Code of Conduct

Last updated 14-02-2024

Actona Group is committed to upholding high environmental and ethical trade practices. Furthermore, we have a very clear position on product safety. This supplier Code of Conduct outlines our expectations. We expect our suppliers to embrace and work with us towards these standards to help us improve the environmental and social impacts through our supply chain. We look to collaborate with our suppliers to share knowledge and experience to achieve the highest level possible.


Actona Group is working actively with Environmental objectives as an integrated part of the Sustainability-oriented corporate strategy “Towards Sustainable business”.

Protection of the Environment

Suppliers must take necessary measures to avoid environmental degradation.

Suppliers should assess significant environmental impact of operations and establish effective policies and procedures that reflect their environmental responsibility. They will see to implement adequate measures to prevent or minimize adverse effects on the community, natural resources, and the overall environment.


Suppliers must ensure that goods are produced and delivered without exploitation or abuse of individuals or any living being, and that human and animal rights are respected throughout their operations and supply chains.

Suppliers must conduct their business with the highest level of integrity and ethics and prohibiting any form of corruption and bribery. Furthermore, Suppliers must comply with all applicable anti-corruption laws and regulations.

Product safety 

Suppliers must do their utmost to ensure that all products are carefully tested for potential loads and events. The goods must be tested on an exceptional scope in cooperation with suppliers, public and non-public laboratories, test stations, and technological institutes in order to assure a high-quality safety of all products.


Actona Group is a member of the Business Social Compliance Initiative BSCI Universal Declaration of Human Rights.
Social responsibility is at the core of BSCI where social and environmental performance goes hand in hand with economic considerations.

The BSCI Code of Conduct refers to international conventions:

  • Children’s Rights and Business Principles
  • Gender Dimensions of the UN Guiding Principles on Business and Human Rights
  • UN Guiding Principles on Business and Human Rights
  • OECD Guidelines
  • UN Global Compact
  • ILO Conventions

The Rights of Freedom of Association and Collective Bargaining

Suppliers* shall:

  • Respect the right of workers to form and join unions in a free and democratic way
  • Not discriminate against workers because of trade union membership
  • Respect workers’ right to bargain collectively
  • Ensure meaningful representation of all workers, without distinction whatsoever and irrespective of gender.

Suppliers shall furthermore not prevent workers’ representatives from having access to workers in the workplace or from interacting with them.

When operating in countries where trade union activity is unlawful or where free and democratic trade union activity is not allowed, suppliers shall respect this principle by allowing workers to freely elect their own representatives with whom the company can enter into dialogue about workplace issues.

No Discrimination

Suppliers shall treat all workers with respect and dignity and ensure that workers are not subject to any form of violence, harassment, and inhumane or degrading treatment in the workplace, as well as threats of violence and abuse, including corporal punishment, verbal, physical, sexual, economic or psychological abuse, mental or physical coercion, or other forms of harassment or intimidation.

The supplier shall identify and understand the possible grounds for discrimination in their specific context, and not discriminate or exclude persons based on sex, gender, age, religion, race, caste, birth, social background, disability, ethnic and national origin, nationality, membership in unions or any other legitimated organizations, political affiliation or opinions, sexual orientation, family responsibilities, marital status, pregnancy, diseases, or any other condition that could give rise to discrimination, and establish disciplinary procedures in writing and explain them verbally to workers in terms and language which they understand. The disciplinary measures must be in line with national legislation.

The supplier must provide gender-sensitive and equal opportunities and treatment throughout recruitment and employment and verify that workers are not harassed, disciplined, or retaliated upon for reporting issues on any of the grounds listed above.

Fair Remuneration

Suppliers observe this principle when respecting the rights of the workers to receive fair remuneration sufficient to provide them with a decent living for themselves and their families, as well as the social benefits legally granted, without prejudice to the specific expectations set out hereunder.

Suppliers shall as a minimum comply with wages mandated by governments’ minimum wage legislation or industry standards approved on the basis of collective bargaining, whichever is higher.

Wages are to be paid in a timely manner, regularly, and fully in legal tender. Partial payment in the form of allowance “in kind” is accepted in line with ILO specifications. The level of wages is to reflect the skills and education of workers and shall refer to regular working hours.

Deductions will be permitted only under the conditions and to the extent prescribed by law or fixed by collective agreement.

Decent Working Hours

Suppliers observe this principle when they ensure that workers are not required to work more than 48 regular hours per week, without prejudice to the specific expectations set out hereunder. However, the BSCI recognizes the exceptions specified by the ILO.

Applicable national laws, industry benchmark standards, or collective agreements are to be interpreted within the international framework set out by the ILO.

In exceptional cases defined by the ILO, the limit of working hours prescribed above may be exceeded, in which case overtime is permitted.

The use of overtime is meant to be exceptional, voluntary, paid at a premium rate of no less than one and one-quarter times the regular rate and shall not represent a significantly higher likelihood of occupational hazards. Furthermore, suppliers shall grant their workers with the right to resting breaks every working day and the right to have minimum one day off every seven days, unless exceptions defined by collective agreements apply.

Occupational Health and Safety

Suppliers observe this principle when they respect the right to healthy working and living conditions of workers and local communities, without prejudice to the specific expectations set out hereunder. Vulnerable individuals such as - but not limited to - young workers, new and expecting mothers and people with disabilities, shall receive special protection.

Suppliers shall comply with occupational health and safety regulations or with international standards where domestic legislation is weak or poorly enforced.

The active co-operation between management and workers, and/or their representatives is essential in order to develop and implement systems towards ensuring a safe and healthy work environment. This may be achieved through the establishment of Occupational Health and Safety Committees.

Suppliers shall ensure that there are systems in place to detect, assess, avoid, and respond to potential threats to the health and safety of workers. They shall take effective measures to prevent workers from having accidents, injuries, or illnesses arising from, associated with, or occurring during work. These measures should so far reasonable aim at minimizing the causes of hazards inherent within the workplace.

Suppliers shall seek improving workers protection in case of an accident, including through compulsory insurance schemes.

Suppliers shall take all appropriate measures within their sphere of influence to ensure the stability and safety of the equipment and buildings they use. This includes residential facilities to workers, when these are provided by the employer as well as to protect against any foreseeable emergency.

Suppliers shall respect the workers’ right to exit the premises from imminent danger without seeking permission.

Suppliers shall ensure adequate occupational medical assistance and related facilities.

Suppliers shall ensure access to drinking water, safe and clean eating and resting areas, as well as clean and safe cooking and food storage areas. Furthermore, suppliers shall always provide effective Personal Protective Equipment (PPE) to all workers free of charge.

No Child Labour

Suppliers observe this principle when they do not employ, directly or indirectly, children below the minimum age of completion of compulsory schooling as defined by law, which shall not be less than 15 years, unless the exceptions recognized by the ILO apply.

Suppliers must establish dependable age-verification mechanisms as part of the recruitment process, which may not be in any way degrading or disrespectful to the worker. This principle aims to protect children from any form of exploitation. Special care is to be taken on the occasion of the dismissal of children, as they can move into more hazardous employment such as prostitution or drug trafficking. In removing children from the workplace, suppliers should in a proactive manner identify measures to ensure the protection of affected children. When appropriate, they shall pursue the possibility to provide decent work for adult household members of the affected children’s family.

Special Protection for Young Workers

Suppliers observe this principle when they ensure that young people do not work at night and that they are protected against conditions of work which is prejudicial to their health, safety, morals, and development, without prejudice to the specific expectations set out in this principle.

Where young workers are employed, suppliers should ensure that (a) the kind of work is not likely to be harmful to their health or development; (b) their working hours do not prejudice their school attendance, their participation in vocational orientation approved by the competent authority, or their capacity to benefit from training or instruction programs.

Suppliers shall establish the necessary mechanisms to prevent, identify, and mitigate harm to young workers with special attention to the access young workers shall have to effective grievance mechanisms and to Occupational Health and Safety training schemes and programs.

No Precarious Employment

Suppliers observe this principle when, without prejudice to the specific expectations set out in this chapter, (a) they ensure that their employment relationships do not cause insecurity and social or economic vulnerability for their workers; (b) work is performed on the basis of a recognized and documented employment relationship, established in compliance with national legislation, custom or practice and international labour standards, whichever provides greater protection.

Before entering into employment, suppliers are to provide workers with understandable information about their rights, responsibilities and employment conditions, including working hours, remuneration and terms of payment.

Suppliers should aim at providing decent working conditions that also support workers, both male and female, in their roles as parents or caregivers, especially with regard to migrant and seasonal workers whose children may be left in the migrants’ hometowns.

Suppliers shall not use employment arrangements in a way that deliberately does not correspond to the genuine purpose of the law. This includes, but is not limited to, (a) apprenticeship schemes where there is no intent to impart skills or provide regular employment, (b) seasonality or contingency work when used to undermine workers’ protection, and (c) labour-only contracting. Furthermore, the use of sub-contracting may not serve to undermine the rights of workers.

No Bonded, Forced Labour or Human Trafficking

Suppliers shall not engage in any form of servitude, forced, bonded, indentured, trafficked or non-voluntary labour.

Suppliers will risk allegations of complicity if they benefit from the use of such forms of labour by their suppliers.

Suppliers shall act with special diligence when engaging and recruiting migrant workers both directly and indirectly.

Suppliers shall allow their workers the right to leave work and freely terminate their employment provided that workers give reasonable notice to the employer.

Suppliers shall ensure that workers are not subject to inhumane or degrading treatment, corporal punishment, mental or physical coercion, and/or verbal abuse.

All disciplinary procedures must be established in writing and are to be explained verbally to workers in clear and understandable terms.

Protection of the Environment

Suppliers must implement a process- and risk-based environmental due diligence management system in their business practices, adjusted to the business model of the company. This can also be integrated into the overall due diligence management system.

The supplier must comply with national environmental legislation, or with international standards where national legislation is weak or poorly enforced. Furthermore, the supplier must identify the environmental impacts of their operations, and implement adequate measures to prevent, mitigate and remediate adverse impacts on the surrounding communities, natural resources, climate, and the overall environment.

Ethical Business Behaviour

Suppliers observe this principle when, and without prejudice to the goals and expectations set out in this chapter, they are not involved in any act of corruption, extortion or embezzlement, or any form of bribery. This includes, but does not confine to, the promising, offering, giving or accepting of any improper monetary or other incentive.

Actona Group has a zero-tolerance approach towards bribery and corruption and is committed to act professionally in all of its business dealings and relationships. Actona Group’s anti-bribery policy reflects our commitment to uphold all laws relevant to countering bribery and corruption. In particular, Actona Group and third parties acting on behalf of Actona Group, i.e. suppliers, distributors, officials etc., are committed to comply with the UK Bribery Act 2010.

Suppliers are expected to keep accurate information regarding their activities, structure and performance, and should disclose these in accordance with applicable regulations and industry benchmark practices.

Suppliers should neither participate in falsifying such information, nor in any act of misrepresentation in the supply chain.

Furthermore, they should collect, use and otherwise process personal information (including that from workers, suppliers, customers and consumers in their sphere of influence) with reasonable care. The collection; use and other processing of personal information is to comply with privacy and information security laws and regulatory requirements.

Reporting and Compliance 

By entering business with Actona Group, suppliers commit to compliance with this Supplier Code of Conduct. Suppliers must have a due diligence processes in place in order to ensure compliance from subcontractors.

Suppliers are required to:

  • Notify Actona Group immediately upon discovering any actual or suspected misconduct or violations of this Code of Conduct or applicable laws.
  • Co-operate in any investigations of reported violations and to take appropriate corrective action.
  • Accept independent audits and assessments to verify compliance with this Code of Conduct.
  • Maintain systems to track and report compliance with the Code of Conduct.

If a supplier fails to meet the requirements of the Actona Group Code of Conduct and if no solutions can be agreed upon and implemented within a reasonable amount of time, Actona Group may choose to halt current production, cancel corresponding contracts, suspend future contracts, and/or terminate the business relationship with the non-conforming supplier.

We encourage our suppliers to collaborate with us to improve performance – for any questions or reports of violations please contact us.