- CORPORATE RESPONSIBILITY OVERVIEW
- SUPPLIER CODE OF CONDUCT
- ENVIRONMENTAL POLICY
- WHISTLEBLOWER POLICY
CORPORATE RESPONSIBILITY OVERVIEW
SARAH & SEBASTIAN is committed to complying with all applicable national and international laws, regulations and conventions, as well as best practices in ethics, human rights and social responsibility.
SARAH & SEBASTIAN is committed to acting with integrity in all its business actions and to promoting ethical conduct, enforcing compliance with applicable laws and providing guidance in the management of its business.
SARAH & SEBASTIAN has adopted several key policies in support of this commitment, defining what Sarah & Sebastian expects of its employees, internal operations and external suppliers.
SARAH & SEBASTIAN works with business partners and suppliers who agree to abide by the requirements of our Supplier Code of Conduct as well as the principles set out in the International Labour Organization conventions, the Universal Declaration of Human Rights, the United Nations Global Compact, the OECD Guidelines for Multinational Enterprises and the United Nations Women's Empowerment Principles.
SARAH & SEBASTIAN is committed to responsible and low-risk Mineral Supply Chains.
SARAH & SEBASTIAN is committed to implementing the UN Guiding Principles on Business and Human Rights as well as the International Covenant on Civil and Political Rights and the International Covenant on Economic, Social and Cultural Rights.
With this statement, SARAH & SEBASTIAN wishes to highlight the policies, risk assessment, risk assessment management system and grievance mechanism, which aim to prevent or mitigate negative consequences related to our procurement practices.
1. Organizational Structure
SARAH & SEBASTIAN's supply chain only includes suppliers and business partners that are either RJC or able to provide evidence of RJC compliant practices such as the Kimberly process for diamonds.
SARAH & SEBASTIAN requires its suppliers to comply with the ethical principles set out in its Supplier Code of Conduct and to ensure that their own suppliers and subcontractors comply with these principles.
This Supplier Code of Conduct specifically specifies the obligation to respect social issues and to respect and adhere to moral and ethical values in the management of the company with regard to human rights, working conditions and environmental issues.
SARAH & SEBASTIAN is aware of the potential social consequences of its activities, particularly in relation to the sourcing of raw materials. For this reason, the company has defined a responsible approach to sourcing and policies to operate ethically and with respect for human rights. Particular attention is paid to the production of jewellery items:
- SARAH & SEBASTIAN confirms its commitment to act responsibly and to work with trusted suppliers based in countries that are signatories to the Kimberley Process, an initiative bringing together governments, industry and civil society and aiming to prevent the circulation of conflict diamonds through an international certification system.
- Since 2022, SARAH & SEBASTIAN has been a member of the Responsible Jewellery Council and is seeking certification of the RJC Code of Practice. The Responsible Jewellery Council (RJC) is a non-profit organization established to promote a common standard for responsible ethical, social and environmental practices that respect human rights throughout the supply chain of gold, platinum mined metals, diamonds and coloured stones from mining to retail.
- SARAH & SEBASTIAN is committed to strengthening systems and controls for the respect of human rights throughout the supply chain. Therefore, Sarah & Sebastian's management committee regularly assess the adequacy of the procedural framework and identify opportunities for continuous improvement.
3. Supply Chain Risk Assessment
Through principles promoted by the Responsible Jewellery Council, Sarah & Sebastian monitors social and human rights risks throughout the supply chain.
To this end, SARAH & SEBASTIAN has implemented a supplier risk management process, consisting of the following three steps:
1) supplier risk assessment;
2) social and environmental monitoring of suppliers
Suppliers included in the risk assessment are sent a self-assessment questionnaire covering, among other things, the following topics: forced and child labour, freedom of association, discrimination, disciplinary and complaint procedures, working hours, wages and general working conditions. These suppliers are also asked to complete a duty of care questionnaire. The purpose of the questionnaire is to collect information on Sarah & Sebastian's supplier due diligence management system, in line with the recommendations of the OECD's Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict and High Risk Areas.
Through supplier responses to the questionnaire and knowledge of supplier activities, Sarah & Sebastian has identified potential risks.
4. Due diligence and control of suppliers
SARAH & SEBASTIAN is able to visit its suppliers’ factories to conduct announced and unannounced audits based on the RJC Code of Practice.
SARAH & SEBASTIAN aims to comply with the RJC Code of Practice. As a result,
SARAH & SEBASTIAN is working to strengthen its internal procedures and processes in line with the OECD Duty of Care Guide for Responsible Supply Chains of Minerals from Conflict and High Risk Areas.
SUPPLIER CODE OF CONDUCT
SARAH & SEBASTIAN herein referred to as “S&S” is committed to ethical business practices. This means that we conduct business lawfully, appropriately and with honesty and integrity by adhering to applicable laws and regulations, exercising sound judgement and taking actions to minimize environmental impact on the planet. We set our ethical commitment, standards of behaviour and conduct to which we expect entire S&S to adhere to.
Our Code is based on internationally accepted labour standards and guidance, including the Ethical Trade Initiative (ETI) Base Code, the International Labour Organization (ILO)’s core conventions, the Universal Declaration of Human Rights, and the United Nations (UN) Guiding Principles for Business and Human Rights.
This Code also supports S&S’s human right commitments, as outlined in the company’s Modern Slavery, Anti-Slavery, Anti- Bribery Corruption, Anti – Discrimination, Workplace Discrimination & Harassment, Bullying policies.
We expect that our suppliers share this commitment, and we are committed to working with our suppliers to ensuring high social, environmental and business ethics standards.
This Supplier Code applies to all S&S suppliers. Observance of the Supplier is an enforced part of any agreement or contract between S&S and our suppliers. The provision of the supplier code extends to all supplier facilities, activities and employees including employees who are engaged informally on short term contracts, or on a part time basis that contribute to fulfilment of the contract.
We require that suppliers of S&S meet the following standards at minimum.
4. Human Rights & Labour Rights
Child Labour and Young Labour
- The supplier shall not engage in or benefit from the use of child labour. There shall be no recruitment of child labour.
- Companies shall develop or participate in and contribute to policies and programmes which provide for the transition of any child found to be performing child labour to enable her or him to attend and remain in quality education until no longer a child; “child” and “child labour” being defined in the appendices.
- Children and young persons under 18 shall not be employed at night or in hazardous conditions.
- These policies and procedures shall conform to the provisions of the relevant ILO standards.
Freely chosen Employment
There is no forced, bonded, or involuntary prison labour. Suppliers shall ensure that all employees are working in voluntary situations.
Suppliers shall not retain original copies of an employee’s personal documentation, such as identity papers and shall not use deceptive recruitment practices and/or require employees to pay any deposits, equipment advances or recruitment fees (either wholly or partially) as part of the recruitment process. If any such fees are found to have been paid by employees, they shall be reimbursed.
Supplier shall not prevent employees from terminating their employment after reasonable notice or as established by applicable law.
Freedom of Association and The Right to Collective Bargaining
- Workers, without distinction, have the right to join or form trade unions of their own choosing and to bargain collectively.
- The employer adopts an open attitude towards the activities of trade unions and their organisational activities.
- Workers representatives are not discriminated against and have access to carry out their representative functions in the workplace.
- Where the right to freedom of association and collective bargaining is restricted under law, the employer facilitates, and does not hinder, the development of parallel means for independent and free association and bargaining.
Obligations to employees under labour or social security laws and regulations arising from the regular employment relationship shall not be avoided through the use of labour-only contracting, sub-contracting, or homeworking arrangements, or through apprenticeship schemes where there is no real intent to impart skills or provide regular employment, nor shall any such obligations be avoided through the excessive use of fixed-term contracts of employment.
Wages and benefits paid for a standard working week meet, at a minimum, national legal standards or industry benchmark standards, whichever is higher. In any event wages should always be enough to meet basic needs and to provide some discretionary income.
All employees shall be provided with written and understandable information about their employment conditions in respect to wages before they enter employment and about the particulars of their wages for the pay period concerned each time that they are paid.
Deductions from wages as a disciplinary measure shall not be permitted nor shall any deductions from wages not provided for by national law be permitted without the expressed permission of the worker concerned. All disciplinary measures should be recorded.
The supplier shall comply with applicable national laws on working hours and public holidays.
Working hours, excluding overtime, shall be defined by contract, and shall not exceed 48 hours per week.
All overtime shall be voluntary. Overtime shall be used responsibly, taking into account all the following: the extent, frequency and hours worked by individual workers and the workforce as a whole. It shall not be used to replace regular employment.
Overtime shall always be compensated at a premium rate, which is recommended to be not less than 125% of the regular rate of pay.
The total hours worked in any seven-day period shall not exceed 60 hours.
Workers shall be provided with at least one day off in every seven-day period or, where allowed by national law, two days off in every 14-day period.
Suppliers will not practice or condone any form of discrimination in the workplace in terms of hiring, remuneration, overtime, access to training, promotion, termination, or retirement based on race, ethnicity, caste, national origin, religion, disability, gender, sexual orientation, union membership, political affiliation, marital status, pregnancy status, or age, or any other characteristic protected by applicable law.
No Harsh or Inhumane Treatment
Physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation shall be prohibited.
Legal and Compliance
Anti – Bribery and Corruption
Bribes, kickbacks or similar unlawful or improper payments, in cash or kind, are strictly prohibited, whether given to obtain or retain business or for any other purpose.
The supplier shall refrain from offering, promising, giving, or authorizing money or anything of value to any employee of S&S or any individual, organization or other acting on behalf of S&S in an attempt to influence the judgment or conduct of that person for actual or perceived favourable treatment or an advantage. All these actions would constitute a bribe regardless of the monetary value.
Suppliers shall not offer or pay or provide anything of value (including travel, gifts, hospitality expenses, charitable donations, or other favours) to any official or employee of any government, government agency, political party, public international organization, or any candidate for political office, or an immediate family member of any such individual, to influence any act or decision to promote the interests of S&S in any respect.
Suppliers shall have a policy, covering bribery, corruption, or any type of fraudulent business practice.
Our employees are also bound by the same business ethics. If you see any indications that any of our employees may engage in wrongful practices, you, as our business partner, are required to inform us immediately under S&S’s Whistleblower Policy.
Anti-Money Laundering and Terrorist Financing
Suppliers are expected to refrain from engaging in or facilitating activities which may contravene the requirements of applicable anti-money laundering and terrorist financing laws. Suppliers must comply with all applicable laws and regulations pertaining to the detection, prevention, and reporting of potential money laundering and terrorist financing activities. Suppliers shall not cause S&S to facilitate or violate any applicable anti-money laundering or antiterrorist financing laws or regulations.
Suppliers must maintain financial accounts of all business transactions where required by applicable law and in accordance with national or international accounting standards.
Suppliers must comply with applicable economic sanctions laws and regulations; and refrain from engaging in any transaction with any sanctioned party or country or using another party to carry out activities that could not be lawfully performed directly due to trade sanctions prohibitions.
Suppliers shall have access to a transparent system in place for confidentially reporting and dealing with unethical business ethics without fear of reprisals towards the reporter.
Conflict of Interest
Suppliers are expected to avoid all conflicts of interest or situations giving the appearance of a potential conflict of interest. Suppliers are expected to provide notification to all affected parties in the event that an actual or potential conflict of interest arises. This includes a conflict between the interests of S&S and personal interests or those of close relatives, friends, or associates.
Suppliers must not fix prices or rig bids with their competitors. They must not exchange current, recent, or future pricing information with competitors. Suppliers must refrain from participating in a cartel, and they may not abuse a dominant position.
Intellectual Property Rights
Suppliers must comply with all the applicable laws governing intellectual property rights assertions, including protection against disclosure, designs, patents, copyrights, and trademarks.
Suppliers must not infringe, misappropriate, or misuse intellectual property of S&S and must take reasonable measures to safeguard all S&S intellectual property from theft and unauthorized access. Suppliers must obtain written consent from S&S before using or disclosing any intellectual property to third parties. Suppliers must adhere to applicable brand guidelines, as applicable, to help deliver a unified and consistent brand experience.
Grievance Mechanism, Confidentiality and Non-Retaliation
Employees should have access to a grievance mechanism through which complaints can be made, investigated and resolved in a fair and confidential manner.
Policies and procedures enabling employees to confidentially communicate concerns relating to non-compliance with this Policy shall be in put place and communicated to employees, with an avenue for anonymous disclosure and protection against detrimental treatment provided.
All Suppliers who handle data pertaining to S&S, its affiliates or our consumers, are bound to safeguard all data in accordance with S&S’s Data Processing Agreement as well as applicable laws and regulations. Suppliers must only use personal data for legitimate business purposes, and it must be protected, used, stored, and shared in accordance with the manner informed and agreed upon collection and in accordance with applicable data protection laws.
Monitoring and Compliance
Suppliers will permit S&S and its designated agents (including third parties) to engage in monitoring activities to confirm compliance with this Policy, including unannounced on-site inspections of manufacturing facilities and employer-provided housing; reviewing books and records relating to employment matters; and private interviews with employees.
Suppliers and Suppliers will maintain on- site all documentation that may be needed to demonstrate compliance with this Policy.
Safe and Hygienic Working Environment
- A safe and hygienic working environment shall be provided, bearing in mind the prevailing knowledge of the industry and of any specific hazards.
- Adequate steps shall be taken to prevent accidents and injury to health arising out of, associated with, or occurring in the course of work, by minimising, so far as is reasonably practicable, the causes of hazards inherent in the working environment.
- Suppliers and service providers will ensure that personal protective safety equipment is available, and workers are trained in its use.
- Safety guards on machinery must meet or exceed local laws. Valid certifications are maintained for special machines/facilities operators (boiler operator, forklift operator, cargo lift operator etc.).
- Risk areas, such as toxic substances and dangerous machinery, are identified and effectively managed by providing the applicable training and ensuring chemicals are properly stored and labelled with Material Safety Data Sheets (MSDS) and available to workers in the local language.
- Emergency eyewash stations and/or showers are provided where hazardous chemicals are handled and used.
- Electrical equipment and wiring are properly maintained, covered/insulated to prevent exposure of wires. Electrical cords and outlets are in a safe, working condition. Electrical control panels are clearly marked, are easily accessible and unblocked at all times.
- Workers shall receive regular and recorded health and safety training, and such training shall be repeated for new or reassigned workers.
- Injury records are properly maintained, and all significant accidents and near misses are investigated, reported and corrective action is performed to minimise any re-occurrence.
- Where local law requires; suppliers, vendors and service providers must provide worker compensation to all workers covering medical treatment for work related accidents and compensation for work related accidents resulting in permanent disability.
- Access to clean toilet facilities, potable water and sanitary facilities for food storage shall be provided.
- Accommodation, where provided, shall be clean, safe, and meet the basic needs of the workers, including:
- Requirements for fire safety and cleanliness, privacy and have a ventilation system to provide circulation of air to reduce odours.
- Accommodation must be separated from the workplace including material storage areas, must be well ventilated, adequately heated or cooled and have a separate entrance.
- Workers must have the freedom to move throughout their accommodation and be able to leave the premises during their free time.
- Workers must be able to lock their accommodation and securely store their personal belongings.
- There are a reasonable number of operating toilets and showers that are clean and separated by gender.
Training & Consultation
Suppliers shall provide employees with the necessary health and safety training and/or education and will secure those adequate systems to detect and avoid potential threats and to help continuously improving health and safety are put in place, and such training shall be repeated for new or reassigned employees.
The supplier shall develop and maintain effective systems for informing and consulting employees on relevant health and safety matters. Through these systems the supplier shall keep accurate records of accidents, injuries and known exposure to health and safety risks at work according to local legislation.
Clean & Sanitary Infrastructure
Suppliers shall provide a suitable, clean and sanitary infrastructure, including access to toilets and potable water, which meets the needs of its employees and is adequate for its employee numbers.
Health & Safety Representative
Suppliers shall assign responsibility for health and safety to a senior management representative.
Environmental Aspect and Associated Environmental Impacts
Suppliers shall regularly review all business processes and activities to understand how the company interacts with the environment and to identify any actual and potential environmental impacts, which may involve pollution of air, water or soils, use of materials and energy, wastes and emissions, noise and visual effects.
Suppliers shall identify and mitigate significant wastes and emissions to air, water and land generated in their business processes and activities. Significant wastes and emissions are those that are hazardous and require special handling and disposal, have the potential to harm the environment or individuals, or require a license or permit.
Suppliers will comply with all applicable environmental laws and regulations. The facility shall dispose of its production waste in accordance with local environmental laws and regulations.
The facility must have identified and documented its key environmental impacts and implemented controls to eliminate or minimise its impact on the environment with respect to solid waste disposal, hazardous chemicals storage and management, air and water emissions.
Suppliers shall exercise due diligence when sourcing raw materials to minimise the risk of sourcing such materials from jurisdictions and suppliers connected with human rights and/or environmental abuses.
Opportunities to reduce the consumption of natural resources including, but not limited to, water and virgin forests, while identifying an increase in the use of renewable and recyclable resources shall be pursued and implemented where feasible.
Suppliers must comply to all applicable laws and regulations with respect to the use of harmful, prohibited or restricted substances in the production process. Sufficient and appropriate water management systems and practices must be maintained, to ensure water is conserved where possible, and wastewater managed and treated appropriately prior to being disposed of responsibly and in accordance with local laws.
Suppliers are to look for cost effective methods to improve energy efficiency and to minimise their energy consumption and greenhouse gas emissions.
Applicable Environmental Laws and Regulations
Suppliers, as a minimum, must meet the requirements of local and national laws relevant to the environmental impacts of its activities, products and services, and ensure legal compliance through training, awareness, operational control and monitoring.
Where it is a legal requirement, suppliers must be able to demonstrate that they have the relevant valid permits including for use and disposal of resources e.g., water, waste, air emissions, etc.
Environmental Policy, Communication & Training
Suppliers shall have an environmental policy, covering their environmental impact, which is communicated to all appropriate parties, including its own suppliers.
In the planning process, the supplier establishes environmental objectives to fulfil the commitments established in its environmental policy and achieve other organizational goals.
Suppliers shall provide training and information about environmental risks and controls to all relevant employees. These shall be given in a format and language that employees can easily understand.
Establishing Operational Controls
Suppliers shall ensure that its operations and associated processes are conducted in a controlled way in order to fulfil the commitments of its environmental policy, achieve its environmental objectives and manage its significant environmental aspects and compliance obligation.
Operational controls can take various forms, such as procedures, work instructions, physical controls, use of competent personnel, or any combination of these. Once operational controls have been established, the suppliers shall monitor the continuing application and effectiveness of these controls, as well as plan and take any action needed.
S&S believes that mutual trust, transparency and dialogue are essential to a successful business partnership including the effective implementation of this Suppler code. To this end, S&S reserves the right to request performance data related to this supplier code including by performing announced and unannounced audits at suppliers’ sites. Such audits may be performed by S&S, by assessors appointed by S&S and/or assessors appointed by organisations of which S&S is a member. Audit performed or commissioned by S&S uses the SMETA audit methodology.
S&S seeks to continuously improve together with our suppliers and help them achieve compliance with the provisions of this Supplier Code. In the event of failure of compliance, S&S and suppliers will agree on corrective actions that must be taken within a specified timeline. If no solution can be agreed upon and implemented within a reasonable amount of time, S&S may choose to terminate the business relationship and/or suspend future contracts with a non-compliant supplier. The S&S responsible Sourcing Policy specifies S&S’s approach to corrective actions as well as details S&S zero tolerance requirements.
As part of an effort towards continuous improvement, suppliers shall assess all activities to control environmental impacts regularly and ensure they remain effective, and adapt control measures accordingly.
Suppliers shall make continuous improvements in their environmental performance.
Suppliers will not sub-contract production for services, products or components without S&S’s express written consent, and only after the subcontractor has entered into a written commitment with S&S to comply with this Policy and the supply or products or services.
All manufacturing facilities should have a valid Building Structure Safety Certificate or permit, confirming the compliance to the relevant building code, and relevant Fire Safety Certificates.
Per local codes and laws, supplier premises must have an adequate number of unlocked, freely accessible and clearly marked emergency exits, properly maintained and valid firefighting equipment and relevant first aid equipment easily accessible.
Supplier facilities shall communicate fire and emergency evacuation plans and post the diagrams in the local language in various locations around the manufacturing site.
Supplier facilities must conduct fire and emergency evacuation drills for all areas and shifts on an annual basis, with the presence of the local fire service and/or the civil defence authority, or as required by law.
Manufacturing facilities must have a fire alarm system in place that is audible throughout the entire premises. The system is inspected regularly and tested in coordination with fire drills.
Flammable materials are stored in a designated area away from emergency evacuation routes (aisles, exit, stairways and assembly points), open flames, heated surfaces, sparks, and unprotected electrical wiring.
Designated personnel (workers and supervisors) are trained at regular intervals in fire safety, the use of fire extinguishers, and how to administer the fire prevention procedures and emergency evacuation plan. Where firefighting training is legally required, training is provided in accordance with the law.
S&S has implemented a Whistleblower Policy making it possible for all S&S employees and board members to report any serious or sensitive concerns, including misconduct, unethical behaviours, violations of the Code, any underlying Policies or applicable laws, rules or regulations
S&S requires it suppliers to raise and report serious or sensitive concerns including misconduct, unethical behaviours, violations of the S&S code of conduct or appliable laws, rules, or regulations in their operations. They should be permitted to raise concerns and reports confidentiality and without the risk of retaliation. Further, suppliers are required to provide their employees with avenues for raising legal or ethical issues or concerns without fear or retaliation. Suppliers are also expected to take action or prevent, detect and correct any retaliatory actions.
SARAH & SEBASTIAN respects and recognises the value of the environment to the community and future generations. We understand our responsibility to work towards sustainable development through the accountable and engaged use of energy and resources.
At SARAH & SEBASTIAN we recognise and welcome that the industries we are integrated with are governed by strict requirements and enforced processes for Health, Safety, Security and Environmental concerns.
We engage with our contractors and employees in ensuring that all hazards and dangerous substances are reported in compliance with our procedures. Where possible we visit and regularly monitor our partners to ensure they comply to monitor their environmental performance and policies. SARAH & SEBASTIAN seeks assurance that all our partners fulfil their commitment in observing all environmental laws. We actively promote and encourage the adoption of ecologically sustainable work practices within SARAH & SEBASTIAN and amongst our partners.
SARAH & SEBASTIAN recognises its responsibility to the community to protect and enhance the environment in which we operate.
SARAH & SEBASTIAN’s policy includes:
- A commitment to reviewing the environmental aspects of Sarah & Sebastian operations and establishing objectives, targets and programs for all aspects with potential to have a significant impact on the environment. Objectives and targets will be reviewed on an annual basis, or as new significant aspects of our operations are identified.
- A commitment to continued compliance with relevant environmental legislation, regulations and other requirements applicable to the delivery of SARAH & SEBASTIAN services to our clients.
- Respecting our environment and operating in recognition of community expectations with regard to resource utilisation and management.
- A commitment to preventing pollution created from activities under our control. This will be done by minimising or eliminating the introduction of contaminants to the natural environment that cause an adverse change.
- Actively promoting a sense of environmental responsibility amongst our people.
- Communicating with and involve all interested people on environmental issues in an open and timely manner.
- Conserving the natural and cultural environment in all our operations in a socially responsible manner.
- Working with and apply the principles of continual improvement, waste minimization and pollution prevention.
- Striving to continually improve our environmental management system.
- Meeting all legal obligations and industry agreements both in letter and spirit.
- Developing, monitoring and reviewing environmental targets and publicly report environmental performance.
- Executing cost-effective measures to abate greenhouse emissions as part of business decisions.
- Ensuring our people understand our core values and expectations in relation to environmental consciousness.
- Encouraging our people to look for new and better ways to manage the potential impact of our operations on the environment.
- Maintaining a certified Environmental Management System in accordance with the requirements of ISO 14001:2015.
Our strategies for the fulfillment of this policy include:
- Monitoring of environmental performance and compliance with management systems will be conducted, analysed and reported with the intention of continually improving the effectiveness and environmental performance of our operations and environmental management systems.
- Ensuring that all waste is disposed of in the most appropriate and environmentally sensitive way, including reuse and recycling where available. Where necessary for compliance purposes, specialist qualified and licensed contractors shall be engaged for disposal of waste.
- Utilisation of resources with consideration for the environmental impact, especially with regard to consumption of energy, water, consumables and chemical materials.
Disposal of waste shall follow the waste management hierarchy below:
- Energy recovery
- Volume reduction
Training and information shall be provided to employees so that they are aware of the environmental aspects relevant to their area of operations, the requirements of the integrated management system and waste management procedures. Adherence to responsible environmental management principles and practices and to management system requirements will apply to all areas where a SARAH & SEBASTIAN representative is working, whether in their own work area or on a client’s sites.
SARAH & SEBASTIAN requires directors, officers and employees to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. As employees and representatives of SARAH & SEBASTIAN, we must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations.
SARAH & SEBASTIAN has an open-door policy and suggests that employees share their questions, concerns, suggestions or complaints with their supervisor. If you are not comfortable speaking with your supervisor or you are not satisfied with your supervisor’s response, you are encouraged to speak with a senior staff member. Supervisors and managers are required to report complaints or concerns about suspected ethical and legal violations in writing to the Compliance Manager, who has the responsibility to investigate all reported complaints. Employees with concerns or complaints may also submit their concerns in writing directly to their supervisor, senior manager.
This Whistleblower Policy is intended to encourage and enable employees and others to raise serious concerns internally so that SARAH & SEBASTIAN can address and correct inappropriate conduct and actions. It is the responsibility of all board members, officers, employees and volunteers to report concerns about violations of S&S code of ethics or suspected violations of law or regulations that govern SARAH & SEBASTIAN’s operations.
The Compliance Manager is responsible for ensuring that all complaints about unethical or illegal conduct are investigated and resolved. The Compliance Manager shall ensure that all complaints and their resolution and will report at least annually to the on-compliance activity relating to accounting or alleged financial improprieties.
It is contrary to the values of SARAH & SEBASTIAN for anyone to retaliate against any board member, officer, employee or volunteer who in good faith reports an ethics violation, or a suspected violation of law, such as a complaint of discrimination, or suspected fraud, or suspected violation of any regulation governing the operations of SARAH & SEBASTIAN. An employee who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination of employment.
Acting in Good Faith
Anyone filing a written complaint concerning a violation or suspected violation must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation. Any allegations that prove not to be substantiated and which prove to have been made maliciously or knowingly to be false will be viewed as a serious disciplinary offense.
Violations or suspected violations may be submitted on a confidential basis by the complainant. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.
Handling of Reported Violations
The Compliance Manager will notify the person who submitted a complaint and acknowledge receipt of the reported violation or suspected violation. All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation.