking. All employees must be free to leave their role with reasonable notice.

Notice Period, Dismissal & Disciplinary Action

We expect our suppliers respect the rights of employees to terminate their employment with reasonable notice. We believe all employees should receive all salary they are owed.

Overtime Pay

We expect our suppliers to compensate employees for any overtime worked. Overtime must be voluntary and not completed on a regular basis. Suppliers must ensure employees agree on the payment for overtime and must not be pressured or forced in to accepting terms.

Working Hours & Rest Breaks

We expect our suppliers to follow regular and overtime hours allowed by the law of the country of employment. We expect our suppliers to ensure employees work the hours agreed in advance. We expect our suppliers to ensure employees are able to take breaks during the working day, and have the right to discuss with their manager if they feel stressed, tired or overworked. We expect our suppliers ensure employees are paid annual leave.

Sub-contracting, Outsourcing & Homeworkers

We expect our suppliers to inform Pas Normal Studios of the use of sub-contractors before production has begun, and at the earliest date possible. Subcontracting is not permitted without permission from Pas Normal Studios: Any sub-contractor must meet the standards of all other suppliers used by Pas Normal Studios.

Wages & Financial Benefits (e.g. bonuses, insurance, social security, pensions)

We expect our suppliers to pay employees, at a minimum, the minimum legal wage for the country or region. We encourage suppliers to pay a living wage. We expect suppliers to ensure wages are paid at the date agreed, and in full. No deductions should be made for disciplinary measures, or for any measures not authorized. Suppliers must proactively work towards ensuring all workers are paid fairly and on time.

Animal Welfare

We believe that all animals should be treated fairly, and with the utmost care. We only work with suppliers of animal products when we can be sure they treat their animals well. We expect our suppliers to work progressively to improve the wellbeing of all animals involved in the activity of the business, by applying the most appropriate technologies and standards possible. Suppliers must adhere to local and international regulations regarding the treatment and use of animals and animal products.

Biodiversity & Conservation

We are committed to encouraging biodiversity and conservation. It is vital for the protection of our environment, and the maintenance of quality of life. We expect our suppliers to encourage biodiversity and conservation.

Restricted Substances List

We expect our suppliers to ensure all chemicals used in our products are in compliance with the EU’s Registration, Evaluation, Authorisation & restriction of Chemicals (REACH) regulation. We expect suppliers to immediately inform us if they identify any chemicals not compliant with this regulation. We will then work to replace the chemical with an alternative material or process.

Energy & Carbon Emissions

We endorse efforts to reduce the energy use and carbon footprint of our suppliers. This includes measuring impact and creating a strategy to improve practices. We expect our suppliers to promote initiatives to reduce energy use and emissions.

Waste & Recycling

We believe in working to reduce waste within our supply chain. We expect our suppliers to identify areas where our supply chain can reduce waste. We expect our suppliers to proactively encourage employees to reduce waste and increase recycling.

Water Effluents & Treatment

We expect our suppliers to ensure its operations do not negatively affect access to safe water for the community.

Water Usage & Footprint

We expect our suppliers to identify areas where our supply chain can reduce water use. We expect our suppliers to proactively encourage employees to reduce water use.

Monitoring

As a supplier of Pas Normal Studios, frequent communication and transparency are at the heart of our relationship. Communication regarding ethical and legal requirements is essential for the success of the relationship. Visits to facilities by representatives and staff of Pas Normal Studios will allow consistent updating and internal auditing to take place. Suppliers must also ensure access to facilities for external audits if requested.

Failure to comply

Our suppliers are crucial to the success of our organisation, and we trust them to operate in a responsible way. If a supplier is not aligned with our standards described in the Code, we will work with the supplier to ensure the standards are raised to at least those outlined in the Code. If the supplier can not operate in line with these standards then we will look to identify a new supplier.

This Code of Conduct has been approved and issued by the Pas Normal Studios.

Commitment

Please sign and return to your contact person at Pas Normal Studios.

• We hereby confirm that we have received, read and understood the Pas Normal Studios Supplier Code of Conduct and understand the importance of compliance to this Code by ourselves, our suppliers and subcontractors.

• We commit to adhere to all provisions in the Code of Conduct, and accept that Pas Normal Studios is entitled to cancel orders and terminate the business relationship in case of failure to comply.

• We also accept that Pas Normal Studios, and/or anyone representing Pas Normal Studios, is entitled to evaluate via questionnaires or on-site social audits all relevant facilities at any time, announced or unannounced, in order to monitor compliance with this Code.

• We confirm that we will promptly provide upon request the correct and true information and/or documentation regarding all products, manufacturing, assembly and storage sites.

• We understand that open and transparent communication on all issues related to the provisions of this Code is a requirement for doing business with Pas Normal Studios. We understand that falsification of records, factory names, and certifications may cause termination of the business relationship with Pas Normal Studios.

• We understand that the Pas Normal Studios’s Supplier Code of Conduct is available on the customer’s website and it is our responsibility to keep ourselves up to date with the latest version.

Name of Company ..........................................

Main Address ...................................................

Date and Place ................................................

Signature ...........................................................