Devold's Sourcing Principles

This document is relevant for Devold of Norway and its wholly owned subsidiaries, and suppliers to these companies. It is also relevant to partly owned companies, if, and to the extent, approved by the governing bodies for such companies, and subsequently to their suppliers.

People lie at the heart of Devold – both those we have chosen and those who choose us. For over 170 years, our very foundation has been that everyone working for Devold should have decent jobs. Today, this commitment covers the full length of our supply chain. 

Devold is committed to conducting our business with integrity, and selecting suppliers who share our commitment to upholding human rights, animal welfare, reducing environmental impact, and compliance. In turn, our supplier partners are expected to adhere to standards consistent with Devold’s Sourcing Principles throughout their operations and upstream supply chain delivering goods and services to Devold. 

Suppliers must ensure that their operations are compliant with applicable laws, regulations, legal agreements and permits relevant to the activities and geographic locations of their operations.

The Transparency Pledge

1.1. Devold is committed to transparency and will publish data and information on our own operations and the supplier partners we work with so customers and stakeholders can see our progress. To achieve this objective, Devold will share supply chain data in a way that is accessible and collaborative. Supplier agrees to provide and keep updated supply chain data relevant to Devold’s products, on Devold’s template which we upload to the Open Supply Hub (OS Hub) biannually. Any omissions or refusals to share information will impact the onboarding process.

Due diligence process

2.0. Devold and Supplier share a commitment to respecting human rights as a standard of conduct. This means to prevent and address harms to people within their supply chains.

2.1. To achieve this objective, Devold and Supplier agree to establish and maintain a human rights due diligence process, reasonably adapted to the specific human rights risks connected to their operations and supply chain relationships, consistent with the United Nations Guiding Principles on Business and Human Rights and the OECD Due Diligence Guidelines. Such due diligence will be preventative, risk-based, and ongoing.

Note: This entails each party setting priorities, addressing the most pressing issues first, without portraying a fictional representation that everything is perfect. It is the outcomes (or results) for people affected directly or indirectly by our activities, of this process that are relevant, in specific cases and/or over time.

2.2. Supplier shall disclose information on all matters relevant to the human rights due diligence process in a timely, transparent, and accurate fashion to Devold.

2.3. Due diligence will also require Devold to provide support for and participate in remediation where appropriate and necessary, in particular where we caused or contributed to an adverse impact.

Labour standards

2.4. Devold acknowledges that most Codes of Conduct overlap and is committed to using the ETI Base Code, an internationally recognised collaborative code of labour practice, in our own operations and in our supply chain. The ETI Base Code is an integral part of this Agreement with Supplier. Where there is a discrepancy between the provisions of applicable local laws and regulations and these principles, the one that offers the greatest protection for workers shall be applied.

2.5. Further to this, Supplier shall abide by the Employer Pays Principle: No workers, including domestic or foreign migrant workers, shall pay for a job (based on the ILO definition of recruitment fees), irrespective of where and how they are recruited. The cost of recruitment shall be borne by the employer.

2.6. Devold and Supplier share a commitment to agree to, abide by, and communicate these standards through the supply chain.

2.7. As a preventive safety measure, Supplier will, if relevant to source from countries or regions where the International Accord for Health and Safety in the Textile and Garment Industry is operational, commit to it, and to only source from factories participating in the Accord. Supplier is requested to provide us with a copy of the commitment form to the Accord before production commences.

2.8 If Devold’s due diligence determines Supplier requires assistance to comply with the labour standards, Devold shall employ commercially reasonable efforts to provide such assistance, which may include supplier training, upgrading facilities, and strengthening management systems. Devold’s assistance shall not be deemed a waiver by Devold of any of its rights, claims or defences under this Agreement or under applicable law.

2.9. Unauthorized subcontracting is prohibited. If supply chain changes are necessary, Supplier must inform Devold’s sourcing team and obtain approval before commencing production. Such approval is also subject to Supplier providing necessary environmental documentation to Devold.

Responsible purchasing practices  

2.10. Devold will treat Supplier fairly and with respect and will communicate with Supplier clearly and promptly throughout our relationship.

2.11. Devold commits to support Supplier’s compliance with the labour standards by engaging in responsible purchasing practices. Devold recognizes that our purchasing practices can either improve the human rights performance of our supply chains or exacerbate and compound adverse human rights impacts for workers.

2.12. Devold commits to improving alignment across our teams and business units on relevant aspects of human rights and procurement and to assign oversight and responsibility for the human rights performance of our supply chain to our senior management and executive board.

2.13. Devold and Supplier agree to seek feedback from stakeholders who are or may be impacted, to understand the effectiveness of their due diligence efforts. Upon request, Supplier agrees to participate in anonymously rating Devold's purchasing practices through Buying Better, identifying both those that are working well and those that need improvement.

Assessment of labour standards

2.14. While Devold’s due diligence efforts will concentrate on our strategic suppliers, we reserve the right to monitor suppliers based on our risk assessment at any time. These assessments with enable us to work with our suppliers to improve their performance.

2.15. Our selected first-tier production suppliers are required to undergo an annual assessment of labour standards. Devold acknowledges the limitations of external assessments in uncovering concerns in the workplace, and will therefore accept and prefer the Social & Labor Convergence Program’s (SLCP) verified assessments or the Better Work assessments (2-year cycle), instead of conducting our own proprietary audit. Where these are not operational, first-tier production sites will be assessed against the ETI Base Code, on a semi-announced basis within an audit window. Devold reserves the right to conduct unannounced audits. Devold will pay for social audits it schedules directly. Devold may consider accepting recent audits or assessment by another brand on a case-by-case basis.

Note: A first-tier production supplier is defined as producing whole/finished products carrying a Devold label or are identifiable as a Devold product.

Provide access to whistleblowing and grievance mechanisms

2.16. Supplier agrees to set up a function where workers and others affected by its business can report misconduct anonymously. Supplier is expected to have a user-friendly system in place to manage grievances.

Responsible exit

2.17. If it is established that Supplier is unwilling or unable to improve conditions deemed necessary by Devold to meet requirements in this Agreement, if Supplier or any of its sub-suppliers have committed a substantial or repeated breach of the requirements in this Agreement, Devold is entitled to terminate the business relationship and the Agreement with Supplier.

2.18. In any termination of this Agreement by Devold, whether due to a failure by Supplier to comply with this Agreement or for any other reason (including the occurrence of a force majeure event or any other event that lies beyond the control of the parties), Devold shall (i) consider the potential adverse human rights impacts and employ commercially reasonable efforts to avoid or mitigate them; and (ii) provide reasonable notice to Supplier of its intent to terminate this Agreement.

Termination of this Agreement shall be without prejudice to any rights or obligations accrued prior to the date of termination, including, without limitation, payment that is due for acceptable goods produced by Supplier pursuant to Devold’s purchase orders before termination.

Disclaimer

2.19. Devold does not have the authority and disclaims any obligation to control (i) the manner and method of work done by Supplier, (ii) implementation of safety measures by Supplier, or (iii) employment or engagement of employees and contractors or subcontractors by Supplier. The efforts contemplated by this Agreement do not constitute any authority or obligation of control. They are efforts at cooperation that leave Devold and Supplier each responsible for its own policies, decisions, and operations. Devold and Supplier remain independent and are independent contractors. Nor are they joint employers, and they should not be considered as such.

Type 1 ecolabels

3.0. Supplier acknowledges that meeting the underlying criteria (no certification required) of the EU Ecolabel or an equivalent Type 1 ecolabel throughout the Agreement designates it as a strategic supplier to Devold. Devold intends to increase volumes with suppliers that meet these criteria and may shift volumes from those that do not.

Note: Type 1 ecolabel (ISO 14024) is a third-party verification of a product based on a number of criteria involved in the environmental impact of a product or material throughout its life-cycle. It covers all relevant environmental aspects and has absolute requirements. The certification demonstrates that the products (or services) are “best-in-class” in terms of environmental performance, compared to products in the same category. These life-cycle-based ecolabels allow the use of single-issue ecolabels, such as Oeko-Tex Standard 100, to document the criteria where they match.

EU is advocating its official ecolabel, the EU Ecolabel, and equivalent Type 1 ecolabels, such as the Nordic Swan Ecolabel or GOTS, to contribute to the political objectives of a climate neutral, clean, circular economy and a toxic-free environment.

3.1. Supplier agrees to provide necessary information to Devold on the criteria of the EU Ecolabel and/or the Nordic Swan Ecolabel that include Supplier’s operations or input materials to Devold. If the information is deemed confidential, Supplier may submit it directly to the relevant ecolabelling secretariat for verification.Øverst i skjemaet

Carbon emissions  

3.2. Supplier shall continuously improve its energy management and efficiency. Supplier shall have no use of coal on-site to produce heat and/or electricity in any facilities.

3.3. Supplier agrees, upon request, to disclose information about its Scope 1 and Scope 2 emissions and energy sources to Devold.

3.4. Devold expects Supplier to take active steps towards meeting upcoming requirements in institutional tenders, which include i) having an energy management system (certification not required), (ii) measuring, monitoring, and having an improvement plan for carbon emissions, and (iii) being transparent on carbon emissions.

4.0. Devold commits to do due diligence on animal health and welfare and farming methods when selecting countries and regions from which we source wool. If the circumstances allow for direct sourcing from wool growers without significant logistical or other constraints, Devold will opt for such partnerships.

Note 1: Invited merino growers in New Zealand, with whom we have direct contracts, are required by Devold to be certified under the New Zealand Farm Assurance Program (NZFAP). These selected growers who meet our strict requirements are part of our quality strategy “Sheep to Shop”, with traceability of the wool from the farm of origin to the final garment (information provided on the hang tag of the garment).

Note 2: The Norwegian wool industry has introduced a mandatory animal welfare program for sheep with regular visits by veterinarians, and economic sanctions (1 NOK/kg) imposed if the requirements in the program are not followed and met.

Note 3: Our supplier’s merino wool grower in Uruguay (for our protective workwear), is GOTS- and Responsible Wool Standard-certified.  

Note 4: Devold’s partially owned company, Tova, sources wool from local nomadic families in Mongolia. The animal husbandry has a high ethical standard; they heard the flocks and dwell together with the animals.

4.1. Devold does not accept mulesing.

Note: Recall point 4.0. Mulesing is not practiced and/or is prohibited by law in the countries where Devold and its partially owned companies source wool.

4.2. Supplier agrees to uphold the so-called ‘Five Freedoms and Five Provisions for promoting farm animal welfare’:

Note: The absence of these negative states does not in and of itself generate positive experiences for the animals.

4.3. Aware that the Five Freedoms do not capture current knowledge of what is necessary for animals to have “lives worth living”, Supplier will provide opportunities for the animals to behave in ways they find rewarding. 

4.4. The raw material for leather – animal hides – should be by-products of the meat industry.

Note: Devold’s partially owned company, Tova, uses leather from cattle in most of their wool slippers.

Trade sanctions

5.0. Devold and Supplier will respect international trade boycotts by avoiding supply chain business partners that are subject to trade boycotts by the UN or relevant national authorities.

Anti-bribery and anti-corruption

5.1. Supplier shall not engage or be complicit in, or encourage any activity, practice, or conduct that would be an offence under, or breach of, any applicable laws relating to corruption and bribery.

5.2. Supplier shall not initiate or encourage facilitation payment on behalf of Devold, whether the payment is made directly or indirectly.

5.3. Supplier will not cause or be part of any breach of applicable general or special competition laws and regulations, such as illegal cooperation on pricing, illegal market sharing or any other behaviour that is in breach of relevant competition laws or regulations.

Gifts, Hospitality and Expenses

5.4. Devold does not allow any gifts, favours, or hospitality where giving or accepting them could influence business decisions, violate any local laws or the policies of the recipient company, or cause others to perceive such influence as violations.

5.5. Hospitality, such as social events, meals or entertainment may be offered if there is a clear business reason, and the costs are kept within reasonable limits. Travel, accommodation, and other expenses for individuals representing Devold, will always be paid by Devold, unless other arrangements are agreed in contract. Gifts, hospitality, expenses, or other favours shall not be offered or received in connection with contract bidding, evaluation, or award.

Data protection

5.6. Supplier shall comply with all obligations under applicable data protection laws and regulations, including regulations on handling and storage of personal information. Supplier will ensure all personal data is deleted or anonymized when no longer necessary for the relevant purpose the data was collected.

Intellectual property

 5.7. Any confidential and proprietary information, including intellectual property such as drawings, patterns, trademarks, and other unregistered know-how, provided by Devold to Supplier remains the sole property of Devold. Supplier must keep this information confidential and refrain from disclosing it to competitors or third parties without prior written authorization from Devold. Supplier is responsible for securely storing and protecting this information, ensuring that copies cannot be made without consent.

5.8. Confidential and proprietary information, along with intellectual property rights, may only be used as agreed upon in writing with Devold and in accordance with the intended purpose.

5.9. Upon termination of the agreement or at Devold’s request, Supplier must return all confidential and proprietary information, including intellectual property rights, to Devold. Any electronically stored confidential information must be promptly deleted.

5.10. Supplier must only disclose Devold’s confidential and proprietary information to employees who require it to fulfil the services agreed upon with Devold.

5.11. Supplier must ensure that all employees handling Devold’s confidential and proprietary information treat it as such and maintain its confidentiality.

Supplier Commitment Form

We confirm receipt, reading, and understanding of Devold’s Sourcing Principles. We commit to adhere to standards consistent with the principles outlined for Suppliers in this document. We assume responsibility for informing all related subsidiaries and subcontractors about these standards to ensure their awareness and possibility to comply.

We acknowledge that the Sourcing Principles are drafted and valid in English. Any alternative versions of this document are considered translations of convenience only, with the English version prevailing in cases of discrepancy.

Please sign and submit only this page to Devold. Thank you. 

Version: 1.3. April 2024