XAMAX® Clothing Company Ltd is committed to developing trading relationships that are commercially responsible, legally compliant and ethically managed. We expect suppliers, manufacturers, subcontractors and business partners to comply with this Ethical Trading Policy and to take labour standards, human rights, anti-bribery and responsible sourcing seriously.

This policy is informed by recognised international principles, including the United Nations Global Compact, the Universal Declaration of Human Rights and the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work, as amended from time to time.

1) Supplier expectations

XAMAX® expects suppliers, manufacturers, subcontractors and business partners to comply with all applicable laws and regulations in the countries where they operate. Where local law and recognised international labour standards differ, suppliers should apply the standard that gives workers the greater protection, where legally possible.

Suppliers are expected to:

1. Conduct business legally, honestly and ethically.
2. Respect workers’ human rights, dignity and welfare.
3. Provide safe and hygienic working conditions.
4. Prevent forced labour, bonded labour, involuntary labour and human trafficking.
5. Prevent child labour and protect young workers from hazardous work.
6. Avoid discrimination, harassment, intimidation and abuse.
7. Pay wages and benefits in accordance with applicable law.
8. Comply with working time laws and ensure overtime is responsible, voluntary where applicable, and appropriately compensated.
9. Respect lawful rights to freedom of association and collective bargaining.
10. Prevent bribery, corruption, kickbacks and dishonest business practices.
11. Provide information about ethical trading policies, labour standards or supply chain assurance where reasonably requested.

2) Minimum labour standards

This policy sets out the minimum labour standards XAMAX® expects suppliers to comply with:

1. Employment is freely chosen.
2. Child labour is not used.
3. Working conditions are safe and hygienic.
4. Discrimination is not practised.
5. Working hours comply with applicable law and recognised labour standards.
6. Wages meet or exceed applicable legal minimum standards.
7. Human and civil rights are respected.
8. Bribery, corruption and dishonest business practices are not acceptable.

3) Forced, bonded or involuntary labour

Forced, bonded or involuntary labour is not acceptable. This includes work or service extracted from any person under threat, coercion, penalty or abuse, or where the person has not entered the work voluntarily.

Workers should not be required to lodge deposits, identity papers, passports or other personal documents with their employer as a condition of employment. Workers must be free to leave their employer after reasonable notice, subject to lawful contractual terms.

4) Child labour and young workers

Child labour must not be used. Suppliers must comply with applicable minimum working age laws, compulsory schooling requirements and recognised international standards on child labour.

Young workers must not be employed at night or in hazardous conditions, and their work must not harm their health, safety, development, welfare or education.

5) Discrimination, harassment and abuse

Workers and prospective workers must not be treated less favourably in relation to recruitment, pay, training, promotion, termination, retirement or working conditions because of protected or personal characteristics.

Discrimination, harassment, intimidation, bullying, physical abuse, threats of abuse, sexual harassment, verbal abuse, mental coercion and degrading treatment are not acceptable.

6) Working hours

Working hours must comply with applicable national laws, collective agreements and recognised labour standards. Workers should not be required to work excessive hours.

Overtime should be responsible, should not be used to replace regular employment, and should be appropriately compensated. Workers should receive rest days and breaks in accordance with applicable law.

7) Wages and remuneration

Workers should be paid at least the legal minimum wage required in the country or region where they work. Wages and benefits should be paid on time, in full, and without unlawful deductions.

Workers should receive clear and understandable information about their pay, benefits and employment conditions before starting work, and should receive payslips or equivalent wage information for each pay period.

8) Human and civil rights

Suppliers must respect human and civil rights. Workers should be free to join a trade union of their choice and bargain collectively where this right is recognised by law.

Workers’ representatives must not be discriminated against and should be allowed to carry out lawful representative functions in the workplace. Where freedom of association and collective bargaining are restricted by law, employers should not hinder lawful alternative methods of worker communication and representation.

9) Health, safety and welfare

Suppliers must provide a safe and hygienic working environment. Appropriate steps should be taken to prevent accidents, injuries and work-related ill health.

Workers should have access to appropriate welfare facilities, safe systems of work, relevant training, emergency procedures, and suitable protective equipment where required for the work being carried out.

10) Bribery, corruption and unethical business practices

Bribery is the practice of offering, promising, giving, requesting or receiving money, gifts, hospitality, services or other advantages to influence business decisions or obtain improper favourable treatment.

Suppliers must conduct business ethically and must not seek to gain competitive advantage through bribery, corruption, kickbacks, improper gifts, undisclosed conflicts of interest, dishonest practices or other unethical behaviour.

11) Supplier review and monitoring

XAMAX® may request information from suppliers to help understand their ethical trading approach. This may include supplier codes of conduct, modern slavery statements, ethical trading policies, audit summaries, certification, accreditation or other relevant assurance.

XAMAX® may appraise suppliers against this policy and may take concerns into account when deciding whether to continue, pause, reduce or end a supplier relationship.

12) Raising concerns

Employees, suppliers, customers and business partners are encouraged to report concerns about unethical trading, labour rights, modern slavery, bribery, unsafe working conditions or other breaches of this policy.

Concerns can be reported to XAMAX® using the details on the Contact Us page. Reports will be handled sensitively and escalated to appropriate management for review.

13) Corrective action

Where a concern is identified, XAMAX® may take proportionate action depending on the nature and seriousness of the issue. This may include requesting further information, asking for corrective action, pausing purchasing, escalating internally, or ending a supplier relationship.

XAMAX® recognises that immediate termination of a supplier relationship may not always be the best outcome for workers. Where appropriate, XAMAX® may seek evidence of corrective action before deciding whether to continue or end the relationship.

14) Review and responsibility

Responsibility for this policy sits with XAMAX® management. The policy should be reviewed periodically and updated where appropriate to reflect changes in the business, supply chain, supplier relationships, legal requirements and recognised ethical trading practice.

Last reviewed: 15/06/2026.