Compliance Policy

Sustainability Policy

Crofts & Assinder is aware of the wider environmental concerns facing the planet and its impact on society. As such, we have an ethical and legal responsibility to act in a sensitive manner.
Crofts & Assinder is committed to improving its environmental performance by adopting improved environmental management methods in its business activities.
The purpose of this policy is to enable Crofts & Assinder to reduce its environmental impact by creating and delivering an ongoing sustainability plan that will be reviewed on an ongoing basis. This policy will evolve over time and sits alongside our Environmental Management Policy.
The aim of our Sustainability Plan will focus on each of the key headings below which formulate the basis of the Crofts & Assinder sustainability plan in line with the UN Global Compact and the UN Sustainable Development Goals (SDGs).
Economy – we expect our organisational partners to comply with and adhere to our Supplier Code of Conduct in relation to:
- Anti-bribery and corruption
- Labour Standards
- Human Rights
- Elimination of discrimination
- Elimination of child labour
- Elimination of forced and compulsory labour
- Freedom of association and collective bargaining
- Being members of the sustainable supply chain solutions body Sedex
Society – we are committed to supporting our employees and community by supporting:
- The national living wage.
- Engaging with local and national charities, and educational providers. Sustainability Economy Society Environment
- The health and wellbeing of our employees.
- All appropriate health and safety training, including training in fire safety, to be provided for our people in all working areas. All activities will be carried out under conditions that have proper and adequate regard for the health and safety of those involved. Management arrangements will be in place to detect, avoid and respond to potential threats to health and safety.
- A commitment to workforce development and training.
Environment – we recognise that as an organisation we need to protect the environment as best we can, as such we are committed to the following principles:
- To reduce our carbon footprint: We have committed to our electricity supply coming from carbon neutral sources and we aim for our UK operations to be Carbon Neutral by 2025.
- To continue to improve our waste management by reducing waste produced and increasing the waste material that can be recycled on an ongoing basis.
- We have improved our energy efficiency through the installation of LED energy efficient lighting across our UK sites and by implementing a switch off policy. We will continue to review all of machinery effectiveness and energy consumption.
- To improve our water efficiency through the installation of water saving equipment and the immediate implementation of a tap switch off policy.
- To work with our transport providers to ensure that they adopt sustainable polices within their own organisations to minimise their impact on the environment and for them to become carbon neutral within a reasonable timeframe.
- To minimise pollution through the continued use of effective work practices, equipment maintenance; and dangerous substance disposal via accredited third party disposal experts.
- To continue to promote our product end of life policy which is freely available to our customers.
- Requiring suppliers to adhere to our Environmental Management Policy. Crofts and Assinder Ltd will adhere to undertake all reasonable and practical steps, including factory inspections, to ensure that its standards are being implemented throughout the businesses of its suppliers and that local legislation and regulations are complied with. Crofts & Assinder Ltd will assess any instances of non-compliance on a case-bycase basis and will then tailor remedial action appropriately. Crofts & Assinder Ltd will only trade with those who comply with this policy or those who are taking verifiable steps towards compliance.
- Crofts & Assinder Ltd promotes its business objectives with those in its supply chain to minimise the environmental impact of its operations and encourage the consideration of social issues in business.
Crofts & Assinder will review this policy on an annual basis and strive to continually improve in all areas of the Sustainability plan where possible.

Alexander Crofts – CEO, Crofts & Assinder Ltd April 2023

ETHICAL TRADING PROCEDURE

Crofts & Assinder Ltd is committed to a Code of Conduct on Ethical Trading.
This code states Crofts & Assinder Ltd’s policy on legislation, child labour, employment conditions, wages and benefits, discrimination, human trafficking and health & safety.
Crofts & Assinder Ltd will undertake all reasonable and practical steps, including factory inspections, to ensure that its standards are being implemented throughout the businesses of its suppliers and that local legislation and regulations are complied with. Crofts & Assinder Ltd will assess any instances of non-compliance on a case-by-case basis and will then tailor remedial action appropriately. Crofts & Assinder Ltd will only trade with those who comply with this policy or those who are taking verifiable steps towards compliance.
Crofts & Assinder Ltd opposes the exploitation of children and young people and, in addition to national employment laws, Crofts & Assinder Ltd require from it’s suppliers that children under the age of the local national legal minimum working age and not less than 15, or those below the age for completion of compulsory schooling, must not be employed full-time.
Crofts & Assinder Ltd opposes the exploitation of workers and will not tolerate forced labour, or labour which involves physical, verbal or psychological harassment, or intimidation of any kind.
Crofts & Assinder Ltd will not accept human trafficking in its business or supply chain. The recruitment, provision or importation of a person for labour services must not be undertaken through the use of force, coercion, abduction or fraud. Crofts & Assinder Ltd will not permit the exploitation of, or discrimination against, any vulnerable group.
Crofts & Assinder Ltd supports fair and reasonable rewards for workers. Wages should reflect local norms and should meet or exceed any legal minimum wage levels. Wages must be paid in cash, or by cheque or bank transfers. While local and cultural differences will be observed, workers must not be expected to work excessive hours per week on a regular basis, including overtime. Any overtime must be voluntary. Workers will be entitled to at least one day off in seven. Individual workers have the right to choose not to take their days off should they so wish.
Crofts & Assinder Ltd requires that appropriate health and safety training, including training in fire safety, be provided for all people in all working areas. All activities must be carried out under conditions that have proper and adequate regard for the health and safety of those involved. Management arrangements must be in place to detect, avoid and respond to potential threats to health and safety.
Crofts & Assinder Ltd promotes its business objectives with those in its supply chain to minimise the environmental impact of its operations and also encourage the consideration of social issues in business.

Alexander Crofts – CEO, Crofts & Assinder Ltd January 2022

Equal Opportunities & Inclusion Statement

Introduction
- The Company is committed to treating every individual equally. Consistent with that fundamental belief, the Company is committed to equal opportunities and inclusive treatment for all employees.
Equal Treatment
- As a Company, Crofts & Assinder Ltd is committed to providing a work environment where all employees feel valued and respected where they feel they can make full use of their abilities, skills and experience and contribute fully to the success of the Company, and where people feel they are respected and valued, and can achieve their potential regardless of background. The Company has a separate detailed Equal Opportunities & Individual Treatment Policy which is issued to all employees.
- It is our policy not to discriminate against our employees or treat employees less favourably on the basis of their:
  - gender
  - sex
  - sexual orientation marital
  - status civil partner statusgender
  - reassignment/identity
  - race
  - religion
  - belief
  - colournationality
  - ethnicity
  - national origin
  - disability
  - age
  - pregnancy and maternity status
  - trade union membership or
    - any other personal characteristics that define us as unique individuals.
- Opportunities for employment, training and promotion are equally open to candidates from all groups. Selection for employment, promotion, transfer and training, and access to benefits, facilities and services, will be fair and equitable, and based solely on merit. The Company opposes and commits to avoid all forms of unlawful discrimination. This includes in:
  - pay and benefits.
  - terms and conditions of employment. dealing with grievances and discipline. dismissal.redundancy.
  - leave for parents.
  - requests for flexible working.
  - selection for employment, promotion, training or other developmental opportunities.
- It is in the best interests of both the Company and those who work for it, to ensure that every possible step is taken by the Company to ensure individuals are treated equally and fairly in all aspects of employment.
- This policy applies to all employees, whether permanent, part-time or on fixed-term contracts, to job applicants and to individuals such as agency staff and consultants and volunteers who are not our employees, but who work with us.
- All employees have a duty to act in accordance with this policy, and therefore to treat colleagues with dignity at all times, and not to discriminate against or harass other employees, whether junior or senior to them.
- Responsibilities include employees conducting themselves to help the organisation provide equal opportunities in employment, and prevent bullying, harassment, victimisation, and unlawtul discrimination. All employees should understand they, as well as their employer, can be held liable for acts of bullying, harassment, victimisation, and unlawful discrimination, in the course of their employment, against fellow employees, customers, suppliers and the public.
- The Company will take seriously complaints of bullying, harassment, victimisation and unlawful discrimination by fellow employees, customers, suppliers, visitors, the public and any others during the organisation’s work activities.
- Such acts will be dealt with as misconduct under the organisation’s grievance and/or disciplinary procedures, and appropriate action will be taken. Particularly serious complaints could amount to gross misconduct and lead to dismissal without notice. Further, sexual harassment may amount to both an employment rights matter and a criminal matter, such as in sexual assault legations. In addition, harassment under the Protection from Harassment Act 1997 – which is not limited to circumstances where harassment relates to a protected characteristic – is a criminal offence.
- Employees can raise any concerns in relation to the equal opportunities and individual treatment policy either directly with their Line Managers or raise a grievance of which the details and process are outlined within the Company’s Equal Opportunities & Individual Treatment Policy.

Crofts CEO, January 2022

ANTI BRIBERY & CORRUPTION PROCEDURE

Crofts & Assinder Ltd is committed to preventing bribery and corruption in the workplace.
Crofts & Assinder Ltd will conduct its business fairly, impartially, in an ethical and proper manner, in accordance with the company’s values and in full compliance with all laws and regulations.
The highest standards of ethical business conduct and compliance are required of Crofts & Assinder Ltd employees in performance of their company responsibilities.
The Company is committed to conducting its business with the utmost integrity. No form of bribery or corruption is tolerated.
It is a conflict for any employee or officer to pass on confidential information to other parties in return for gifts, cash or other favours.
It is a conflict of interest to accept bribes from customers, suppliers or other persons that could affect the outcome of business transactions.
It is a conflict of interest for an employee to make bribes or to participate in behaviour that can be interpreted as the corruption of customers, suppliers or other persons that could affect the outcome of business transactions.
Any employee who is approached by a customer and/or supplier and/or competitor and/or any other person with the offer of a gift, favours, invitation or cash must bring it to the attention of an officer of the Company (Director).
Reasonable entertaining is allowed and it is incumbent on the employee to justify what is reasonable. The purpose of business entertainment and gifts in a commercial setting is to create goodwill and sound working relationships, not to gain unfair advantage with customers. No gift or entertainment should ever be offered, given, provided or accepted by any Company employee or officer, family member of an employee or officer, or agent unless it cannot be construed as a bribe or payoff and does not violate any laws, regulations or applicable policies of the other party’s organisation. Employees must discuss with an officer of the Company any gifts or proposed gifts which they are not certain is appropriate.
This procedure applies to all employees. It also applies to agency workers or self employed contractors working on behalf of Crofts & Assinder Ltd including sales agents.

Alexander Crofts – CEO, Crofts & Assinder Ltd January 2022

Wellbeing Policy

INTRODUCTION
- The Company is committed to treating every individual equally. Wellbeing is defined as the experience of overall health; it encompasses good mental, physical, financial and social health.
EQUAL TREATMENT
As a Company, Crofts & Assinder Ltd is committed to providing a work environment where employees feel protected and comfortable to talk and to seek help and support. The Company will work to continuously improve the environment and culture of the organisation and will strive, as is reasonably practical, to promote good mental health throughout the organisation by establishing and maintaining processes which enhance mental health and wellbeing.
This policy will apply to all employees including those on temporary or fixed term contracts.
Aim 1 – To develop a supportive culture and to address factors that may negatively affect mental wellbeing.
- Reduce discrimination and stigma by increasing awareness and understanding.
- Give employees information on and increase their awareness of mental wellbeing.
- Provide employees with a copy of the wellbeing policy as part of their staff induction programme.
- Encourage employees to look after their mental wellbeing, for example through physical activity, stress reducing activities, financial management or social events.
- Encourage the use of predictable working hours, reasonable workloads and flexible working where appropriate.
- Ensure all staff have clearly defined job descriptions, objectives and responsibilities and to provide them with good management support, training and adequate resources to do their job.
- Manage conflict effectively and ensure the workplace is free from bullying, harassment, discrimination and racism.
- Ensure a physical environment that is supportive of mental health and wellbeing including sound ergonomically designed workstations with appropriate lighting, noise levels, heating, ventilation and adequate facilities for breaks.
- Promote and support opportunities to enhance professional development, identified through employee appraisals.
- Provide training for designated staff in the early identification, causes and appropriate management of mental health issues such as anxiety, depression, stress and change management.
Aim 2 – To provide support for employees experiencing mental health difficulties.
- To create an open environment where employees feel able to speak to their line management in the event of them experiencing mental health problems.
- To encourage employees to look after their mental wellbeing, for example through physical activity, stress reducing activities, financial management or social events; and to support them as is reasonably practical to do so.
- Ensure that individuals who suffer from mental health problems are treated fairly and consistently.
- Manage return to work for those who have experienced mental health problems and in cases of long term absence put in place, where possible, a phased return to work.
- Ensure employees are aware of support that can be offered such as the SHOUT mental health support line.
- Treat all matters relating to individual employees and their mental health problems in the strictest confidence and share on a need to know basis only with the consent of the individual concerned.
Communication
- All employees will be made aware of the wellbeing policy. This will sit as part of the H&S policy and will form part of the induction pack for new starters.
- Regular updates will provided to all employees via their line management.
Review and Monitoring
- Employees participating in any mental wellbeing activities will be asked for their feedback.
- Senior Management will be responsible for reviewing the wellbeing policy.

A Crofts CEO, September 2023

Your Product – End of Life Cycle & Recycling Policy

Crofts & Assinder Ltd is committed to reducing its environmental impact and will strive to continually improve its environmental performance by continually evaluating its operating methods and always looking for more environmentally friendly alternatives.
A core area of this approach is to educate customers on the disposal of Crofts & Assinder’s products at the end of their life cycle or usage.
Crofts & Assinder’s handles, knobs, hinges, castors, and other items are all made from metal (iron, steel, Mazak (zinc), aluminium or brass), and are made up of recyclable material. As such, we recommend that these items are disposed of in an environmentally friendly manner.
All iron, steel, Mazak (zinc), aluminium and brass products are made from recyclable materials and can be disposed of in an environmentally friendly manner. We recommend that this is done either through your local household recyclable waste collection service or by being taken to and disposed of at your local municipal waste site where these products can often be placed in recycled metal collection containers/bins.
Please note that fixing screws/bolts are also made of recyclable materials and can also be disposed of in an environmentally friendly manner. Again, we recommend that this is done either through your local household recyclable waste collection service or by being taken to and disposed of at your local municipal waste site where these products can often be placed in recycled metal collection containers/bins.
In addition, all packaging used in Crofts & Assinder products including, cardboard boxes, product bags and outer box banding is also made from recyclable materials and can be disposed of in an environmentally friendly manner. Again, we recommend that this is done either through your local household recyclable waste collection service or by being taken to and disposed of at your local municipal waste site in plastic recycling.
Alternatively, if you are unable to do this, you can send your redundant hardware back to us and we can dispose of your redundant hardware for you.
Crofts & Assinder will review this policy on an annual basis and in line with the Company’s Environmental Management System.

A Crofts CEO, September 2023