Corporate Responsibility

It’s our responsibility to ensure we manage our production schedule efficiently to ensure we don’t place unrealistic pressure on our manufacturing partners. Our production is planned a year in advance to ensure our factories have the space and staff to manage our orders, and can avoid the use of overtime. Workloads at factories are closely monitored and reasonable lead-times of 90-125 days are given, so use of subcontractors is rare in Max production.

Workers must be provided at least one day off for every 7-day period, and regular working hours must not exceed 48 hours per week. All overtime must be voluntary and cannot total more than 12 hours per week. This is a minimum requirement and doesn’t replace national or local laws if this provides greater protection.

Use of overtime required continued improvement for most of our factories in the past year, due to the nature of the clothing business where there are peak times in peak seasons, and prior to Chinese New Year factory closures. Often workers request to do overtime and prefer to work longer hours so they can take longer breaks to travel home to see family. We take an open view to overtime as long as it’s at a reasonable level, and we only require continued improvement in this area.

If there is an issue with wages or excessive use of overtime, we require the factory to resolve the issue within three months.

We have a responsibility to provide a safe and healthy working environment for all workers producing our garments – this is a non-negotiable for Max. This includes fire safety, building safety, working environment, and workers health and welfare.

Our suppliers must provide a safe and hygienic working environment for all staff, with adequate ventilation and light. Safe drinking water is to be provided at no extra charge, along with safe storage for food items. Workers must have access to hygienic toilet facilities, and if accommodation is provided it is vital this is safe, clean and meets basic needs.

Training in health and safety must be provided regularly to all workers, and it’s essential all new workers are given this training before they commence work. A record of this training is to be kept on file, and a senior manager must monitor and control this process. Training includes fire prevention and steps to prevent accidents and injury. Non-compliance in this area can usually be resolved in a reasonably short time. Training and continual monitoring by Max staff is key to making improvements.

We are committed to ensuring that all workers are employed on a voluntary basis, and are free to leave with acceptable notice. The employer is not allowed to hold onto identity papers or accept any deposits from workers.

Our factories are operating in accordance with the Modern Slavery Act 2015 in the UK, and the Slavery Act of 2014 in the USA.

Ensuring wages are enough to meet the basic needs of workers and their families, and provide extra for additional needs is an ethos we all buy into at Max. Wages, at a minimum, must meet the legal requirements of that region or country. Any overtime must be paid at least at a rate that meets minimum requirements for local or national laws.

Workers are to be provided with written confirmation of their remuneration prior to commencement of work, and information on how and when this will be paid. Deductions from wages are not permitted without permission from the worker concerned.

All our factories are required to pay the minimum wage legislated by Chinese Government and local laws, and some chose to pay above minimum wage. This is covered in our audit and we have never required any corrections in this this area.

All Max manufacturing is done in China. The Chinese Government continuously monitors wage rates. Minimum wages in China have increased 33% in the last 5 years (Source Qualspec Oct 18), and average wage rates in Max supplier factories have increased at the same pace over this time period.

Temporary, contract and migrant workers are traced through our auditing process. These workers have the same rights as full time employees, and adequate records must be kept so the auditor can assess how much of the work force falls under this category. This is monitored by both the Production and Audit Managers. This is at a very low level in our factories, however if this were to change, the Audit Manager would visit the factory to ascertain why this has increased. We take an open view to using temporary or contract workers, as there are many factors that can influence their use (eg) peak volume times. A factory would not be penalised for using these workers, however Max must feel confident the workers are not being taken advantage of, and this is assessed through audits and regular visits to the factories.

We will not tolerate any use of Child Labour to manufacture our garments, or produce any components of these garments, including fabric and trims. The UN convention (138) outlines the minimum age a child shall be allowed to work and this is broken down into light work, basic minimum age, and hazardous work. We expect all Max suppliers to follow this requirement, however if the national or local laws are more stringent than this, then these must be followed.

If any violation is detected, the supplier must take appropriate action immediately following the Impact Limited guidelines for addressing Child Labour. No child labour has been found in our factories since we commenced auditing.

We are an equal opportunities employer and do not tolerate any discrimination, including based on religion, age, gender, sexual orientation, political views, national origin, race, union membership or disability occurring in our factories.

Physical or verbal abuse, including sexual harassment is not acceptable. All workers must be treated with dignity and respect, and any complaints must be documented by management. If disciplinary action is required, this must comply with international human rights, or national laws, which ever provides the greatest protection to the victim.

If workers have any concerns about their treatment in our factories they can contact Max Support Office directly via a confidential email to highlight concerns about their working conditions. This is communicated to them via notices in their native language placed on noticeboards in the factories. The complaint can be made in their native language, and will be translated by Max. Any concern is investigated by Max Support Office staff, and/or our Hong Kong based Audit Manager, and when applicable, corrective action taken.

Gender Inequality

The majority of workers in the garment industry are women. Max has developed a strategy to ensure women are not discriminated against in the workplace.

Sexual harassment is not tolerated in Max factories. This includes invitation or coercement to perform sexual acts, or rewarding workers for sexual acts, inappropriate contact or inappropriate use of power. Workers have a confidential helpline to Max Support Office and can report issues directly to us without having to raise it at the factory. This is communicated on noticeboards in the factories in workers local language. Any issue raised will be investigated immediately.

In our factories, an employee cannot be terminated during her pregnancy, maternity leave, or breast feeding period, which is until the baby is 12 months old. From the twelfth week of pregnancy the employee is entitled to paid leave for pre-natal check-ups. These appointments are managed through the local community health centre.

Paid maternity leave is available to all eligible workers and must meet the requirements of local laws. The length of leave differs depending on circumstances and the province the mother is in, but the minimum allowance for paid leave for the mother is 98 days. Male employees are also entitled to paid leave. Employees receive their full salary paid by the company for the period of their maternity leave.

If the employee becomes pregnant while on a fixed-term contract and that contract ends during pregnancy, the contract must be extended to the end of the breast-feeding period. Breast feeding mothers are allowed to have one hour of paid leave during work hours during the breast feeding period. If the mother does not require this time they are entitled to accumulate this extra leave to use as vacation time.

All employees must be given the option to participate in maternity insurance. The benefit results in them receiving additional payment during maternity leave. This is managed by the Social Security Bureau where the women is registered.

Corruption & Bribery

We will not tolerate corruption or bribery in our business under any circumstances. Suppliers are required to identify which departments could be at risk of bribery and corruption, and ensure adequate training and support is provided to staff to ensure this does not occur.

Worker Representation

Workers in our factories have the right to representation. They have the right to join trade unions or democratically elected worker representative groups of their choice, and to bargain collectively. Any discrimination to these workers will not be tolerated, and no payment or bonus can be offered to workers who do not belong to a union or worker group.

Worker representatives must be allowed to carry out their functions, and the employer should be supportive of this process.

Workers are trained on their rights to form, join and organise workers collectives of their choice, and to bargain collectively with the company. In situations where unions are restricted by law, workers can freely elect their own representatives. Training is provided to all workers when they join the company. Most companies choose to outsource training to a professional teacher (for example The Shenda Group) so they can be sure the training is conducted in accordance with China and local laws.

Max factories have functioning grievance mechanisms where workers can raise concerns anonymously, in their native language. All workers are trained on their rights and entitlements, and how to use grievance mechanisms. Training is provided by the company, and is managed through trade unions, or in cases where unions are restricted by law, this managed through worker representatives who are elected by workers. Workers can raise grievances through worker representatives, and regular meetings are held between management and unions or representatives. Minutes from these meetings must be kept and be available for review. This is thoroughly checked in our audits.

Traceability of Fabric and Trims

All Max input suppliers are traced. 100% of input suppliers are required to sign the Max Fashions code of conduct and return this to the Production and Audit Managers for sign off. Max uses 97 input suppliers in addition to our 15 factories. Factories who source fabric or trims from third parties are responsible for enforcing the principles of our code of conduct with each source. Adequate records should be kept, showing contract agreements and payments, and a company name and address must be supplied for all third parties to enable us to trace the origin of components used in our supply chain. This includes fabric mills, wash mills and accessory suppliers. Max does not accept the use of Uzbekistani cotton in any of our fabric or trims, and we don’t use sand blasted denim due to its impact on worker health.

Fabric Testing/Chemical Use

We are focused on ensuring the chemicals we use are safe for the people working with them and our customers who wear them. We test for the restricted substances, AZO dyes and formaldehyde, through SGS and reject any fabric that fails testing. All chemicals used for dyeing, finishing and printing fabrics (including linings and trims) comply with New Zealand and Australian standards.

Environment

In addition to protecting workers, we are focused on ensuring our factories and supply chain processes have minimal impact on the environment they operate in. This is included in our audits. Our factories must have a copy of valid local laws and regulations and understand these requirements. All approvals, permits and licenses required by local laws need to be complied with. An environmental emergency procedure related to identified risks needs to have been developed, for example regarding chemical use. Training must be provided to all workers to increase environmental awareness for their specific jobs, and for broader factory requirements.

Hazardous waste must be stored and disposed of correctly so there’s no risk to the environment, population or animal life. Some factories require treatment facilities before water, gas or chemicals can be disposed of. Factories are checked to see if they’re monitoring the emission of waste water and gas as legally required. An energy efficiency plan is encouraged to reduce wastage of resources. This requires an energy survey or assessment, and can relate to electricity, heat or water.

All of our factories are actively working towards the 2020 and 2030 targets set by the Chinese government under the Water Pollution Prevention and Control Action Plan (The Water 10 Plan), and are expected to be compliant.

The plan sets out 10 general measures which can be broken down to 38 sub-measures with deadlines and responsible government departments identified for each action. In general, the plan covers the following four broad actions:
- Control pollution discharge, promote economic & industrial transformation and save & recycle resources;
- Promote science & technology progress, use market mechanisms and enforce law & regulations;
- Strengthen management & ensure water environment safety;
- Clarify responsibilities & encourage public participation.

In total, there are 238 specific actions involved. Some key targets and actions are listed below:
- By 2020, China’s water environment quality will gradually improve;
- To greatly reduce the percentage of badly polluted water bodies – over 70% of water in 7 key rivers shall reach Grade III or above
- To improve the quality of drinking water – over 93% of urban drinking water sources shall reach Grade III or above
- To reduce groundwater over extraction and control groundwater pollution – groundwater falling under “very bad” category shall decrease to around 15%
- To improve the environmental quality of coastal areas – up to 70% of coastal water shall reach Grade I or II
- Improve urban water environment in key regions – the amount of Grade V+ water in Beijing-Tianjin-Hebei shall fall by 15%, and Grade V+ water shall be eliminated in Yangtze River Delta and Pearl River Delta
- By 2030, the overall quality of the ecological environment will be improved
- By the middle of 21st century, the quality of the ecological environment should be fully improved and the ecosystem should realise a virtuous cycle