Policy on Responsible Business Conduct

1. Applicability 

This Policy applies to all brands under Wheat A/S, Wheat Kids Clothing UK Ltd, Wheat Fashion Ltd and Wheat Norge NUF. 

Each entity is responsible for implementing this policy in accordance with applicable national legislation and regulatory requirements. 

This policy also applies to all employees and management of Wheat A/S, suppliers, subcontractors, business partners, own operations and supply chain activities.  

 

2. Purpose 

Wheat A/S is committed to conducting business in a responsible, ethical and transparent manner. This Policy establishes our overarching commitment to responsible business conduct across: 

  • Human rights and labour standards 

  • Environmental and climate impact management 

  • Chemical management and product integrity 

  • Ethical governance and business integrity 

  • Sourcing and supply chain management 

 

3. Commitment 

Wheat A/S commits to operate in accordance with: 

  • The OECD Guidelines for Multinational Enterprises on Responsible Business Conduct 

  • The UN Guiding Principles on Business and Human Rights 

  • The latest version of the Global Organic Textile Standard (GOTS)  

  • The latest version of the Global Recycled Standard (GRS) 

  • The latest version of the Responsible Wool Standard (RWS) 

  • The latest version of the FSC Core Labour Requirements (Appendix A) 

  • Applicable national and international laws 

We recognise that responsible business conduct is an ongoing process and requires continuous improvement. 

 

4. Human Rights and Labour Standards 

Wheat A/S respects internationally recognised human rights, including those expressed in The Universal Declaration of Human Rights and The ILO Core Conventions 

We commit to: 

  • Prohibit child labour and forced labour 

  • Prohibit discrimination and harassment 

  • Respect freedom of association and collective bargaining 

  • Promote fair working conditions 

  • Work towards closing living wage gaps 

  • Ensure access to grievance mechanisms 

These commitments apply to our own operations and our supply chain.  

 

5. Environmental and Climate Impact management 

Wheat A/S commits to map, measure and implement actions on its environmental and climate impacts across its operations and supply chain. Wheat’s environmental and climate impact areas are defined in the Environmental and Climate Policy and cover: 

  • Greenhouse gas emissions 

  • Energy type and use 

  • Water consumption, recycling and treatment 

  • Chemical use and management 

  • Natural habitats, ecosystems and biodiversity 

  • Animal welfare 

  • Circularity 

Our environmental commitments are supported by our Environmental and Climate Policy, and Environmental and Climate Process Manual.  

 

6. Sourcing and Supply Chain Management 

Wheat A/S recognises that the textile sector carries inherent risks related to labour, environment and chemical use. Wheat commits to: 

  • Conduct risk-based human rights and environmental due diligence 

  • Assess and monitor suppliers based on severity and likelihood of harm 

  • Prioritise the most severe human rights and environmental impacts 

  • Use leverage to prevent or mitigate adverse impacts 

  • Cooperate in remediation where we have caused or contributed to harm 

Our Supplier Code of Conduct defines minimum requirements, expectations and recommendations for suppliers. 

 

7. Due Diligence Commitment 

Wheat A/S commits to conducting ongoing, risk-based due diligence guided by:  

  • OECD Guidelines for Multinational Enterprises on Responsible Business Conduct 

  • UN Guiding Principles on Business and Human Rights 

  • OECD Due Diligence Guidance for Responsible Supply Chains in the Garment and Footwear Sector 

Due diligence at Wheat A/S: 

  • Covers own operations, where Wheat is directly accountable, and the supply chain, where Wheat has influence but no direct operational control 

  • Is proportionate to risk and business context 

  • Prioritises the most severe human rights and environmental impacts 

  • Includes stakeholder engagement 

  • Is documented and monitored 

Where Wheat A/S has caused or contributed to adverse impacts, we shall provide or cooperate in remedy. And where Wheat A/S is directly linked through business relationships, we shall use leverage to prevent or mitigate harm. 

Processes, implementation and responsibilities are defined in Wheat’s Due Diligence Process Manual.  

 

8. Ethical Business Conduct and Governance 

Wheat A/S commits to conducting business with integrity, including: 

  • Zero tolerance for corruption and bribery 

  • Responsible lobbying practices 

  • Transparency in reporting 

  • Protection of confidential information 

  • Respect for data privacy 

These commitments are detailed in our Code of Ethics and related governance policies. 

 

9. Responsible Business Relationships 

Wheat A/S seeks to ensure that its suppliers and other business partners operate in a manner consistent with internationally recognised standards on human rights, labour rights, environmental protection and ethical business conduct. 

Wheat A/S does not enter into or maintain business relationships with: 

  • Entities subject to EU sanctions or trade restrictions 

  • Entities credibly alleged to be contributing to forced labour, corruption, conflict financing or illegal land use 

  • Entities credibly alleged to be operating in violation of international humanitarian or human rights law 

Where Wheat A/S engages with suppliers or partners located in conflict-affected or high-risk areas (as identified by the European Union, OECD or other internationally recognised sources), enhanced due diligence shall be carried out prior to engagement. 

 

9.1 Enhanced due diligence may include: 

  • Independent third-party social and environmental audits 

  • Third party verified certification schemes  

  • Evidence and records of functioning grievance mechanisms 

  • Records of training programs 

  • Time-bound corrective action plans (CAPAs) 

  • Demonstrated progress towards living wages 

Engagement in such regions shall only proceed where Wheat A/S determines that risks can be adequately mitigated and that the relationship does not contribute to adverse human rights or environmental impacts. 

Where violations are identified, Wheat A/S will seek remediation through time-bound corrective action plans prior to considering suspension or termination of the relationship, in accordance with OECD Due Diligence Guidance. 

 

10. Stakeholder Engagement 

Wheat A/S engages relevant stakeholders to strengthen responsible business practices, including: 

  • Employees 

  • Customers  

  • Suppliers 

  • Workers in our supply chain 

  • Certification bodies 

  • Relevant civil society stakeholders 

We maintain grievance mechanisms to allow concerns to be raised confidentially. 

Related documents: Wheat’s Stakeholder Engagement Policy and Procedure 

 

11. Governance and Oversight 

The Board of Directors holds ultimate oversight responsibility for this Policy. 

Executive Management is accountable for implementation. 

The Impact Manager coordinates operational execution and reporting. 

This Policy is reviewed annually by management and Board and updated as necessary. 

 

12. Related Documents 

This Policy is supported by Wheat’s: Code of Conduct, Code of Ethics, Human Rights Policy, JEDI Commitment, Due Diligence Commitment, Due Diligence Process Manual, Environmental and Climate Policy, Environmental and Climate Process Manual, Wage Policy, Grievance Procedure, Stakeholder Engagement Policy and Procedure  

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Annex A: FSC Core Labour Requirements 

This appendix forms part of the Policy on Responsible Business Conduct and constitutes Wheat A/S’s policy statement on the FSC core labour requirements, as required by the FSC Chain of Custody standard (FSC-STD-40-004). The requirements are based on the ILO Declaration on Fundamental Principles and Rights at Work. 

 

A.1 No child labour 

Wheat A/S shall: 

  • Not employ any person below the age of 15, or below the minimum age set by national law where this is higher 

  • Not assign workers below the age of 18 to hazardous work, night work or any work that may harm their health, safety or development, or interfere with their education 

  • Verify the age of all new employees at recruitment and keep records of this verification 

Supplier requirements: Supplier Code of Conduct, Section 1.2. 

 

A.2 No forced or compulsory labour 

Wheat A/S shall ensure that: 

  • All employment is voluntary, and employees are free to terminate their employment with notice in accordance with their contract and applicable law, without penalty 

  • Employees retain full control of their identity documents, passports, work permits and other personal documents 

  • No recruitment fees, deposits or withheld wages are used to bind employees to their employment 

  • Overtime is voluntary and compensated in accordance with applicable law and agreements 

  • No employee is subject to threats, coercion, debt bondage or restrictions on their freedom of movement 

Supplier requirements: Supplier Code of Conduct, Sections 1.3 and 1.5. 

 

A.3 No discrimination in employment and occupation 

Wheat A/S shall ensure that: 

  • Decisions on recruitment, remuneration, training, promotion, discipline and termination are based solely on ability, qualifications and performance 

  • No employee or applicant is discriminated against on the basis of gender, age, ethnicity, national or social origin, religion, political opinion, disability, sexual orientation, gender identity, pregnancy or parental status, marital status, trade union membershipor any other status protected by law 

  • Equal pay is provided for work of equal value 

See also: Code of Ethics, Sections 5 and 6. Supplier requirements: Supplier Code of Conduct, Sections 1.6 and 1.7. 

 

A.4 Freedom of association and the right to collective bargaining 

Wheat A/S shall: 

  • Respect the right of all employees to form and join trade unions of their own choosing and to bargain collectively, without prior authorisation from Wheat A/S 

  • Not interfere with, discriminate against or retaliate against employees for exercising these rights or for acting as employee representatives 

  • Respect the role of elected employee representatives and allow them reasonable time and access to carry out their duties 

Supplier requirements: Supplier Code of Conduct, Section 1.8. 

 

A.5 Safe and healthy working environment 

Wheat A/S shall: 

  • Provide a safe and healthy working environment in compliance with applicable national legislation in each country of operation 

  • Carry out and regularly review a workplace risk assessment (APV in Denmark, or the equivalent in other countries) 

  • Maintain procedures for accidents, fire and emergencies, and train employees in them 

  • Record incidents and near-misses and implement corrective actions 

See also: Code of Ethics, Section 7. Supplier requirements: Supplier Code of Conduct, Sections 1.10 and 1.12. 

A.6 Implementation and monitoring 

  • The Impact Manager is responsible for implementing this appendix and for maintaining Wheat A/S’s FSC self-assessment of the core labour requirements 

  • Compliance in own operations is assessed at least annually; any deviations are addressed through documented, time-bound corrective actions 

  • Compliance in the supply chain is monitored through third-party social audits and corrective action plans (CAPAs), as set out in the Supplier Code of Conduct 

  • Concerns can be raised confidentially and without fear of retaliation through Wheat’s whistleblower channel and Grievance Procedure 

  • This appendix is reviewed annually together with the Policy