Human Rights Policy
About this policy
This policy confirms our commitment to Human Rights and what we are doing to respect and protect the Human Rights of the people we employ, the people who work in our supply chains and the people who live in the wider communities in which we operate both nationally and internationally.
Responsibility for this policy
The management team have responsibility for this policy, and colleagues who have any queries relating to it, should contact their line manager.
Index
- Introduction
- Scope
- Our Purpose
- Key Points
4.1 Governance
4.2 Policies
4.3 How do we mitigate our risks
4.4 Communication and Training
4.5 Remedy
4.6 Accountability
- Introduction
Respect for Human Rights is an important value of Cole Fabrics. We believe that people are entitled to enjoy Human Rights, without discrimination, and should be treated with dignity. Human Rights are inherent in all human beings, whatever their nationality, place of residence, sex, national or ethnic origin, colour, religion, language, or any other status. We respect the rights of individuals belonging to groups or populations which maybe particularly vulnerable to adverse impacts, including women; national or ethnic, religious and linguistic minorities; children; LGBT+ community, indigenous people; people with disabilities and migrant workers and their families.
As a business, we are committed to protect and respect Human Rights of all individuals and remedy any areas for improvement should they occur, in line with the United Nations Guiding Principles (UNGP) on Business and Human Rights to international standards.
Corporate responsibility to respect human rights with the foundational principles outlined in the UNGP state that;
The responsibility of business enterprises to respect human rights applies to all enterprises regardless of their size, sector, operational context, ownership and structure. Nevertheless, the scale and complexity of the means through which enterprises meet that responsibility may vary according to these factors and with the severity of the enterprise’s adverse human rights impacts.
Cole Fabrics are a Small Medium Size Enterprise (SME) with around 65 employees. Our policies and procedures are in line with our size and our ability to influence our supply chain.
This policy confirms our commitment to Human Rights, and what we are doing to respect and protect the Human Rights of the people we employ, the people who work in our supply chains and the people who live in the wider communities in which we operate both nationally and internationally.
- Scope
This policy applies to all employees that are part of the Cole Fabrics Group.
Whilst not directly under the scope of this policy, we expect all our third-party partners (Customers, Distributors and/or Suppliers,) to maintain a similar position and approach to Human Rights as outlined within this policy.
- Our Purpose
Our Human Rights Policy supports the company mission of doing business in the right way:
- Our Customers by ensuring that we improve and innovate the best materials without compromising our integrity or the environment for the future;
- Our People by creating an inclusive culture, where people can reach their full potential, as well as attracting the very best talent and embracing diversity along the way;
- Our Community by creating economic activity, employment and supporting local charities.
- Our Planet by reducing our environmental footprint through our commitment to Net Zero and maintaining our high ethical standards across our supply chain.
We will work with our third-party partners/suppliers to address any breaches of Human Rights.
By continuing to enrich the lives of our consumers, our colleagues and our communities, as well as the planet we live on, we can grow our business effectively and sustainably.
Our core values underpin our culture and are imperative to the role colleagues play in ensuring that breaches of Human Rights do not take place at Cole Fabrics or with our third-party partners. It is our duty to create a safe place for colleagues to question and check if Cole Fabrics is complying with the principles of this policy, as well as questioning and checking with our third-party partners as to whether they have a current Human Rights Policy. We encourage our colleagues and third-party partners to speak up if they see something that causes concern.
4. Key Points
4.1 Governance
Cole Fabrics’ responsibility to respect Human Rights means we are committed to implementing the UN Guiding Principles on Business and Human Rights throughout our business.
The Human Rights Policy is overseen by our Operations Director and is approved by the Board of Directors.
Should we identify any potential Human Rights breaches due to our business activities, we are committed to ensuring we provide for, or co-operate in, their fair and equitable resolution. This also applies to any adverse impacts through our relationships with third parties. Should there be any areas identified that we need to improve, we will put in place an action plan to ensure we resolve any issues working closely with any external suppliers/third parties to rectify.
Our Human Rights approach requires compliance with all applicable local laws and regulations. As a business, we align to the Ethical Trading Initiative (ETI) Base Code, which is an internationally recognised code of labour practice that applies to our business and the supply chains we choose to use. Our respect for Human Rights is not limited to this code, as we are committed to tackling all forms of Human Rights breaches. We have policies in place to meet the ETI base code requirements and to identify risks across our supply chain.
4.2 Policies
Inclusion and Diversity
As a business, we believe in inclusion, authenticity, and individuality. Our culture is one where everyone is welcome. We are committed to equal opportunities for all and do not tolerate any form of discrimination and harassment. We maintain a safe working environment for all that are free from discrimination and harassment on the basis of race, sex, colour, national or social origin, ethnicity, religion, age, disability, sexual orientation, gender identification or expression, political opinion or any other status protected by applicable law. This is detailed in our Equal Opportunities Policy.
Security at Work
We are committed to promoting a harmonious working environment, free from harassment and bullying, where all colleagues should be treated, and treat others, with dignity and respect and can carry out their role without fear of being harassed, bullied, discriminated against or victimised as detailed in our Harassment and Bullying Policy. We will not tolerate bullying or harassment of any kind towards a colleague or group of colleagues and all allegations of bullying and harassment will be investigated and, if appropriate, disciplinary action will be taken. Should a colleague wish to raise a complaint in this area, the process of this is detailed in our Grievance Procedure.
All individuals have the right to be treated with dignity and respect and we have a responsibility to ensure that all colleagues feel that they are protected from any kind of harassment. This also applies to the treatment of clients, customers, third-party partners and members of the public who have dealings with the Company and its colleagues.
Health and Safety
Our Health and Safety Policy is designed to provide a safe and healthy work environment, including safe access and egress arrangements and to prevent work related injury and ill health. We achieve this by setting effective and consistent standards and targets to fulfil our legal obligations and also drive continuous improvement. We aim to prevent accidents and work-related ill health through suitable training, instruction and supervision of our colleagues, contractors, visitors and others to ensure their safety and to complete suitable and sufficient risk assessment ensuring the proportionate control of risks which may arise in work activities. We also expect the same of our suppliers/third-party partners.
Human Trafficking and Forced Labour
Cole Fabrics have a long-established supply chain. With key supply partners trading with Cole Fabrics for over 20 years. We require our suppliers to work to a Human Rights Policy which aligns with the ETI Base Code and complies with all local laws and regulations.
Cole Fabrics prohibit the recruitment, movement, harbouring or receiving of children or adults using force, coercion, abuse of vulnerability, deception, or other means for the purpose of exploitation.
Modern Slavery
We have a zero-tolerance approach to modern slavery under the definitions of the Modern Slavery Act 2015. As we look to mature our systems in the future we aim to publish a Modern Slavery Statement, but this is not currently a legal requirement due to our limited size.
Child Labour
Cole Fabrics do not employ children or young persons. We require the age of our colleagues to be verified at the time of hiring and have processes in place to responsibly remediate any potential policy violations to ensure we are legally compliant in UK and/or international law.
Collective Bargaining and Freedom of Association
We respect our colleagues right to join, form or even not join a Trade Union, without fear of any consequences. Cole Fabrics is committed to working collaboratively with all recognised Trade Unions.
Hours, Pay and Benefits
Cole Fabrics compensate colleagues with pay equitable with their role, skills and experience and external benchmarking. This will be in line with the terms and conditions of any relevant collective bargaining agreements. We ensure full compliance with wage, work hours, overtime and benefit laws. In addition to this, we are committed to employing colleagues on contracts of employment where there is a stated number of contracted hours. We do not directly employ any colleague on a ‘zero hours’ contract.
All our colleagues pay meets or exceeds the legal minimum wage. Overtime is paid at the appropriate rate as agreed as part of any collective bargaining agreement and/or contract of employment. All colleagues are paid on time and in full and receive a pay statement for each pay period that outlines the components of their pay.
In terms of our Supply Chain, we believe it is important that we understand the impact that our goods have on the people that produce it. We continue to champion high ethical labour standards across our supply chain, and ask our co-manufacturing and packaging suppliers to provide full transparency when requested.
Data Protection
Everyone has the right to the protection of personal data concerning themselves. Such data must be processed fairly for specified purposes and on the basis of the consent of the person concerned or some other legitimate basis laid down by law. Cole Fabrics ensures the handling of consumer, customer, supplier and colleague data is in line with GDPR Regulations. In order to achieve this, we have a Data Protection Policy.
Speaking Up/Whistle blowing
Cole Fabrics is committed to conducting business with integrity and fairness.
All staff are encouraged to speak up and work directly with their colleges to resolve any issues they feel comfortable to discuss. All staff have access to our Grievance Procedure if they wish to raise a grievance and we have a Whistle Blowing Policy.
Cole Fabrics encourage any stakeholder (Customers, Distributors and/or Suppliers) to raise concerns and have Anonymous Reporting available to our employees and all third parties. This is available under the “contact us” section of our website www.colefabrics.com. To ensure its maximum reach we also highlight our anonymous reporting channel on all our Purchase Orders ensuring it is available to our supply chain.
To date we have no reports of Non-Compliance. However, we would first look to engage our suppliers and business partners to drive corrective actions that help address underlying issues. Where direct engagement does not lead to meaningful progress, we consider all appropriate forms of leverage, including the reduction and/or termination of supply.
4.3 How do we mitigate our risks?
Employees
For our colleagues, we publish all the relevant policies and procedures. In addition to this, we conduct our own face to face training annually on Equality, Inclusion and Diversity as well as Bullying, Victimisation and Harassment to ensure all our staff can recognise what this might look like and the channels they have available for raising any issues. Our training also covers Mental Health Awareness.
Supply Chain
We recognise that we need to work in partnership with our supply chains and customers to mitigate and improve Human Rights issues. We are committed to driving best practice in protecting Human Rights in our supply chains, with the aim that every worker is treated fairly, to prevent all forms of exploitation as like-minded businesses.
Our Code of Conduct sets out the standards that we expect to be in place throughout our supply chain and is based upon the ETI base code. We know that Human Rights and human dignity are important for our colleagues, our shareholders, investors, customers and to the communities in which we operate. We will engage with our customers and suppliers to ensure that the best standards of transparency and inclusion are adhered to within our activities.
We identify risk levels in our Supplier Management System (SMS). This is designed to list all external independent audits and certifications that our suppliers hold. We focus on our highest impact areas, which we have identified as our raw material suppliers with whom we purchase the greatest value of materials.
We look at audits such as ISO 9001, ISO 14001, ISO 45001, SA 8000, BRCGS, GRS, FSC, GOTS and SMETA. We also look at suppliers’ transparency and disclosure through our information sharing platforms EcoVadis, the Higg FEM and Sedex. Seeking these internationally recognised standards that are independently verified mitigates our risks and highlights areas of Non-Conformance to these standards.
Cole Fabrics are a member of SEDEX and have a SMETA Audit annually. We ensure that any non-conformances raised are addressed, actioned, and closed out in a timely manner.
4.4 Communication and Training
We communicate our Human Rights policy throughout the business and conduct our annual training on EDI and Harassment and Bullying. Our SMETA audit results are shared with all employees.
4.5 Remedy
As a business, we will continue to build the awareness and knowledge of employees and workers on human rights as detailed in this policy. We actively encourage anyone to speak up, without fear of retribution, by contacting us directly or via our anonymous reporting or Grievance Procedure, if they have any information on adverse human rights in our business and/or with any of our third-party partners. We have a fair and confidential grievance procedure in place to manage any such concerns.
The outcome of any procedure will ultimately result in providing a remedy where they have caused or contributed to an impact on human rights. We are committed to continue to increase our capacity to effectively identify and respond accordingly to any concerns that may arise. As a SME (Small, Medium Enterprise) we have limited internal expertise and as such, depending on the severity of the complaint we would seek the appropriate level of external support and advice on any human rights breaches.
4.6 Accountability
This policy was approved by the Board of Cole Fabrics Plc on 22nd April 2025.
The Operations Director has overall accountability for human rights within Cole Fabrics, with support from the Leadership Team. The Operations Director is accountable for ensuring best practice is maintained internally and the Compliance Manager is accountable for mitigating external risk throughout our Supply Chains.
We reserve the right to review this Human Rights Policy on a regular basis and update it if necessary. The latest version of this document will be posted on our notice boards and shared with our key suppliers.