Rhenoflex Code of Conduct

Commitment to International Standards

Coats subscribes to a number of international standards and guidelines relevant to corporate responsibility and business conduct, including:
·      The United Nations (UN) Declaration of Human Rights;
·      The United Nations (UN) Convention on the Rights of the Child;
·      The International Labour Organisation (ILO) Eight Fundamental Conventions;
·      The Organisation for Economic Co-operation and Development (OECD) Guidelines for Multinational Enterprises; and
·      The Organisation for Economic Co-operation and Development (OECD) Convention on Combatting Bribery.

Principles and requirements of these standards and guidelines are incorporated into this code.

Ethical business conduct and fair dealing

All Coats’ employees must accept responsibility for maintaining and enhancing the Company’s reputation for integrity and fairness in its business dealings. In its everyday business transactions the Company must be seen to be dealing even-handedly and honestly with all its customers, consumers, suppliers, employees and others with whom the Company has a relationship. The foundations of this lie in all employees acting with honesty, integrity and fairness and being prepared to speak up when they feel this is not happening.

Conflicts of interest

Outside engagements – employees of the Company should not serve as an officer, director, employee, consultant or promoter of or have any financial interest in any organisation which is or becomes a supplier, customer or competitor of Coats, without the prior approval of the Group Chief Executive (GCE).

Related engagements – Coats does not permit nepotism. Where any relative (either by blood or marriage) of a Coats employee has a financial interest (for example, a shareholding or some other performance related incentive) in a customer or supplier, competitor or any other enterprise with whom Coats intends to do business, the prior approval of the GCE must be obtained. Similarly, if an employee becomes aware that Coats is already engaged in any such business relationship involving a relative then approval from the GCE must be obtained if that business relationship is to continue.

See the guidance note on conflicts of interest for further details (including the procedure to be followed where a relative has a non-financial interest in a customer, supplier, competitor or other enterprise with which Coats does or intends to do business). Separately, refer to the Coats Employment of Relatives Policy if you are considering recruiting or working with a relative.

Gifts and entertainment – employees of the Company must ensure that they deal with customers, suppliers and other business relationships in a way that avoids their independent judgement on behalf of the Company being influenced by personal advantage, or any appearance that this may be the case. All employees must adhere to our Gifts and Entertainment Policy.

Employees

Working conditions – the Company believes the human rights of its employees at work are an absolute and universal requirement.

Equal opportunities/no discrimination – in employment related matters (including recruitment, access to training and promotion, transfer, employment termination, discipline, compensation and benefits) decisions are made on the basis of the qualifications, performance record and abilities needed for the work to be undertaken, and relevant business circumstances.

The Company is committed to equal opportunities at work; employees should not engage in or support discrimination based on race, colour, language, caste, national origin, indigenous status, ethnic origin, sexual orientation, religion, disability, gender, marital status, union membership, political affiliation, or age.

Working environment and occupational health and safety – the Company is committed to providing a safe and healthy work environment and to ensuring, so far as it is reasonably practicable, the health, safety and welfare at work of its employees. The Company’s Health and Safety Policy is publicly available and a Health and Safety Management System is in place to coordinate the management of occupational health and safety across the Company.

Employees have a duty to take reasonable care of their own health and safety and that of others who may be affected by their acts or omissions. Employees must use all work items provided by the Company correctly, in accordance with their training and the instructions they received to use them safely.

Employees should not act contrary to what is expected in the ordinary course of employment (for example lending money to other employees).

Suppliers and contractors

The Company is committed to proactively encourage its suppliers and contractors to demonstrate responsible business behaviour and high standards of business conduct. Suppliers and contractors are required to adhere to the Coats Antibribery and Anti-corruption Policy and familiarise themselves with the applicable anti-corruption laws in each jurisdiction in which they conduct business on behalf of Coats.

Delegated authorities

The existence of an agreed authority delegation structure is an essential requirement for establishing an effective financial and operational control environment. The Company delegates the authority of the Board of Directors through its Delegated Authorities Policy. All business units are required to establish and maintain appropriate levels of authority to cover all items of asset value / expenditure and all transactions which need to be subject to management approval.

Integrity of Company financial records

The books and records of the Company must accurately reflect the nature of the underlying transactions and no undisclosed or unrecorded liabilities or assets shall be established or maintained. Books and records must be maintained in all respects according to law and the accounting principles, policies and procedures that the Company has adopted. The Company will not evade tax obligations and all taxable benefits which employees may receive will be listed and declared for tax purposes.

Protecting confidential information

Employees of the Company must ensure that confidential information is preserved and protected. Confidential information is that which is not generally known outside the organisation and either gives or could give the Company a competitive advantage or disadvantage or could lead to the loss of any existing competitive advantage if it became known to others or became known in the public domain. This kind of information may not be revealed to anyone outside of the organisation unless an appropriate confidentiality agreement is in place and such disclosure is necessary for business purposes. See our Confidential Information Policy for further details.

Protecting personal data

Employees of the Company must respect the privacy of others and ensure that they process personal data in accordance with Coats’ Data Protection Policy.

Political activities

The Company is not a political organisation. It neither supports political parties nor contributes to the funds of groups whose activities are calculated to promote party interests.

Compliance with this Business Code of Conduct

All employees are required to comply with this code and are personally responsible for doing so.
The Company’s Group Executive Team will ensure, so far as is reasonably practicable, that the principles and ethical values embodied in this code and associated policies are communicated to all employees of the Company.

Senior management are required to certify compliance with this code for the operations for which they have responsibility by obtaining a signed Ethics Code (including Code of Business Conduct and Managing Company Property) “Certification Form” annually from all supervisory staff under their responsibility.
Exceptions, if any, to the code should be approved by the GCE. Each business unit’s HR department should send details of exceptions, if any, to the Chief Human Resources Officer who will consolidate and present to the GCE, the list of exceptions.

Management will not be criticised for any loss of business resulting from adherence to this code. The Company undertakes that no employees will suffer as a consequence of bringing to the attention of senior management a breach or suspected breach of this code.

The Company’s Speak Up (Whistleblowing) Policy and process is in place to encourage the reporting of any non-compliance with this Business Code of Conduct and with the Ethics Code generally.
 
Coats Footwear by Rhenoflex
 
Coats is a world leader in thread manufacturing and structural components for apparel and footwear, as well as an innovative pioneer in performance materials. In 2022 Coats acquired Rhenoflex and Texon and as a result, Rhenoflex will now operate under the Coats Footwear Division.