Norty Limited will not tolerate the deprivation of a person’s human rights by another human being to exploit them for personal or commercial gain. We are committed to our zero-tolerance policy regarding modern slavery and human trafficking, which is explicitly outlined to our partners and suppliers throughout our Operating Principles.

We are committed to acting ethically and with integrity in all our business operations and relationships, whether these be through direct employment, or with suppliers or contractors. Furthermore, we are committed to implementing measures, processes and controls to ensure that modern slavery is not occurring anywhere in our business operations or supply chain.

Our policies relating to modern slavery and human trafficking comply with all laws, regulations, legislation, rules and best practice relevant to our business operations. They are aligned with the ETI (Ethical Trading Initiative) base code and the ILO (International Labour Organisation). The ETI Base Code is founded on the conventions of the ILO and is an internationally recognised code of good labour practise.

We utilise the ETI Base Code as a level of reference standard which, alongside our partners’ ethical trade due diligence, internal audit and self-assessment reviews, and risk assessment analysis, informs our continuous improvement plans. We use these plans to define an explicit minimum standard which needs to be met. Where local law and the Base Code address the same subject, our partners are expected to apply the provision that affords greater protection to workers.

We, at Norty Limited, are firmly opposed to the use of any kind of forced labour in the sourcing of our raw materials. This is illustrated by our complete commitment not to knowingly source any of our cotton for the manufacturing of our products from areas where forced labour is a reported issue, such as the Xinjiang region of China.

As such, no Chinese sourced cotton should come from this region in the manufacturing of our products at any stage of production in our supply chain. Where Chinese cotton must be used, we require a declaration confirming the region of sourcing.

Our Operating Principles, which were first introduced in 2014, explain to our partners and the factories we work with the minimum requirements and expectations we have of them in order to maintain a working relationship. These Principles uphold our zero tolerance policy and outline expectations on Human Rights, Labour, Environmental and Ethical requirements.

Our Operating Principles are shared with all our partners and tier one suppliers before any orders are placed. These partners and suppliers are required to read, agree to, and sign the Principles to acknowledge their agreement to uphold the Principles within their own facilities and to subsequently communicate these Principles to any supplier they work with on behalf of Norty Limited.

Our Operating Principles include the following sections relating to human rights:

Employment is Freely Chosen

• There shall be no forced, bonded or involuntary prison labour. Workers must not be required to lodge ‘deposits’ or their identity papers on commencement of employment. Workers must be free to leave their employer after reasonable notice. All contracts should be written in a language understandable by employees.

No Child Labour

Norty Limited categorically will not do business with vendors or suppliers that use child labour.

• Vendors and suppliers who employ young people in violation of respective local mandatory school age or under the respective country’s legal employment age will not be used.
• We reserve the right to establish our own minimum age limit for vendors and suppliers on a country-by-country basis if we deem the work being done by employees at the legal minimum employment age is inappropriate or poses a risk to safety.
• Under no circumstance will the minimum age of employees be under fourteen.
• Children and young persons under the age of eighteen shall not be employed at night or in hazardous conditions, such as working with machinery or chemicals.
• The policies and procedures will conform to the relevant ILO policies.
• Norty Limited is extremely supportive of the development of legitimate workplace apprenticeship programmes for the educational benefit of younger people.

Freedom of Association and Employee Representation

• Suppliers should respect the rights of employees to join or form an association of their choosing (such as workers’ councils, unions, or workers’ associations).
• Where the right to freedom of association and collective bargaining is restricted by law, the employer should facilitate, and not hinder, the development of parallel means for independent and free association and collective bargaining.
• Representatives must not be discriminated against and they must have access to carry out their representative function in the workplace.

No Discrimination

• Norty Limited recognises and respects cultural differences; and we believe that there should be no discrimination in hiring, compensation, access to training, promotion, termination or retirement based on race, caste, nationality, religion, age, disability, gender, marital status, sexual orientation, union or political membership.
• However, in-country laws will take precedence over company policies and directions.

Wages and Benefits of Employment

• Wages and benefits paid for a standard working week must meet, as a minimum, national legal requirements or industry benchmark standards, whichever is higher.
• Wages should cover the need to meet both basic needs and some discretionary income.
• All workers should be provided with written and understandable information about their employment conditions and wages before employment, in a language which they can understand. Furthermore, workers should be provided with payslips, in a language they can understand, for each period they are paid.
• Deductions from wages as a disciplinary measure are not permitted, other than those required by law. Any such deductions must not be taken without the expressed permission of the worker concerned.

Hours of Work and Regular Employment

• All factories must adhere to the relevant national laws with regards to maximum working hours as standard.
• Obligations to employees should not be avoided through the use of home working schemes, subcontracting, or apprenticeships where there is no intent to provide regular employment.
• The conditions for the termination of a contract should be laid out before employment commences and conform to established and transparent company practices and local laws.

Discipline

• Employee abuse in physical, sexual, or verbal forms of intimidation, are not acceptable and are prohibited.

Health and Safety

• A safe, clean, and hygienic environment should be provided, taking into account the specific hazards of the industry.
• Adequate steps should be taken to prevent accidents and injury to health at work.
• Workers should receive regular and recorded health and safety training.
• All workers should have access to clean toilet facilities and drinking water.
• Where provided, accommodation should be clean, safe, and meet the basic needs of workers.
• A senior manager should be appointed as the Health and Safety representative for the company.

Anti-Corruption

• No employee of Norty Limited or any of its approved business partners may, directly or indirectly, through one or more intermediaries, give, offer, or agree to give or offer, a bribe or kickback to any person.
• Prohibited payments include the payment of anything of value (in the form of money, gifts, loans, rewards, travel or business opportunities, advantage or benefit of any kind) to or for the benefit of any foreign official, domestic official or person doing business in the private sector for the purpose of inducing or rewarding favourable action (or withholding of action) or the exercise of influence by such individual.

Due Diligence Processes

“One of the pillars that Norty Limited is built on is our desire to do the right thing, and this principle is highlighted through our choice of partners.”

We only partner with factories who meet our high standards and share our commitment across human resource management, health and safety, environmental practises, legal compliance, security standards and local laws.

Ultimate responsibility for the commitment and prevention of modern slavery and human trafficking lies with our Board of Directors, who have overall responsibility for ensuring this policy and its implementations comply with legal and ethical obligations. Our modern slavery and human trafficking policy will be reviewed on an annual basis – at the end of the financial year.

We conduct risk assessments based on inherent risks, such as geographical location, and supplier’s Self-Assessment Questionnaires to identify potential risks and factors which may indicate signs of human rights. The SAQs help to identify risks to specific sites and these are subsequently mitigated through auditing and certification of that facility.

Our Auditing Process

It is mandatory for our tier one suppliers to undertake regular, independent, third-party on-site audits which are then reviewed internally by members our of team. Through these audits, we get a better understanding of how people employed in our supply chain are treated. The audits identify any non-compliances the site may have whether these be minor, major, critical, or zero tolerance issue. We accept a combination of announced, semi-announced and unannounced audits.

Minor – a minor non-compliance is a less significant breach that represents a low risk to workers which, in isolation, can be rectified quickly. If a number of minor non-compliances are raised in the one audit at a respective site then this may indicate a greater underlying issue which needs to be fixed.

Major – a systemic breach of a code or local law which could present a danger to workers or violate upon a human right.

Critical – a systemic, deliberate or severe breach of a code or local law which presents a danger to workers or others, or which denies a basic human right.

– an attempt to pervert the course of an audit through fraud, coercion, deception or interference with the audit process.

– this issue must be rectified and have this validated by an auditor within the given time period.

Zero tolerance – a breach of code or law which presents an immediate or serious risk to life and limb, or which constitutes a severe human rights impact that could be difficult  to remedy.  This could lead to an immediate suspension or cessation of working relationships between us and that partner.

– no zero tolerance non-compliances have been found within the last twelve months.

All of the third-party social auditing bodies utilised by our suppliers address gender equality through their own standards and respective auditing processes. The methodologies focus on areas such as non-discrimination, the prohibition of harassment, and the collection of gender-disaggregated data to identify and address specific risks. We frequently review the gender data provided through these audits and utilise the tools and guidance offered to us by these third-parties.

We have our own internal grading system which must be met by the factory’s audits and certifications. If the number of minor or major non-compliance exceeds our threshold on a Sedex audit, then the factory must be reaudited within the given period in which we provide the factories with. The same applies for critical non-compliances, except with a shorter time frame. With regard to a zero tolerance non-compliance, if the working relationship persists, the factory must have the issue rectified and validated by an auditor within a specified time frame.

With regard to the amfori BSCI audit, if the score is given as an A or a B, we require the factory to be reaudited within two years and if the factory is scored between and C and E, then we require a follow up audit within the year.

For a WRAP certification, if the facilities have been scored as Platinum, we require them to be reaudited within two years. If the factory received a Gold certification then they must be reaudited within a year. If the factory received a Silver certification, then they are required to be reaudited within six months.

Other certifications

A number of factories are respectively GOTS (Global Organic Textile Standard) or BCI (Better Cotton Initiative) certified. These audits look at the social elements of the factories and ensure the factories adhere to the ILO guidelines.

The GOTS audit focuses on various social elements that include: Prohibition of Forced and Child Labour; Safe and Hygienic Working; Freedom of Association and Collective Bargaining; and Fair Treatment of Vulnerable Workers.

The BCI audit focuses on various social elements that include: Forced Labour, Occupational Health and Safety; Non-Discrimination and Harassment; and Gender Equality.

Continuous Improvement

We offer our continuous support to our factories to work towards continuous improvement with the assistance of our partners who are on the ground and are highly skilled in the audit process, as well as local laws and regulations. By working with local experts on the ground, we can more effectively develop programmes built around advice they have given us. Through social audits, we are ensuring the implementation of international labour standards that protect workers’ rights and acts as a driving force for improvements across the world.

In addition to routine third party audits, members of the Norty team visit each of our tier one suppliers at least once a year. This allows us to conduct our own reviews of the facilities and subsequently monitor the effectiveness of our compliance programme. As a result, we are able to check for discrepancies in information we were provided. It also helps us to maintain our transparent and honest relationships with our suppliers as we have an in-person connection with them.

To keep up relationships, transparency and accountability in regards to demands with our suppliers and buying houses, we have bi-weekly calls to discuss any issues and keep in contact. These calls allow a direct communication avenue, above emails, which allows for any issues or queries to be addressed.

Improving Supply Chain Transparency and Accountability

Through our partnership with tex.tracer, a leading Digital Product Passport platform based out of Amsterdam, Netherlands, we aim to dive into our supply chains and establish a connection with parties further down the chain. The platform will allow us to establish a direct connection with suppliers as they are invited to make an account and publish their social and environmental data and compliance certifications and audits onto the system. We will also be able to send these suppliers our Operating Principles directly for them to agree to and return back to us. We want to further embed our policies into our tier two and beyond suppliers.

On the platform, our tier one suppliers are invited to the platform and once an orderline has been placed, our supplier is then able to invite their suppliers until the full supply chain is invited and onboarded onto the platform. This will allow for up-to-date and specific supply chain partner information. Each new supplier invited throughout the supply chain will be internally reviewed by members of the Norty team as we want to hold ourselves accountable for our whole supply chain.

Key Performance Indicators to Measure Effectiveness of Steps Being Taken

At Norty Ltd, we have implemented a company-wide supply chain strategy focused on maintaining end-to-end visibility to ensure compliance with our agreed requirements. We recognise that this is an ongoing journey and are committed to continuous improvement through regular reviews, process enhancements, and further implementation where required.

Using a KPI tracking system, we proactively identify areas for improvement and new opportunities, enabling coordinated, company-wide actions to ensure we operate in the most sustainable and ethical manner possible.

75% of our tier one suppliers have completed a Self-Assessment Questionnaire, but we aim to increase this to 100% by the end of 2026.

It is our aim for this year to utilise all of the resources at our disposal regarding forced labour, modern slavery and child labour to produce a training guide for members of the team who visit our factories so they are trained to identify any indicators of modern slavery and forced labour. We want to educate our staff to identify dangers associated with specific countries and regions and become more aware of the overall situation regarding the supplier and their production.

We aim to form a connection with our suppliers all the way down our supply chains. We will use the tex.tracer platform to achieve this and develop direct avenues of communication with those further down our supply chain who we may not have had the opportunity to communicate with. 

We are redeveloping our supplier manual which will be disseminated to our suppliers during 2026 which further reinforces our stance and our standards with regards to modern slavery and human rights. The document will outline our audit processes and expectations.

We will continue to work closely with our factories and suppliers to support and educate them to continually improve.