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Responsible Sourcing PolicyUpdated 4 months ago

Business Integrity and Ethics

1: Legal Compliance & Countering Corruption – All relevant laws and regulations are complied with and there is a zero-tolerance approach to all forms of corruption.


Mandatory Requirements


Compliance with laws

1.1       All laws and regulations are complied with and required permits are held, for the countries where the business partner operates, as well as for all other applicable international laws and regulations.


Anti-bribery & corruption 

1.2       All forms of corruption, including bribery, extortion and embezzlement are prohibited and prevented through adequate and proportionate procedures. Bribery of public officials or private organization officials as well as facilitation payments and other forms of corruption (for example fraud or theft) are all covered by this prohibition. Any breach of this requirement in connection with Dollar Shave Club business is promptly disclosed to Dollar Shave Club.

1.3       A business partner is prohibited from offering anything of value to Dollar Shave Club employees to improperly obtain or retain business.

1.4       Dollar Shave Club employees are prohibited from soliciting any improper advantages from our business partners.

Gifts and hospitality

1.5       Gifts or hospitality offered to Dollar Shave Club employees are not intended to influence decisions about how Dollar Shave Club assesses performance or awards future business. They are legitimate, proportionate and respectful of Dollar Shave Club’s internal policies which limit significantly the acceptance of gifts and hospitality.


Avoiding conflicts of interest 

1.6       All business transactions are free of conflicts of interest. Any material ownership or beneficial interest in a business partner’s company by a public official, representative of a political party, Dollar Shave Club employee or their relatives are declared to Dollar Shave Club prior to any business relationship with Dollar Shave Club so that Dollar Shave Club can take appropriate action.

1.7       Any other conflict of interest in any business dealings with Dollar Shave Club, of which the business partner is aware, is declared to Dollar Shave Club to allow Dollar Shave Club the opportunity to take appropriate action.


Accurate records, anti-money laundering and economic sanctions compliance 

1.8       All business and commercial dealings are transparently performed and accurately recorded in a timely manner.


1.9       All economic sanctions, anti-money laundering and anti-tax evasion legislation and rules must be complied with. Any suspicions of occurrence of any of these issues in relation to transactions with Dollar Shave Club are promptly reported to us and effective steps are taken to mitigate risks.


Mandatory Management Systems 


For all mandatory requirements: 

1.10     Systems are in place to regularly communicate on business integrity, ethics and compliance topics to Supplier’s employees, led by senior leaders.

1.11     Processes are in place to identify and assess key risks and to enable actions to respond to them, taking into account company size, country of operation, business activities and external environment.

1.12     Internal policies and guidance are designed, based on key risks, and communicated to employees as appropriate, given company size.

1.13     Training is in place to mitigate key risks and embed a culture of integrity.


Specific to accurate records, anti-money laundering and economic sanctions compliance: 

1.14     Financial procedures ensure the proper recording of all financial transactions and facilitate the identification of any suspected money laundering, tax avoidance and breach of economic sanctions activities.

1.15     No undisclosed or unrecorded account, fund or asset is established or maintained.


Future Mandatory Requirements Compliance with laws 

1.16     All relevant laws are complied with as they become binding on business partners operating in, or supplying to, applicable jurisdictions.


Leading Practices 

1.17     Independent risk assessments and audits are performed, and any gaps identified and remediated.

2: Safeguarding Information & Property - Information is protected, whether that information derives from Dollar Shave Club or from its competitors, and personal data is collected, processed, stored, transferred and disposed of responsibly.


Mandatory Requirements


Protecting Dollar Shave Club’s information and property 

2.1       Dollar Shave Club’s, or any other party’s, confidential information, know-how and intellectual property are respected and safeguarded.

2.2       All information provided by Dollar Shave Club or another party that is not in the public domain is deemed confidential and only used for its intended and designated purpose.


Competitor information

2.3       All competitor information is obtained and used legitimately and in compliance with all applicable laws and regulations.

2.4       No attempt is made to divulge to Dollar Shave Club, or to any other party, any commercially sensitive or confidential information about their competitors or the business partner’s competitors.

2.5       Dollar Shave Club’s commercially sensitive or confidential information is not used for other business purposes or shared with any third party unless expressly permitted by Dollar Shave Club in writing.


Data ethics and privacy

2.6       Personal data is collected, processed, stored, transferred and disposed of in line with applicable laws and with respect for the protection of privacy as a human right.

2.7       The risk to individuals when using their personal data is always considered and steps are taken to mitigate those risks and restrict the collection or use of personal data to only the purpose it is being collected for.


Mandatory Management Systems


Protecting Dollar Shave Club’s information and property 

2.8       Procedures and mechanisms are in place to ensure that all confidential information, whether business or product related, is safely stored with limited access rights on a need-to-know basis only.

2.9       There are procedures and mechanisms in place to ensure that the appropriate consent has been obtained before disclosing Dollar Shave Club’s or another party’s commercially sensitive or confidential information to third parties, or that of third parties to Dollar Shave Club.


Leading Practices


Data ethics and privacy

2.10     Standards, processes and governance are in place for the ethical use of both personal data and artificial intelligence technologies.

2.11     Business partners are transparent about how and why they collect, process, store, transfer and dispose of personal data, in a way that is understandable for people to make informed choices.

2.12     Business partners can show that when an automated decision is made that might impact people’s lives, there is an explainable and ethical rationale for these decisions.


3: Sourcing and Manufacturing Products - Products and materials supplied to Dollar Shave Club are appropriately and responsibly sourced and tested and meet agreed specifications.


Mandatory Requirements


Product specifications and quality

3.1       Products, materials and services meet agreed specifications (where the goods or services are covered by a specification) and quality and safety industry norms for such items, as well as such other quality and safety standards as agreed between us. They also comply with all applicable legal and regulatory requirements.

3.2       Suppliers to Dollar Shave Club are responsible for meeting these specifications, quality and safety standards and for legal and regulatory compliance whether they are directly supplying the goods or services to Dollar Shave Club or have sub-contracted the supply to a third party.

3.3       Where relevant, business partners conduct research and development activities responsibly, follow good clinical practice and generally accepted scientific, technological and ethical principles.


Animal welfare 

3.4       Any animal testing previously conducted on existing products, product ingredients or materials supplied to Dollar Shave Club, or to Dollar Shave Club’s collaborative manufacturers for Dollar Shave Club’s business, is disclosed.

3.5       Any animal testing previously conducted on new products, product ingredients or materials which they intend to supply to Dollar Shave Club, or to Dollar Shave Club’s collaborative manufacturers for Dollar Shave Club’s business, is disclosed. This includes pre-existing products, product ingredients and materials, as well as those newly developed.

3.6       Agreement from Dollar Shave Club is obtained before conducting any future animal testing on new or existing products, product ingredients or materials to be or being supplied to Dollar Shave Club, or to Dollar Shave Club’s collaborative manufacturers for Dollar Shave Club’s business.


Responsible sourcing

3.7       The business partner’s own Code of Conduct, guidelines, policies and/or training are in place and readily available to workers to enable the business partner to meet or exceed the Mandatory Requirements of the RSP.

3.8       Business partners have their own Responsible Sourcing Policy, Supplier Code, Third Party Policy or similar policy that covers the equivalent principles to the RSP Mandatory Requirements for their own business partners. The business partner’s policies place comparable requirements on its own business partners.

3.9       Where the provision of goods or services being sourced by Dollar Shave Club is sub-contracted to another party, the business partner has in place a Code of Conduct or Responsible Sourcing Policy for these suppliers, consistent with the requirements of the RSP. In addition, there is a process to communicate this and to monitor compliance by these suppliers.

3.10     The business partner exercises and shows human rights and environmental due diligence. This should identify, prevent, mitigate and account for how it addresses and manages potential and actual adverse impacts that it may cause or contribute to through its own activities, or which may be directly linked to its operations, products or services by its business relationships.


Mandatory Management Systems 


Product specifications and quality

3.11     Procedures are in place to ensure that any product quality or safety concerns originating from the business partner, or its supply chain, are notified to Dollar Shave Club without delay.

3.12     Supply and manufacturing partners have procedures in place to meet the Dollar Shave Club requirements for external certification, where informed prior to contracting.


Animal welfare

3.13     Procedures are in place to ensure that Dollar Shave Club is notified before any products, product ingredients or materials are to be tested on animals – either existing or future products, product ingredients or materials.


Conflict minerals

3.14     Where applicable to sourcing activities, supply chain diligence and reporting procedures are in place with regard to minerals which may come from conflict-affected or high-risk areas, including areas for which applicable laws provide reporting requirements and/or usage, import or export restrictions (so-called ‘conflict minerals’).


Leading Practices


Animal welfare 

3.15     Modern non-animal science and technology is used for assessing product, product ingredient and material safety and for regulatory compliance, upholding the principle that any animal testing is a last resort.

3.16     Advocacy in the public domain is engaged in, promoting the use of non-animal science and participating in consortia working for regulatory change to end animal testing.


Responsible sourcing 

3.17     All business partners have in place a Code of Conduct or Responsible Sourcing Policy for their own supply chain, at least consistent with the requirements of the RSP. In addition, there is a process to communicate this throughout their supply chain and to monitor compliance


Human Rights 

4: Freely Agreed Terms of Employment -  Work is conducted on the basis of freely agreed and documented terms of employment.


Mandatory Requirements

4.1       All workers, both permanent and casual, are provided with employment documents that are freely agreed and which, at a minimum, respect their legal and contractual rights.

4.2       Key components of the employer–worker relationship, including hours, overtime, pay, benefits, leave, and disciplinary and grievance systems, are freely agreed by the worker; documented in writing; and formally acknowledged by the employer and worker before the start of employment.

4.3       Terms and conditions of employment are in a language understood by the worker, are explained verbally or diagrammatically if required, and available throughout employment.

4.4       All workers receive a copy of their terms and conditions of employment in a language they understand for their records that matches those the employer has on file.

4.5       Any changes to the terms and conditions of employment are agreed in writing by both worker and employer.

4.6       Where required by law, short-term, casual or agency workers are hired as permanent employees where the work involved is of a regular nature and is required all year round.

4.7       Workers are entitled to maternity, paternity, adoption or parental protection, leave and benefits as required by law.


Mandatory Management Systems

4.8       Key management functions such as hiring and contracting, grievance management, discipline, promotion and employment termination have clear policy frameworks, procedures for implementation and training of those responsible for implementing them, with appropriate documentation kept.

4.9       There is a clear and transparent system of worker and management communication. Employees are provided with information relating to any decision that changes or affects their terms of employment and have the right to effective dialogue with management.


5: Free from Discrimination-  All workers are treated equally and with respect and dignity without any form of discrimination. Particular attention is paid to the rights of workers most at risk of discrimination.


Mandatory Requirements

5.1       There is no discrimination in employment (including hiring), any aspects of training, personal and professional development, compensation, advancement, discipline, employment termination or retirement.

5.2       Discrimination based on race, ethnicity, age, role, sex, gender identity, color, religion, country of origin, sexual orientation, marital status, pregnancy, dependents, disability, social class, union membership, personal characteristics, disease, health status or political views, or on any other grounds stated by local law is prevented.

5.3       Engaging in, supporting or tolerating discrimination is prohibited.

5.4       Pregnancy testing, other forms of health screening that might result in discrimination, and mandatory contraception use are not tolerated. When health tests are mandated under local laws, the results cannot be used to dismiss workers or otherwise discriminate against them or treat them unfavorably.


Mandatory Management Systems 

5.5       Policies and procedures are in place that prohibit discrimination in any form during the recruitment, compensation, access to training, promotion, employment termination or retirement processes and these are clearly and regularly communicated to all workers, including management.

5.6       Selection criteria for all human resource decisions are objective and transparent and controls are in place to ensure these criteria are followed.

5.7       Procedures are in place to ensure that job vacancies are not described in terms that could exclude a group, or groups, of people, other than based on the skills, occupational requirements or training needed to perform the work.

5.8       Those responsible for hiring, paying, training, promoting, disciplining and terminating the employment of workers are trained to avoid discrimination in the exercise of their duties.

5.9       All workers, and specifically managers, supervisors and site security, are trained to avoid discrimination.


6: Free from Harassment -  All workers are free from harassment and abuse. No worker is subject to any physical, sexual, psychological or verbal harassment, abuse or other form of intimidation.


Mandatory Requirements 

6.1       Workers are treated with dignity and respect. Physical, sexual, verbal or psychological abuse, any form of harassment, hate speech, intimidation, bullying, violence and corporal punishment are not engaged in or tolerated.

6.2       Distinct procedures for cases involving sexual harassment or assault are available. Those procedures take account of the potential trauma and risks involved and make provision for counselling and other support to survivors, as needed.

6.3       Disciplinary measures are proportionate and do not include physical or mental punishment.

6.4       All workers, and specifically managers, supervisors and site security, who subject workers to harassment or abuse are subject to appropriate disciplinary measures.

6.5       There is zero tolerance of any abuse, threats, intimidation or reprisals against human rights defenders.


Mandatory Management Systems

6.6       Policies and procedures are in place that prohibit any form of harassment or abuse and are communicated clearly to all workers, with regular training on how to recognize and prevent harassment and other forms of intimidation.

6.7       Written disciplinary procedures are communicated and explained clearly to all workers and records of all disciplinary actions are documented for the duration applicable by law.  


7: Work is Voluntary -   Employment is accepted and work is conducted on a voluntary basis.


Mandatory Requirements

7.1       Under no circumstances will forced labor be used, whether in the form of trafficked labor, indentured labor, bonded labor or other forms including mental and physical coercion, and slavery.

7.2       Workers enter employment freely and are neither required to surrender any identity or personal papers nor pay a deposit in relation to their employment.

7.3       Workers are free to terminate their employment after a reasonable notice period without penalty, as agreed in the terms and conditions of employment.

7.4       Workers have freedom of movement and are not confined to the business partner’s premises, including dormitories or provided housing.

7.5       Workers are not required to pay a fee or deposit in connection with obtaining employment, to the employer or to any person, company or agency involved in the recruitment process.

7.6       Employers are responsible for the payment of all fees and expenses in connection with a worker obtaining employment or incurred in connection to the worker performing their duties. If workers have paid any fees, these must be reimbursed by the employer.

7.7       The use of prison labor is prohibited except in circumstances where their terms and conditions of employment uphold the Mandatory Requirements of this policy and can be verified.


Mandatory Management Systems

7.8       There are hiring policies in place and employees trained in human resources procedures to ensure that workers are entering into employment freely and that they are not prevented from leaving if they so wish.

7.9       Workers relocating for a job, either internationally or domestically, are made aware of the terms and conditions as well as their rights, via pre-departure and post-arrival trainings or other acceptable means, in a language that they understand.

7.10     Effective and transparent processes are set up to ensure that workers have freedom of movement and are not confined to the facility’s premises, including worker accommodation and transportation to or from the place of work (where either is provided). Such processes extend to the role and responsibility of security employees, where present.

7.11     Policies and procedures are in place and implemented to identify, prevent and remediate any potential cases of recruitment fees paid by workers, including through selection and monitoring of recruitment agencies or labor brokers.


8: Appropriate Age - All workers are of an appropriate age and young workers are protected.


Mandatory Requirements 

8.1       Under no circumstances are individuals employed under local legal minimum age for work or mandatory schooling, whichever is higher.

8.2       Responsible remedial measures are immediately implemented whenever any workers under the local legal minimum age are identified. These measures include immediately removing the child from all work and ensuring they are in a safe environment.

8.3       In all circumstances, the health and safety of young workers are considered and protected. This protection should preclude them from certain types of work, such as hazardous or night work, and requires extra care and commitment, ensuring that they must not do work that is mentally, physically, socially or morally dangerous or harmful.

8.4       The goals and requirements set out in the International Labour Organization Worst Forms of Child Labour Convention are met.


Mandatory Management Systems 

8.5       An employment policy (which covers all workers, including those recruited directly or via an agency or third party) is in place, specifying the minimum age for all workers as well as remediation measures if there is an incident of child labor detected. The policy should also outline the conditions under which young workers can be employed.

8.6       An effective age verification process, that includes proper documentation and record keeping systems, is in place in the workplace.

8.7       All relevant workers are trained to respect the provisions for young workers, inclusive of apprentices and interns, especially with respect to hours of work, night shifts, working hours during school terms and heavy or dangerous work.  


9: Fair Wages - All workers paid fair wages.


Mandatory Requirements 

9.1       All workers are provided with a total compensation package for a standard working week that includes wages, overtime pay, benefits and paid leave which meets or exceeds legal minimum standards.

9.2       Compensation terms established by legally binding collective bargaining agreements are implemented and adhered to.

9.3       Wages are paid, on time, regularly and in full.

9.4       Workers receive a pay slip for each pay period, clearly indicating the components of the compensation, including exact amounts for wages, specifying regular and overtime hours worked (where workers are paid on an hourly basis) and benefits, incentives/bonuses and any agreed deductions.

9.5       Where a worker is paid based on volume output, piece rate, quotas or similar, the pay rate allows the worker to be able to earn at least the equivalent of the minimum or collective agreement wage, whichever is higher, during normal working hours.

9.6       All overtime work or work on statutory holidays is paid at the appropriate premium rate according to local legal requirements and/or collective bargaining agreements.

9.7       Other than legally mandated deductions, all other deductions from wages are made only with the express and written consent of the workers in a language they understand.

9.8       All legally mandated deductions, such as taxes and social or health insurance, are deposited each pay period in the legally stipulated accounts or agencies and as required by law.

9.9       Insurance is taken to cover workers in the case of any work-related injuries, accidents, illness, invalidity and death in accordance with local worker compensation laws, as a minimum.


Mandatory Management Systems

9.10     A written policy on wages and compensation is in place, transparent and explained to all workers in a language they understand.

9.11     A process to understand legal requirements for wages, overtime pay, benefits, holidays and deductions and to monitor any changes to these, is in place and implemented.

9.12     Records are maintained that demonstrate that workers are paid accurately for standard and overtime hours worked, based on an appropriate hours and wages system.


Future Mandatory Requirements

9.13     All workers of business partners directly providing goods and services to Dollar Shave Club must earn at least a Living Wage or Living Income. A Living Wage must be achievable within normal working hours (not including overtime), whether the worker is paid on a salary, hourly or volume output/ piece-rate/quota basis.

10: Reasonable Working Hours - Working hours for all workers are reasonable.


Mandatory Requirements

10.1     Workers are not required to work more than the regular and overtime hours according to local legal requirements. Total weekly working hours including overtime must not exceed 60 hours for non-management workers even if local law would otherwise allow it, in order to prevent excessive physical and mental fatigue.

10.2     All overtime is on a voluntary basis. If the employment contract allows for contractual overtime, then workers expressly agree to it.

10.3     Workers are entitled to at least 24 consecutive hours of rest in every seven-day period, and to take legally required annual leave.

10.4     If workers are required to work on a rest day due to a genuine need for continuity of production or service, workers must receive an equivalent period of compensatory rest immediately following to ensure a minimum of two days’ rest in every 14 days.

10.5     Workers are entitled to reasonable meal and rest breaks, which, at a minimum, must comply with applicable laws.


Mandatory Management Systems 

10.6     Written policies are in place and implemented for regular working hours and overtime; the policies clearly state that overtime is voluntary.

10.7     The expected work hours and schedules are communicated to all workers in a language and format that they understand.

10.8     Workers’ consent to perform overtime work is documented.

10.9     There are defined and effective mechanisms for recording, documenting and monitoring working hours and overtime for all workers, regardless of wage system (for example, piece-rate payment) or contract type.


11: Freedom of Association - All workers are free to exercise their right to form and/or join trade unions and to bargain collectively.


Mandatory Requirements

11.1     All workers can freely exercise their right to form or join a union of their choice, to seek representation and collectively bargain and do so without fear of intimidation, harassment or obtaining prior approvals, unless legally required.

11.2     Workers know and understand their rights, including any legal right to strike. No other worker, manager or other company representative impedes them in the enjoyment of these rights.

11.3     Collective bargaining negotiations are entered into in good faith when requested from any legally recognized representative group of workers and collective agreements are concluded and implemented.

11.4     Worker representatives are not discriminated against, and unfair labor practices do not take place against them because of their role as worker representatives. They have reasonable access to carry out their representative functions in the workplace.

11.5     Where local law sets restrictions on the right to freedom of association and collective bargaining, alternative forms of worker representation, association and bargaining are allowed.


Mandatory Management Systems

11.6     Clear policies and processes relating to freedom of association and collective bargaining in day-to-day operations are in place and clarify that a worker’s choice to form or join a trade union will not compromise their equal treatment (including treatment relating to hiring, discipline, promotion, wages, hours, grievances or employment termination).

11.7     Regular training of workers, managers and site security guards is carried out to ensure a worker’s right to associate freely and to ensure the effective right to collective bargaining and good industrial relations practice (including consultation and negotiation).

11.8     Clear rules governing the activities of recognized trade unions in the workplace are in place.


12: Health & Safety - All workers operate in a safe and healthy work environment that identifies and reduces risks to prevent accidents, injuries and illnesses.


Mandatory Requirements

12.1     A healthy and safe workplace is provided to prevent accidents and injury, or illness (either physical or mental) arising out of, linked with or occurring in the course of work, or as a result of the employer’s operations.

12.2     All workers and other people who enter business premises are clearly informed about the inherent dangers of the workplace and are provided with adequate knowledge and personal protective equipment to avoid such dangers, and there is clear and appropriate signage or information provided on how to evacuate in the case of an emergency.

12.3     All workers, visitors, and people who enter the premises to provide any operational services or deal with products are properly trained and informed about the appropriate actions to take should a health and safety incident occur.

12.4     All workers have easy access to free, potable drinking water.

12.5     Lavatories are clean and fully serviced, include hand washing facilities with running water and soap, and are accessible to all workers.

12.6     Company-wide goals to achieve zero accidents are actively monitored and reported on, while continuing to encourage transparent reporting of any incidents that occur.


Mandatory Management Systems

12.7     Clear and effective policies and procedures are in place for occupational health and safety and are updated regularly.

12.8     Occupational health and safety policies and procedures are widely communicated and cascaded effectively throughout the organization, with a mechanism to ensure relevant information is provided to all visitors.

12.9     Regular and repeated safety training including evacuation drills is provided to all workers, including managers, supervisors, contract workers and security guards.

12.10   An effective Health & Safety Committee, with roles that are clearly understood by workers and managers, proportional to the size and risks of the work site, is in place. The Committee should identify, monitor and ensure improvement plans are implemented to reduce health and safety risks, in order to protect workers from work-related accidents, injury and illness.

12.11   A senior member of management is appointed to administer and oversee the safety plan for each work site.

12.12   The effectiveness of safety plans is regularly tested through drills and other means.

12.13   The structural integrity and fire safety of work sites are specifically and regularly assessed, and identified issues are addressed.

12.14   Operations are regularly evaluated for safety issues, including areas for equipment and worker housing, where provided.

13: Access to Grievance Mechanisms & Remedies - All workers have access to grievance mechanisms with fair procedures and remedies. 


Mandatory Requirements 

13.1     All workers are provided with transparent, fair and confidential procedures that result in swift, unbiased and equitable resolution of issues which may arise as part of their working relationship.

13.2     The grievance mechanisms are in line with the UN Guiding Principles on Business and Human Rights and are well communicated and accessible in order to enable workers to report any issue.

13.3     The grievance mechanisms guarantee the confidentiality of any complainant unless permission is given by the complainant to disclose to a given person.

13.4     Those reporting a grievance or participating in any investigation of a grievance must not be retaliated against.

13.5     Grievances are fully addressed in an effective, timely and respectful manner, and escalated to and overseen by the appropriate level of management.


Mandatory Management Systems 

13.6     There is a clear and documented process to address any grievance which ensures confidentiality (unless permission is given by the complainant to disclose to a given person).

13.7     There is a non-retaliation policy towards workers or whistle-blowers who report grievances, with specific measures to protect complainants from retaliation.

13.8     All employees are trained on the policy and procedures for handling grievances and managers are specifically trained to avoid recriminations and retaliation.


Leading Practices

13.9     Anonymized data on the receipt and handling of grievances is maintained and analyzed to ensure the efficacy of grievance mechanisms.

13.10   Root causes of complaints and grievances and any related underlying patterns are identified, in order to make operational improvements where appropriate.

13.11   Grievance mechanisms are widely communicated and accessible in order to enable local communities to report to the company on any issue, in line with the UN Guiding Principles on Business and Human Rights.


14: Protect and Regenerate Nature- Business is conducted in a manner which protects, preserves and regenerates nature (including biodiversity) and ensures no deforestation or conversion takes place in connection with the supply of palm oil, soy, paper & board, and tea and cocoa materials. Water consumption is reduced, particularly in areas of high-water stress, and wastewater discharge is appropriately managed.   


Mandatory Requirements 

14.1     Current and valid legal permits and requirements relating to planning, development and business operations, with respect to the protection of the environment, nature and biodiversity, are held and complied with.

14.2     Applicable laws and permits relating to water – including but not limited to water abstraction, water usage, surface water management and effluent discharge – are complied with.


Mandatory Management Systems 

14.3     An environmental management system is in place, and updated periodically, to identify and mitigate issues related to water management and wastewater discharge.


The following general management systems shall be in place in order to meet the Mandatory Requirements for each Section under the Planet pillar. 

14.4     Environmental management policies and procedures are in place and implemented for issues that present significant environmental risks relating to your operations.

14.5     Due diligence policies and processes relevant to national and international sourcing requirements are in place and are implemented as required by applicable laws and regulations, and as advised or requested by Dollar Shave Club prior to purchase, or as otherwise agreed in contract.

14.6     Training is provided to all relevant workers to ensure knowledge of and compliance with all necessary legal permits.

14.7     All required data is shared with Dollar Shave Club where needed to allow Dollar Shave Club to use that data (on an anonymized basis, where the reporting or requirements allow anonymity) to comply with the reporting and disclosure requirements of all relevant human rights, environmental protection and supply chain due diligence laws.

14.8     Relevant policies and procedures are widely communicated throughout your organization, with appropriate training provided.


15: Climate Action - Greenhouse gas (GHG) emissions are reduced in line with the goals of the Paris Agreement and limits global warming to well below 2 degrees Celsius compared to pre-industrial levels.


Mandatory Requirements 

15.1     All applicable legal and regulatory requirements are complied with and permits held with respect to GHG emissions management and reduction.


16: Waste-free World - The generation of waste is reduced. Plastic use and waste are reduced to help create a transparent and circular economy for plastics.


Mandatory Requirements 

16.1     Applicable laws and permits relating to the storage, handling and disposal of waste directly or through waste sub-contractors are complied with.

16.2     Waste is stored, handled, transported and disposed of in a way that protects the health and safety of people and also protects the environment.

16.3     All applicable legal requirements with respect to plastic feedstock sourcing, plastics production, storage, transport and end-of-life management are complied with.

16.4     Suppliers of post-consumer recycled (PCR) plastic conduct annual migration tests to confirm the materials supplied to Dollar Shave Club are within the approved limits for contaminants and appropriate records of these results are maintained. Any contaminant identified above the limit must be risk assessed and the result communicated to Dollar Shave Club.


Mandatory Management Systems

16.5     An environmental management system is in place and updated periodically to identify and mitigate issues related to waste management and reduction.


Applicable to suppliers using plastic in their production processes: 

16.6     Clear and effective policies and management controls appropriate to your operations are in place to manage plastic production, use and end-of-life treatment and these are updated periodically.

16.7     A process to identify and manage the potential adverse environmental impacts and risk (associated with plastic production, usage, reduction, collection and end-of life management) appropriate to your operations and activities is in place. Appropriate procedures and controls to minimize the identified risks are implemented.


Future Mandatory Requirements 

Applicable to suppliers of plastic packaging: 

16.8     Suppliers of plastic packaging only supply plastic that is designed to be fully reusable, recyclable or compostable.

16.9     Suppliers of plastic packaging develop and disclose a plastics inventory to support the transparency and traceability efforts (related to plastics) of Dollar Shave Club or other downstream parties. This includes relevant data such as virgin fossil-based content, post-consumer recycled content and detail on the ability of the plastic to be reused, recycled or composted.


Reporting on Breaches

1. Any failure to meet the Mandatory Requirements of our RSP of which the business partner is aware and which is not rectified in a reasonable timeframe should be reported to Dollar Shave Club as soon as possible. Failure to do so will be a breach of our RSP.

2. We strongly support a culture of speaking up for both business partners and their workers without fear of retaliation against those who report actual or suspected breaches.

3. Business partners and their workers, communities and other stakeholders may report actual or suspected breaches of our RSP (including any failure by a Dollar Shave Club worker or anyone acting on behalf of Dollar Shave Club) to Dollar Shave Club by email at: [email protected].

4. Dollar Shave Club will investigate any concern raised and discuss findings with the business partner. The business partner shall assist with any such investigation and provide access to any information reasonably requested.

5. If remediation is required, the business partner will create and inform Dollar Shave Club of their corrective action and implementation plans and timeline to effectively and promptly resolve the breach.


Implementation Tips

1. Review your current policies, procedures and practices against the Mandatory Requirements to ensure you are not at risk of any breaches of our RSP.

2. Speak to your Dollar Shave Club contact to discuss any areas you don’t understand or share with us any challenges you may have in meeting the requirements of this Policy.

3. Familiarize relevant workers with our RSP and how to report suspected breaches to Dollar Shave Club.


NOTE: This Responsible Partner Policy supersedes and replaces our previous Responsible Sourcing Policy and Responsible Business Partner Policy. Any reference to our Responsible Partner Policy, RSP, Responsible Sourcing Policy, RSP, Responsible Business Partner Policy, RBPP and/or our Supplier Code in any documentation or contracts with the supplier is intended to refer to this Responsible Partner Policy.

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