Ethical Commitment

The Ethical Trading Initiative Base Code

As part of our Corporate Social Responsibility, Whispering Smith adheres to the terms of the below ethical trading policy:
after it, how long we need it for, and what your rights are.

1. Employment is freely chosen
1.1 There is no forced, bonded or involuntary prison labour.
1.2 Workers are not required to lodge “deposits” or their identity papers with their employer, and are free to leave their employer after reasonable notice.

2. Freedom of association and the right to collective bargaining is respected
2.1 Workers, without distinction, have the right to join or form trade unions of their own choosing and to bargain collectively.
2.2 The employer will adopt an open attitude towards the activities of trade unions and their organisational activities.
2.3 Workers’ representatives will not be discriminated against and have the access they need to carry out their representative functions in the workplace.
2.4 Where the right to freedom of association and collective bargaining is restricted under law, the employer will facilitate, and not hinder, the development of parallel means for independent and free association and bargaining.

3. Working conditions are safe and hygienic
3.1 A safe and hygienic working environment shall be provided, bearing in mind the prevailing knowledge of the industry and of any specific hazards. Adequate steps shall be taken to prevent accidents and injury to health arising out of, associated with, or occurring during the course of work, by minimising, so far as is reasonably practicable, the causes of hazards inherent in the working environment.
3.2 Workers shall receive regular and recorded health and safety training, and such training shall be repeated for new or reassigned workers.
3.3 Access to clean toilet facilities and to potable water, and, if appropriate, sanitary facilities for food storage shall be provided.
3.4 Accommodation, where provided, shall be clean, safe, and will meet the basic needs of the workers.
3.5 The company observing the code shall assign responsibility for health and safety to a senior management representative.

4. Child labour shall not be used
4.1 There shall be no new recruitment of child labour.
4.2 Companies shall develop, or participate in and contribute to, policies and programmes which provide for the transition of any child found to be performing child labour to enable her or him to attend and remain in quality education until no longer a child; “child” and “child labour” being defined in the Modern Slavery Act.
4.3 Children and young persons under 18 shall not be employed at night or in hazardous conditions.
4.4 These policies and procedures shall conform to the provisions of the relevant ILO standards.

5. Living wages are paid
5.1 Wages and benefits paid for a standard working week meet, at a minimum, national legal standards or industry benchmark standards; whichever is higher. In any event, wages should always be enough to meet basic needs and to also provide some discretionary income.
5.2 All workers shall be provided with written and understandable information about their employment conditions in respect to wages before they enter employment, and about the particulars of their wages for the pay period concerned each time that they are paid.
5.3 Deductions from wages as a disciplinary measure shall not be permitted, nor shall any deductions from wages not provided for by national law be permitted, without the expressed permission of the worker concerned. All disciplinary measures should be recorded.

6. Working hours are not excessive
6.1 Working hours shall comply with national laws and benchmark industry standards; whichever affords greater protection.
6.2 In any event, workers shall not, on a regular basis, be required to work in excess of 48 hours per week and shall be provided with at least one day off for every 7 day period on average. Overtime shall be voluntary, shall not exceed 12 hours per week, shall not be demanded on a regular basis and shall always be compensated at a premium rate.

7. No discrimination is practised
7.1 There is to be no discrimination in hiring, compensation, access to training, promotion, termination or retirement based on race, caste, national origin, religion, age, disability, gender, marital status, sexual orientation, union membership or political affiliation.

8. Regular employment is provided
8.1 To every extent, work performed must be on the basis of a recognised employment relationship which is established through national law and practice.
8.2 Obligations to employees under labour or social security laws and regulations arising from the regular employment relationship shall not be avoided through the use of labour-only contracting, subcontracting, or home-working arrangements, or through apprenticeship schemes where there is no real intent to impart skills or provide regular employment, nor shall any such obligations be avoided through the excessive use of fixed-term contracts of employment.

9. No harsh or inhumane treatment is allowed
9.1 Physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation shall be prohibited.


The provisions of this code constitute minimum and not maximum standards, and this code should not be used to prevent companies from exceeding these standards. Companies applying this code are expected to comply with national and other applicable law and, where the provisions of law and this Base Code address the same subject, to apply that provision which affords the greater protection.

Please note:

We have made every effort to ensure that this translation of the ETI Base Code is as complete and accurate as possible. However, please note that it is the English language document which should be treated as the official version.

1. Overview Document – Explaining GDPR in relation to you and Ruler

2. Revised Terms & Conditions

3. Revised Privacy Notice