Comparison of Codes:

ETI Base Code; SA8000; GSCP

 Comparison of Codes: Reference ETI Base Code, SA8000 & GSCP

SEDEX CODE COMPARISON – Introduction to the Codes

ETI – Ethical Trade Initiative:

The Ethical Trading Initiative (ETI) is a ground-breaking alliance of companies, trade unions and voluntary organisations which promotes the implementation of corporate
codes of practice which cover supply chain working conditions. Their ultimate goal is to ensure that the working conditions of workers producing for the UK market meet or
exceed international labour standards.

The Ethical Trading Initiative (ETI) produces guidelines aimed at the promotion and the improvement of ethical trade. The code of conduct has been elaborated in the UK by
an alliance of companies, non-governmental organisations (NGOs) and trade union organisations.

It is composed of two key elements: the ETI Base Code and the accompanying Principles of Implementation. ETI has developed a code of labour practice - the 'Base Code' -
reflecting the most relevant international standards with respect to labour practices which will be used as the basis of its work under the form of 9 statements.

ETI member companies are expected to adopt the Base Code, or to adopt their own code so long as it incorporates the Base Code. The Base Code, which is accompanied by
a set of general principles concerning implementation, provides a foundation for ETI's philosophy of learning.

SA8000:

SAI is a non-governmental, international, multi-stakeholder organization dedicated to improving workplaces and communities. It does this work with two principal types of
tools; developing and implementing socially responsible standards, the first of which was SA8000; training and capacity building-- about specific standards and management
systems for implementing social standards-- for workers, managers and auditors throughout the supply chain.

SA8000 is an auditable certification standard based on international workplace norms of International Labour Organisation (ILO) conventions, the Universal Declaration of
Human Rights and the UN Convention on the Rights of the Child. This standard is the benchmark against which companies and factories measure their performance. Those
seeking to comply with SA8000® have adopted policies and procedures that protect the basic human rights of workers.

There are a series of documents available to support auditors and implementers of the SA8000® Standard; these are: The SA8000® Guidance Document; The SA8000®:2008
Drafters' Notes; and the SA8000® Frequently Asked Questions (FAQs).

Comparison of Codes - Similarities & Additions Page 2

 Comparison of Codes: Reference ETI Base Code, SA8000 & GSCP

GSCP (Global Social Compliance Program):

The Global Social Compliance Programme is a business-driven programme for the continuous improvement of working and environmental conditions in global supply
chains. The GSCP was created by and for global buying companies wanting to work collaboratively on improving the sustainability (social and environmental) of their often-
shared supply base. To this end, these companies are working on harmonizing existing efforts to deliver a shared, global and sustainable approach based on consensus and
best existing practice, to promote upward convergence and reduce duplication. The GSCP Reference tools, including the Reference Code used in this comparison, are the
product of the identification of best existing practices in operating monitoring systems, and provide a common base of high-level labour requirements applicable across
sectors and geographies.

The GSCP Reference Code is not a standard and the GSCP is not a monitoring system. The Programme and its tools are used by companies as a basis to develop their own
supplier codes of conduct or as a benchmark for schemes owners (including initiatives or standard-setting bodies) to assess and improve their existing requirements for
these to reflect best existing practice. The Reference Code is complemented by other GSCP Reference tools (available open source on www.gscpnet.com) which set out
additional requirements for auditing (Reference Audit Process and Methodology), for auditing bodies and auditors (Reference tool for Auditing Competence) and Social
Performance Management Systems.

Comparison of Codes - Similarities & Additions Page 3

 Comparison of Codes: Reference ETI Base Code, SA8000 & GSCP
ETI Base code
Intention of Code / Audit - Auditable Labour Standards Code – not
Method certification scheme.
- Audits conducted by any parties as
agreed by the supply chain.
Structure and General The ETI Base code is structured as
comments follows:
1. ETI Base Code – 9 elements
2. Appendices
- Relevant international standards -
UN Universal Declaration of Human
Rights, ILO etc.
- Definitions (specifically ‘a child’)
Differences (a) Code refers to ‘The Employer’.
ILO Conventions / - Universal Declaration of Human Rights
International Standards - Guidelines for Multinational Enterprises
developed by the Organisation for
Economic Co-operation and Development
(OECD)
- United Nations Convention on the
Rights of the Child
Comparison of Codes - Similarities & Additions
SA 8000
- Third party accredited certification
scheme.
- Audits conducted by approved SA8000
auditors
The SA8000 code is structured as
follows:
1. Purpose and scope of the code
2. Normative elements and their
interpretation – ILO conventions
3. Definitions – of multiple terms
4. Social Accountability
Requirements(SA8000) – 9 elements
(a) Code refers to ‘The Company’.
- ILO Code of Practice on HIV/AIDS and the
World of Work
- Universal Declaration of Human Rights
- The International Covenant on Economic,
Social and Cultural Rights
- The International Covenant on Civil and
Political Rights
- The United Nations Convention on the
Rights of the Child
- The United Nations Convention on the
Elimination of All Forms of Discrimination
Against Women
- The United Nations Convention on the
Elimination of All Forms of Racial
Discrimination
GSCP
- Reference code for benchmarking
- Audits conducted by any parties as
agreed by the supply chain.
The GSCP Reference code is structured
as follows:
1.Objective
2. Scope
3. Structure and Annexes
4. Compliance with international labour
standards and national legislation -
including ILO conventions
5. Reference code – 7 elements
(a) Reference Code refers to ‘The Supplier’.
This reference code shall not be used to
prevent international labour standards or
national and/or local legislations from being
exceeded.
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0 Scope and Objective
Comparison of Codes - Similarities & Additions
Comparison of Codes: Reference ETI Base Code, SA8000 & GSCP
(a) The code constitutes minimum not
maximum standards.
(b) All relevant legislation will apply to
companies.
(c) Companies will apply the provision
which affords the highest protection.
(a) The Reference code constitutes
minimum not maximum standards (appears
in ‘Compliance with international labour
standards and national legislation’ section).
(b) All relevant legislation will apply to (b) ILO/national standard/local
companies (appears in ‘Compliance with legislation/GSCP Reference code will apply
international labour standards and national (appears in ‘Compliance with international
legislation’ section). labour standards and national legislation’
section).
(c) Companies will apply the provision (c) Companies will apply the provision
which is most favourable to workers which affords the highest protection
(appears in ‘Compliance with international (appears in ‘Compliance with international
labour standards and national legislation’ labour standards and national legislation’
section). section).
Additions Additions
The code intends to protect and empower all Requirements in this Reference code apply to
personnel within a company’s scope of control the whole supply chain (appears in ‘Scope’)
and influence as well as control of its suppliers, - The principles and requirements should be
subcontractors and sub-suppliers and home respected and implemented (appears in
workers (appears in ‘Purpose and Scope’). ‘Compliance with international labour
standards and national legislation’ section).
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1 Employment is freely
chosen
Comparison of Codes - Similarities & Additions
Comparison of Codes: Reference ETI Base Code, SA8000 & GSCP
ETI Base code
(a) There is no forced, bonded or
involuntary prison labour.
(b) Workers are not required to lodge
deposits or identity papers.
(c) Workers are free to leave their
employer after reasonable notice.
ILO Convention 29, 105 and
Recommendation 35
SA 8000
(a) The company shall not engage in or
support the use of forced or compulsory
prison labour (as defined in C29).
(b)1. Personnel are not required to pay
deposits or lodge identity papers.
(b)2. The company and any entity
supplying labour should not withhold any
part of the worker’s salary, benefits,
property or documents.
(c) Personnel are free to terminate their
employment provided they give
reasonable notice.
Additions
- Personnel have a right to leave their
workplace at the end of their shift.
- The company and any entity supplying
labour shall not engage nor support
trafficking.
ILO Convention 29, 105
GSCP
(a)1. All work must be conducted on a
voluntary basis with no threat of any
penalty or sanctions.
(a)2. No forced or compulsory labour in all
its forms, including prison labour (as
defined in C29).
(a)3. Bonded labour prohibited.
(b)1. W orkers are not required to lodge
deposits or identity papers.
(b)2. Employers should not withhold any
part of the worker’s salary (outside a legal
contractual agreement).
(c) Workers are free to terminate their
employment after reasonable notice.
Additions
- Workers have a right to leave their workplace
at the end of their shift.
- Suppliers must not permit or encourage debt
by e.g. recruitment fees, fines.
ILO Convention 29, 105 – Fundamental
principle
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2 Freedom of association
and the right to collective
bargaining are respected
Comparison of Codes - Similarities & Additions
Comparison of Codes: Reference ETI Base Code, SA8000 & GSCP
ETI Base code
(a) W orkers have the right to join or form
trade unions and to bargain collectively.
(b) Members or representatives are not
discriminated against.
(c) The employer must adopt an open
attitude.
(d) W here the right is restricted by law,
the employer facilitates a parallel means.
(e) Members shall have access to carry
out trade union function in the workplace.
ILO Convention 87, 98, - core conventions
ILO Convention 135, 154 and
Recommendation 143 – relevant to ETI
SA 8000
(a) All personnel have the right to join,
organise or form trade unions and to
bargain collectively.
(b) Any workers engaged in collective
bargaining, are not subject to any
harassment, discrimination, intimidation
or retaliation.
(c) The company shall not interfere with
the establishment, functioning or
administration of the collective bargaining
(interfere includes: includes company
interference in workers’ organizations and
collective bargaining).
(d) Where the right is restricted by law,
workers are allowed to freely elect their
own representatives.
(e) Company shall ensure that
representatives have access to their
members in the work place.
Additions
- The company shall effectively communicate
this right to workers.
ILO Convention 98, 87, 135
GSCP
(a) W orkers have the right to join or form
trade unions and to bargain collectively.
(b) Any workers engaged in trade unions
(incl. worker representation) and
collective bargaining, are not subject to
any discrimination or otherwise
penalised.
(c) Suppliers shall not interfere, obstruct
or prevent such activities.
(d) Where the law is restrictive, supplier
shall not hinder alternative form of
independent and free worker
representation and negotiation.
(e) Suppliers shall give representatives
access to the workplace in order to carry
out their function.
ILO Convention 87, 98 – Fundamental
principles
ILO Convention 135 - other applicable
standards
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3 Working conditions are
safe and hygienic
Comparison of Codes - Similarities & Additions
Comparison of Codes: Reference ETI Base Code, SA8000 & GSCP
ETI Base code
(a) A safe and hygienic working
environment is to be provided.
(b) Steps are to be taken to prevent
accidents arising out of, associated with,
or occurring in the course of work.
(c) Workers shall receive regular and
recorded H&S training.
(d) Clean toilet facilities and potable water
to be provided & if appropriate sanitary
food storage facilities.
(e) Accommodation shall be clean, safe &
hygienic.
(f) There should be a senior management
representative for H&S.
ILO Convention 155, 190, 183 and
Recommendation 164 – relevant to ETI
SA 8000
(a) A safe and hygienic working
environment is to be provided.
(b)1. Steps are to be taken to prevent
accidents arising out of, associated with,
or occurring in the course of work.
(b)2. Establish systems to detect, avoid
and respond to potential threats &
maintain written records of all accidents.
(c) Workers shall receive regular and
recorded H&S training.
(d) Clean toilet facilities and potable water
to be provided & if appropriate sanitary
food storage facilities.
(e) Accommodation shall be clean, safe &
hygienic.
(f) There should be a senior management
representative for H&S.
Additions
- Appropriate PPE, first aid and follow-up
medical treatment for accidents at the
company's expense shall be provided.
- Assess risk for new & expectant mothers &
ensure risk is reduced.
- Workers have the right to remove
themselves from imminent danger without
permission.
ILO Convention 155, 183 and
recommendation 164
GSCP
(a) A safe and hygienic working
environment is to be provided.
(b)1. Steps are to be taken to prevent
accidents arising out of, associated with,
or occurring in the course of work.
(b)2. Provide adequate safeguards
against fire.
(b)3. Suppliers shall establish and follow
a clear set of procedures regulating H&S.
(c) Workers shall receive regular and
recorded H&S training.
(d) Clean toilet facilities and potable water
to be provided & if appropriate sanitary
food storage facilities.
(e) Accommodation shall be clean, safe &
hygienic.
(f) There should be a senior management
representative for H&S.
Additions
- Appropriate PPE provided by suppliers and
workers access to medical assistance and
facilities.
- Adequate fire safety, safe buildings and
equipment.
- Workers to be trained in waste management
(handling & disposal of chemicals & other
dangerous materials).
- Suppliers to provide access to adequate
medical assistance & facilities.
ILO Convention 155, 161, 164 - other
applicable standards
Page 8

4 Child labour shall not be
used
Comparison of Codes - Similarities & Additions
Comparison of Codes: Reference ETI Base Code, SA8000 & GSCP
ETI Base code
(a)1. No new recruitment of child labour.
(a)2. These policies and procedures shall
conform to the provisions of the relevant
ILO standards.
(b) Develop, participate & contribute to
policies and programmes for transition
enabling them to attend and remain in
education.
(c) Young workers not to be employed at
night or in hazardous conditions.
ILO Conventions 138, 182 and
Recommendation 146, 190
SA 8000
(a) The company shall not engage nor
support the use of Child labour.
(b) Effectively establish & communicate
procedures for remediation, with
adequate financial and other support to
remain in school.
(c) The company shall not expose
children or young workers to night work,
any hazardous conditions or work unsafe
to mental/physical development.
Additions
- The children or young workers shall not be
exposed to these conditions in or outside of the directly and indirectly for the supplier.
work place.
- Work only outside of school hours, no more
than combined 10 hours/day (including
school, work and travel).
- Young workers shall work for no more than
8 hours/day.
ILO Convention 138, 182 and
recommendation 146
GSCP
(a)1. No new recruitment or exploitation of
child labour.
(a)2. Suppliers shall comply with national
min age, age of completion of compulsory
education or otherwise specified
exceptions however no less than 15,
whichever is higher. By ILO 138 exception
14 may apply.
(b) Sensitive and satisfactory solution with
child's best interest first.
(c) Young workers not to be employed at
night or in hazardous conditions which
compromise their health, safety, moral
integrity, physical, mental, spiritual, moral
or social development.
Additions
- This applies for children working both
ILO Convention 138, 182 – Fundamental
principles
ILO Convention 190 - other applicable
standards
Page 9

5 Living wages are paid
Comparison of Codes - Similarities & Additions
Comparison of Codes: Reference ETI Base Code, SA8000 & GSCP
ETI Base code
(a) National legal standards/industry
benchmark standards (income should meet
basic needs & provide discretionary
income).
(b) Written & understandable employment
conditions in respect to wages before
employment & each payment period.
(c) No deductions as a disciplinary means
(except legal deductions).
(d) All disciplinary measures should be
recorded.
Additions
- Only disciplinary deductions with the
expressed permission of the worker concerned. permitted by law and collective bargaining.
ILO Convention 100, 111, 81, 122 and
Recommendation 90 & 111 – Core
conventions
ILO Convention 131 – Relevant to ETI
SA 8000 GSCP
(a) Living wage stated requirement, (a) National legal standards/industry
national legal standards/industry benchmark standards/collective bargaining
benchmark standards (income should meet agreements (income should meet basic
basic needs & provide discretionary needs & provide discretionary income for
income). workers and their families) whichever is
more favourable.
(b) Wages & benefits are written & detailed (b) Written & understandable employment
clearly for each payment period. conditions in respect to wages before
employment & each payment period.
(c) No deductions as a disciplinary means (c) No deductions as a disciplinary means
(except legal deductions & freely (outside legal deductions).
negotiated collective bargaining
agreement).
(d) All disciplinary actions recorded
(appears in ‘Discrimination Harassment and
Abuse’ section).
Additions
- Only disciplinary deductions only when both;
- Paid in cash/check (convenient for workers).
ILO Convention 100 ILO Convention 100 – Fundamental principle
ILO Convention 95, 131, 135, 85 - other
applicable standards
Page 10

6 Working hours are not
excessive
7 No discrimination is
practised
Comparison of Codes - Similarities & Additions
Comparison of Codes: Reference ETI Base Code, SA8000 & GSCP
ETI Base code
(a) W orking hours shall comply with
national law & industry benchmark
standards (whichever provides more
protection).
(b) No more than 48 hours per week.
(c) Overtime voluntary and no more than
12 hours/week, not regular.
(d) One day off for every 7 day period.
(e) Overtime at premium rate.
ILO Convention 175 – Relevant to ETI
(a) There is no discrimination, on hiring,
compensation, promotion, termination, or
retirement etc.
ILO Convention 159 and Recommendation
168 – relevant to ETI
SA 8000
(a) The company shall comply with national
law & industry benchmark standards
(whichever provides more protection)
including public holidays.
(b) No more than 48 hours per week.
(c) Overtime is voluntary and no more
than 12 hours/week, not regular.
(d) One day off for every 7 day period.
(e) Overtime shall be paid at a premium
(appears in ‘Remuneration’ section).
Additions
- exception to (d) if national law allows work
time averaging and collective bargaining
agreement is in place.
- If short-term business needs must still
comply with collective bargaining agreement.
ILO Convention 1, 116
(a) No engagement in discrimination on
hiring, compensation, promotion,
termination, or retirement etc.
Additions
- No interference with the exercise of
personnel's rights to observe practices which
could give rise to discrimination.
- The company shall not subject any
personnel to pregnancy/virginity tests.
ILO Convention – 100, 111, 102, 131, 159,
169
GSCP
(a) Suppliers shall set working hours that
comply with national law & industry
benchmark standards (whichever provides
more protection).
(b) No more than 48 hours per week
excluding overtime.
(c) Overtime shall be voluntary and no
more than 12/week, not regular.
(d) One day off for every 7 day period.
(e) Overtime shall be paid at a premium
(appears in ‘Wages, benefits and terms of
Employment’ section).
Additions
- Suppliers will respect workers right to public
and annual holidays.
- Respect workers right to breaks during work
shifts.
ILO Convention 1, 14, 116 – other applicable
standards
(a) No engagement, support or tolerance
of discrimination on hiring, compensation,
promotion, termination, or retirement etc.
Additions
- Suppliers shall respect equal opportunities.
- Base all terms & conditions of employment on
an individual’s ability to do the job.
ILO Convention 111 – Fundamental principle
Page 11

8 Regular employment is
provided
Comparison of Codes - Similarities & Additions
Comparison of Codes: Reference ETI Base Code, SA8000 & GSCP
ETI Base code
(a) As much as possible, work must be
performed on a recognised employment
relationship (according to law).
(b)1. Obligations to employees shall not
be avoided by: labour-only contracting-
sub-contracting- home-working
agreements - apprenticeship schemes-
where there is no real intent to impart
skills or provide regular employment.
(b)2. Obligations include meeting Labour
and social security laws.
ILO Convention 177 and Recommendation
184 – Relevant to ETI
SA 8000
(b)1. Obligations to employees shall not
be avoided by:- labour-only contracting-
sub-contracting- home-working false-
apprenticeship schemes- where there is
no real intent to impart skills or repeated
fixed term contracts (appears in
‘Remuneration’ section).
(b)2. The company should supply all
legally required benefits (appears in
‘Remuneration’ section).
ILO Convention 177
GSCP
(a) Work must be performed on a
recognised employment relationship
(according to law) (appears in 'Wages,
Benefits and Terms of Employment’ section).
(b)1. Obligations to employees shall not
be avoided by:- labour-only contracting-
sub-contracting- home-working
agreements - apprenticeship schemes- or
where there is no real intent to impart
skills or provide regular employment
(appears in ‘Wages, Benefits and Terms of
Employment’ section).
(b)2. Supply all legally required wages,
overtime pay, benefits and paid leave
which respectively meet or exceed legal
min. and/or industry benchmark
standards and/or collective agreements,
whichever is higher (appears in ‘Wages,
Benefits and Terms of Employment’ section).
ILO Convention 184 - other applicable
standards
Page 12

9 No harsh or inhumane
treatment is allowed
10 Management systems
Comparison of Codes - Similarities & Additions
Comparison of Codes: Reference ETI Base Code, SA8000 & GSCP
ETI Base code
(a) There shall be no physical or threat of
abuse nor harassment, verbal abuse or
other forms of intimidation.
NIL
SA 8000 GSCP
(a)1. No bullying/harassment/abuse of (a) No bullying/harassment/abuse of
any kind (appears in ‘Discrimination’ any kind (appears in ‘Discrimination,
section). Harassment and Abuse’ section).
(a)2. No harsh or inhumane treatment
(appears in ‘Disciplinary Practices’
section).
Additions Additions
- Personnel are to be treated with respect & -Workers are to be treated with respect &
dignity (appears in ‘Disciplinary Practices’ dignity (appears in’ Discrimination,
section). Harassment and Abuse’ section).
- Written disciplinary procedures established
and effectively communicated (appears in
‘Discrimination, Harassment and abuse
’section)
Additions NIL
- Policy.
- Management Representative.
- SA8000 Worker Representative.
- Management Review.
- Planning & Implementation.
- Control of Suppliers, Sub-contractors and
Sub-suppliers.
- Addressing Concerns and Taking Corrective
Action.
- Outside Communication and Stakeholder
Engagement.
- Access for Verification and Records.
Page 13
 Comparison of Codes: Reference ETI Base Code, SA8000 & GSCP

Legend:

Indicates each comment. Each letter

(across all three codes) indicates an
(a) agreement.
Where a single ETI paragraph
(a)1. includes more than one comment, the
(a)2. comments have been split
There shall be no physical Similarities (Arial Font)
Personnel are to be treated Additions (Times New Roman Font)
Where the comment is detailed under
(Disciplinary Practices section) a different section of the code (Italics).

This Code Comparison Document has been produced by Sedex to give members guidance on the scope of 3 common codes (ETI Base Code, SA8000 and GSCP Reference Code). The author has used interpretation
to simplify and align the language used by these codes. Hence opinions expressed in this document are the subjective opinions of Sedex and do not necessarily represent the opinions of other companies referred to in
this document.
The inclusion or reference to external companies or codes does not constitute endorsement, recommendation, or approval of those companies, codes or their contents. This document bears no responsibility for the
accuracy, legality or content of the external parties or for the content of their codes and publications.
The document is not designed for compliance, rather a tool to see the overlap of requirements for the codes. Please see the individual websites for the full codes:
1. ETI Base Code – www.eti.org.uk
2. SA8000 - www.sa-intl.org
3. GSCP Reference Code – www.gscpnet.com
Material in this document, including text and images, is protected by copyright. It may not be copied, reproduced, republished, downloaded, posted, broadcast or transmitted in any way except for your own personal,
non-commercial use.
Please note these materials may be changed without notice.

Comparison of Codes - Similarities & Additions Page 14