Responsible Business Conduct

1. Responsible Business Conduct

Le Nouveau Chef’s Responsible Business Conduct has been drawn up to concur that both Le Nouveau Chef and its suppliers contribute to a fairer and more sustainable world. We care for our products, the materials and the complete supply chain related to our carefully designed and produced products. We aim for long term relations with our business partners to manufacture and co-create the most beautiful product, but also to take care of the people involved. We would like to get insight in the social and environmental impact of our products and work on improvement where needed. Transparency of production places and circumstances are of great importance.

Le Nouveau Chef has a responsible purchasing policy based on social and environmental criteria for the supply chain based on international standards, conventions, and guidelines. Working in compliance with all applicable laws and regulations on human rights, the environment and product safety is of great importance, but international standards are leading if they are more stringent.

We ask all our suppliers and subcontractors, from raw material to product, to support us in our corporate responsibility program and to work according to the standards below. 

2. Our common responsibility: Due diligence

Under the UNGPs and OECD Guidelines enterprises bear a responsibility for preventing and reducing any adverse impact on people and the environment by their own operation or business relationships in the production or supply chain. This means acting in an ethical and transparent way that contributes to the health and welfare of society. This is the baseline for our Due Diligence policy integrated in our corporate responsibility program.

Le Nouveau Chef supports the Conventions of the International Labour Organisation (ILO) and expects suppliers to act in accordance with the conventions of the ILO. These conventions are, along with the relevant UN Declarations and the OECD guidelines, the basis for our responsible business conduct.

The themes listed below, in random order, have been identified by mutual agreement and in discussion with stakeholders which currently merit the priority attention of enterprises in the textile sector in terms of international responsible business conduct (RBC).

1. Discrimination and gender;

2. Child labour;

3. Forced labour;

4. Freedom of association;

5. Living wage;

6. Safety and health in the workplace;

7. Raw materials;

8. Water pollution and use of chemicals, water and energy;

9. Animal welfare.

We added, based on the ILO and OECD guidelines for the promotional industry:

• Working hours

• Ethical trade, no bribery and corruption

• No Sexual harassment and sexual and gender-based violence (SGBV) in the workplace

• Grievance mechanism

We will do our due diligence and give particular attention to these themes, and we expect this as well from our suppliers. Based on these themes, suppliers will identify any possible adverse impact in the supply chain, set specific objectives and take measures which are suitable in the light of the insights resulting from their due diligence process. We ask you to inform us about any possible risks regarding human rights violation, animal abuse and environmental hazards related to our products to cooperate minimising these risks. 

3. Buying behaviour

We are part of the value chain and therefore we take our responsibility regarding sourcing and buying. It is very important to inform us when our buying behaviour does not support the international social and environmental standards, set below. We work according to the following buying strategy: 

Forecasting:
We prefer long-term relationships to increase predictability and stability. This will also enable suppliers to plan for investments in machinery, equipment, and human resources.

We will:

• Work on stable planning;

• Share forecast and purchasing plan with our suppliers and, if possible, book capacity; 

• Allow to start production early for NOS styles (NOS = Never Out of Stock);

• Communicate changes in our forecast/purchasing plan on time. 

Product development:

• Provide clear technical specs and requirements; 

• Ask our suppliers for feedback on new developments;

• Review our sampling process with efficiency in mind; 

• Work with photos/online videos when possible or consider digital prototyping; 

• Supply a target price for the product. 

Price negotiation:

• Get insights in price calculations and the production process;

• Calculate in cooperation with our suppliers and get help to get the best quality for the best price; 

• Consider material costs, labour, transport, testing, audits and the profit for the supplier. 

Payment conditions:

• Pay on time;

• Pay what we agreed on order placement, production, lead time; 

• We have a time and action plan with deadlines for all contributors (buyer and supplier); 

• We agree on a realistic lead time;

• We make agreements on late style/order changes; 

• We work on understanding the local and cultural differences.
  
  

4. Social responsibility

The responsible business conduct aims to attain compliance with certain standards. Supplier companies, in addition, must ensure that the responsible business conduct is also observed by subcontractors involved in production processes of final manufacturing stages. Within the scope of options for action and appropriate measures, supplier companies must aim at the implementation and reporting of the following criteria in a development approach. Le Nouveau Chef declares to only work directly with subcontractors that are prequalified through the same rigorous processes to those used for direct contractors. Approved subcontractors may be reviewed on a semi-regular (e.g. annual) basis to remain approved. Workers of those sub-contractors should have access to grievance mechanisms, like those of direct contractors. We ask for transparency to know where our products are made and to be able to ask questions regarding social and environmental conditions.

4.1 Legal requirements and international guidelines
The labor standards are based on the ILO convention, the OECD Guidelines and the Universal Declaration of Human Rights.

4.2 No child labour and working conditions of young workers
The supplier respects United Nations regulations on human and children’s rights and ILO Conventions 10, 79, 138, 142 and 182 and Recommendation 146. There is a minimum age for admission and there shall be no use of child labour. 

The age for admission to employment shall not be less than the age of completion of compulsory schooling and, in any case, not less than 15 years. There shall be no forms of slavery or practices similar to slavery, such as the sale and trafficking of children, debt bondage and serfdom and forced or compulsory labour. Young workers [in the age of 15-18] shall not perform work which, by its nature or the circumstances in which it is carried out, is likely to harm their health, safety or morals. Children and young persons under 18 shall not be employed at night or in hazardous conditions. Where young workers are employed, business partners should ensure that the kind of work is not likely to be harmful to their health or development; their working hours do not prejudice their attendance at school, their participation in vocational orientation approved by the competent authority or their capacity to benefit from training or instruction programs. Business partners shall set the necessary mechanisms to prevent, identify and mitigate harm to young workers; with special attention to the access young workers shall have to effective grievance mechanisms and to Occupational Health and Safety training schemes and programmes.

Child Labour Due Diligence Bill
By signing this RBC you take part in our Due Diligence Policy and you approve that you will do anything you can to identify, prevent and if necessary address the issue of child labour in our supply chain. We ask our suppliers to cooperate and be transparent about sub- contractors and sub-suppliers and possible risks within the supply chain of our products so we can cooperate in combating child labour. Risk studies show that the severe risks are mainly at cotton farming and wet processing (like spinning mill) stage. 

Le Nouveau Chef’s Product Manager needs to be informed in high-risk situations, for example when cotton comes from countries or facilities where forced labour is required and so the risks on child labour occurs. Ask your suppliers about their social management systems, latest audit reports or certifications like WRAP, SA 8000, Fair Trade, GOTS, Better Cotton or Organic Content Standard, or any other standard that entails Child labour.

4.3 Prohibition of Forced and compulsory Labour and Disciplinary Measures
Based on ILO Conventions 29 and 105, there shall be no use of force, including bonded or prison labour. All forms of forced labour, such as lodging deposits or the retention of identity documents from personnel upon commencing employment, are forbidden as is prisoner labour that violates basic human rights.

4.4 Prohibition of Discrimination
Based on ILO Conventions 100, 111, 143, 158, 159, 169 and 183, no discrimination shall be tolerated in hiring, remuneration, access to training, promotion, termination, or retirement based on gender, age, religion, race, caste, birth, social background, disability, ethnic and national origin, nationality, membership in workers’ organisations including unions, political affiliation or opinions, sexual orientation, family responsibilities, marital status, or any other condition that could give rise to discrimination. Beyond non-discrimination, we expect suppliers to actively support diversity and inclusion in their workforce, in line with our Sustainable Procurement Policy. Particular attention shall be paid to migrant, seasonal and agency workers, who shall receive equal treatment and equal access to the grievance mechanism, and shall not be charged recruitment fees.

4.5 No Sexual harassment and sexual and gender-based violence (SGBV) in the workplace
Our business partners are encouraged to adopt a zero-tolerance policy on sexual and gender-based violence and strict measures against sexual harassment in its own operations. The enterprise should articulate its expectations of suppliers and other business partners to likewise adopt a policy on sexual harassment and sexual and gender-based violence. Enterprises are encouraged to include the following in their internal policies: 

• a commitment to foster an environment at work free from harassment, bullying and violence

• clear consequences for breaking the enterprise’s standards 

• a commitment to hear grievances, to provide a “reprisal-free” complaints mechanism (e.g. operational-level-grievance mechanism) and to maintain the confidentiality of workers or employees who raise complaints

4.6 Freedom of Association and the Right to Collective Bargaining
Based on ILO Conventions 11, 87, 98, 135 and 154 all workers have the right to form and join trade unions and bargain collectively shall be recognised and follow the local labour laws of the countries. The company shall, in those situations in which the right to freedom of association and collective bargaining are restricted under law, facilitate parallel means of independent and free association and bargaining for all workers. Workers' representatives shall not be the subject of discrimination and shall have access to all workplaces necessary to carry out their representation functions. 

4.7 Payment of a living wage 
Based on ILO Conventions 26 and 131 wages and benefits paid for a standard working week shall meet at least legal or industry minimum standards and always be sufficient to meet basic needs of workers and their families and to provide some discretionary income. Deductions from wages for disciplinary measures shall not be permitted nor shall any deductions from wages not provided for by national law be permitted. Deductions shall never constitute an amount that will lead the employee to receive less than the minimum wage. Employees shall be adequately and clearly informed about the specifications of their wages including wage rates and pay period.

4.8 Working Hours
Based on ILO Conventions 1 and 14 and ILO Recommendation 116, hours of work shall comply with applicable laws and industry standards. In any event, workers shall not on a regular basis be required to work in excess of 48 hours per week and shall be provided with at least one day off for every seven-day period. Overtime shall be voluntary, shall not exceed 12 hours per week, shall not be demanded on a regular basis and shall always be compensated at a premium rate. 

4.9 Safe and healthy working conditions
Based on ILO Convention 155, a safe and hygienic working environment shall be provided, and best occupational health and safety practice shall be promoted, bearing in mind the prevailing knowledge of the industry and of any specific hazards. Appropriate attention shall be paid to occupational hazards specific to this branch of the industry and assure that a safe and hygienic work environment is provided for. Effective regulations shall be implemented to prevent accidents and minimise health risks as much as possible. Physical abuse, threats of physical abuse, unusual punishments or discipline, sexual and other harassment, and intimidation by the employer is strictly prohibited.

4.10 Legally binding employment relations
Obligations to employees under labour or social security laws and regulations arising from the regular employment relationship shall not be avoided using labour-only contracting arrangements, or through apprenticeship schemes where there is no real intent to impart skills or provide regular employment. Younger workers shall be given the opportunity to participate in education and training programmes. Agency and labour-only workers shall enjoy terms and protections equivalent to directly employed workers and shall not be used to circumvent obligations under labour or social security law.

4.11 Ethical trade: no bribery and corruption
Enterprises should consider the good practices put forth in the OECD Good Practice Guidance on Internal Controls, Ethics and Compliance, which includes:

• Strong, explicit, and visible support and commitment from senior management to the company's internal controls, ethics and compliance programmes or measures for preventing and detecting bribery, including the bribery of foreign public officials.  

• A clearly articulated and visible corporate policy prohibiting bribery, including the bribery of foreign public officials; and 

• Oversight of ethics and compliance programmes or measures regarding bribery, including the bribery of foreign public officials, including the authority to report matters directly to independent monitoring bodies such as internal audit committees of boards of directors or of supervisory boards, is the duty of one or more senior corporate officers, with an adequate level of autonomy from management, resources, and authority.

4.12 Grievance mechanism
Le Nouveau Chef is committed to hearing grievances from workers and supply-chain stakeholders, to providing a reprisal-free complaints mechanism, and to maintaining the confidentiality of anyone who raises a complaint. The mechanism is accessible to all, regardless of language, literacy, gender, migrant status or disability, and allows anonymous and confidential reporting. Our grievance procedure is publicly available at: https://lenouveauchef.com/pages/grievance-procedure

We expect our suppliers to provide their workers with access to an equivalent, reprisal-free grievance mechanism, and to inform Le Nouveau Chef of any grievance that relates to the production of our products.

 

5. Environmental Responsibility

Suppliers should assess significant environmental impact of operations and establish effective policies and procedures that reflect their environmental responsibility. They will seek to implement adequate measures to prevent or minimise adverse effects on the community, natural resources, and the overall environment. Le Nouveau Chef asks suppliers to have procedures and standards for the use of water and energy, handling and disposal of chemicals and other dangerous materials, waste management, emissions, and effluent treatment. The procedures and standards must meet at least the minimum legal requirements.

5.1 No use of energy of non-renewable sources and minimising Greenhouse Gas (GHG) emissions
Suppliers should keep records of the current energy sources and emissions and reduce the use of energy of non-renewable sources. Targets should be set to work with green energy sources and thus reduce emissions to air. The consumption of energy of non-renewable origin is one of the main causes of greenhouse gas emissions. The production of textile and garments is an energy intensive process. Measuring GHG emissions is a critical first step to reducing the carbon footprint of an enterprise’s activities. It helps an enterprise to assess its impact on the climate and to design cost-effective emission reduction plans.

• We encourage you to establish an energy management plan at the site-level that includes company-wide coordinated measures for energy management. We ask our suppliers to measure, report and minimise their energy consumption and GHG wherever possible. 

• Also, we do encourage our suppliers to make use of renewable energy sources like wind- and solar energy. We ask our supplier to research and use technologies which use less energy, like LED lightning. 

• Implement best available techniques (BAT) as defined by Best Available Techniques Reference Documents for the sector or sub-sector.

• Implement energy efficiency measures (e.g. energy conservation technology, optimization of steam generation and pressurised air, waste heat recovery from wastewater and waste gas, process optimization, etc.) 

• Implement energy conservation measures (e.g. implementation of energy saving through improvements in the process and reaction conditions) 

• Increase efficiencies and quality to reduce need for re-processing due to failures 

• Install and operate accurate metres and/or measuring software as a fundamental step to benchmarking performance and to initiating efficiency improvement 

5.2 Limitations to water use and clean wastewater 
The supplier should measure water use and determine whether it can source from water stressed areas responsibly, for example, by promoting water efficiency and/or reducing process dependence on fresh water amongst its suppliers. Wastewater should be treated and tested before releasing it to the environment. The supplier should comply with national wastewater legislation.

Throughout the production of textiles, a lot of water is used. In general, most water is used for cotton cultivation (2/3 or more of the total volume). Textile processing uses far less water but causes most water pollution. This puts great pressure on the availability and the quality of water in areas where cultivation and processing take place. Water use, the source and wastewater in the wet processing also deserves serious attention, because of the local pollution impact. 

• We ask our suppliers to deliver a (waste) water policy, testing procedure and/or a copy of one of the standards. We ask our suppliers to provide (LCA) data on water, energy and chemicals and emissions. Use the ZDHC (Wastewater) guidelines and the Unido water calculator: https://watercalculator.dnvgl.com/Home/Form. 

• We want to be informed about the water source (rain, groundwater, lake, etc) 

• We would like to offer suppliers more information on a cleaner production process through the ZDHC or OECD guidance which we could provide to you. 

5.3 No hazardous Chemicals 
No hazardous chemicals shall be used in the processing stage and released in water or air. Employees shall be protected and equipped with the right safety measures and appropriate training. Chemicals shall be stored and labelled accurately. 

Chemicals are used everywhere in the production of goods. Apart from the pesticides and fertilisers in the natural fibre production, the ‘big’ issue, mainly in the textile chain, is the use of chemicals in bleaching, dyeing, printing, and finishing and how it affects workers, water and air effluents. 

• Design phase: The base of the use of chemicals lies in the design choices. We ask our business partners to inform us if any design decision leads to the use of hazardous chemicals. 

• Manage and report production phase: From there it is important for our company to know which specific chemicals are used (chemical inventory) and how they are used in the processing of the product. The use of harmful chemicals during these stages of production could be harmful for the environment and the workers and may leave traces in the final product and thus appear to the consumer. 

• We highly suggest you make a Chemical Risk assessment: An environmental or human health risk assessment includes hazard identification, hazard characterization, exposure assessment and risk characterization.

The first two steps are regarded as the process of hazard assessment. The methodology of the environmental risk assessment should align with OECD guidance. See OECD Environmental Risk Assessment Toolkit. The methodology of the health risk assessment should align with the World Health Organisation guidance. See International Program on Chemical Safety, WHO Human Health Risk Assessment Toolkit: Chemical Hazards. Health risks are also addressed in Module 5, Occupational Health and Safety.

5.4 Restricted Substances List (RSL)/ Manufacturing Restricted Substances List (MRSL)
The Restricted Substances List (RSL/MRSL), maintained as a separate document and provided directly to suppliers, informs our suppliers of international and upcoming regulations restricting or banning substances in apparel products, in accessories attached to garments (e.g. zip fasteners, buttons) and in packaging materials. The RSL accounts for most of the world's regulations (incl. REACH, POP and EU Regulation 2025/40 on packaging and packaging waste) as well as harmful substances listed by NGOs.

The RSL and MRSL are reviewed and updated periodically and are provided to suppliers separately from this published RBC. The version in force is the most recent dated version communicated by Le Nouveau Chef.

• We ask our suppliers to purchase materials without harmful substances. Please inform your raw material supplier about the RSL and risk matrix where chemicals are related to certain raw materials and processing steps and inform Le Nouveau Chef about test results based on risk assessments.

• If the supplier buys directly from chemical agencies, make sure it is firm with a CR management system (CR = Corporate Responsibility). 

• Make use of the (ZDHC)MRSL (https://www.roadmaptozero.com/mrsl_online). It is there to provide suppliers with a harmonised approach to managing chemicals during the processing of raw materials into the readymade fabric within our supply chain. The MRSL achieves this by providing a clear list of priority chemicals and specifying the maximum concentration limit of each substance within commercial chemical formulations. 

• We ask our suppliers to inform us about wet processing management (of sub suppliers) to eliminate hazardous chemicals from our products, to keep a chemical inventory and to work with Material Safety Data Sheets for workers. Inform us when you/sub suppliers cooperate with ZDHC or Amfori BEPI. 

• Implement best available techniques (BAT) as defined by Best Available Techniques Reference Documents for the sector or subsector. See Integrated Pollution Prevention and Control, Best Available Techniques Reference Document for the Textiles Industry, 2003). 

5.5 Valid processing standards
A valid health OEKO-TEX® Standard 100 product certificate covers most of the legal requirements of this RSL. Processing standards are of higher value, like: GOTS, Blue Sign or Step (or similar). Substantiation of environmental claims: Where a supplier asserts any environmental or sustainability characteristic, certification or claim in respect of materials, processes, products or packaging supplied to Le Nouveau Chef, the supplier shall, on request, provide verifiable evidence substantiating that claim (e.g. valid scope and transaction certificates, accredited test reports, LCA data or recognised third-party certification). Generic or unsubstantiated environmental claims (e.g. "eco-friendly", "green", "sustainable" without supporting evidence) shall not be made. This enables Le Nouveau Chef to meet its obligations under Directive (EU) 2024/825 on empowering consumers for the green transition and related EU rules on environmental claims.

5.6 Raw materials policy
Le Nouveau Chef aims to reduce the impact of its raw materials. We ask our suppliers to keep records on the content and source of our raw materials. 

• To source for sustainable or preferred raw materials and offer alternatives to conventional materials. 

• It is important to measure, reduce and reuse material waste where possible. 

• We ask our suppliers to use one of the certifications and standards and to provide us with a copy of the scope- and transaction certificates.

• Suppliers shall provide, on request, the content and recycled-content percentage of materials supplied, together with supporting evidence, so that Le Nouveau Chef can substantiate its own product and regulatory claims.

5.7 Animal welfare
We ask suppliers of wool, silk, leather, down and feathers and any other animal derived fibre:

• To prevent, reduce and eradicate animal suffering in the production or supply chain.

• To provide animal welfare guarantees when products of animal origin are used.

• To follow below provision guidelines where animals are concerned in our supply chain:
  

1. 1. Freedom from Hunger and Thirst: by ready access to fresh water and a diet to maintain full health and vigour.

   2. Freedom from Discomfort: by providing an appropriate environment including shelter and a comfortable resting area.

   3. Freedom from Pain, Injury or Disease: by prevention or rapid diagnosis and treatment.

   4. Freedom to Express Normal Behaviour: by providing sufficient space, proper facilities and company of the animal's own kind.

   5. Freedom from Fear and Distress: by ensuring conditions and treatment which avoid mental suffering.

5.8 Endangered Species Policy
Le Nouveau Chef does not accept any raw materials from any endangered species as listed on the IUCN Red List, as critically endangered, near threatened, endangered, extinct in the wild, or vulnerable on the IUCN Red List. Therefore, suppliers must provide animal welfare guarantees when products of animal origin are used. Le Nouveau Chef does not accept Real exotic animal skins (incl. snake, alligator, crocodile, lizard and ostrich).

5.9 Down Feathers Policy 
Le Nouveau Chef does not accept Down/Feathers from live-plucked birds and from force fed birds. Le Nouveau Chef only accepts Down/Feathers from meat production and prefers Down/Feathers that are certified to the Textile Exchange Responsible Down Standard. 

• Our business partners must submit a declaration or certificate guarantee that all Down filled garment/items are Non-live plucked down.

5.10 Man-made Cellulosic Fibres Policy
Le Nouveau Chef does not accept products (Viscose, Rayon, Modal and Lyocell) deriving from illegally logged sources, ancient and endangered forests, as listed in the IUCN Red list as critically endangered, near threatened, endangered, extinct in the wild, or vulnerable. Le Nouveau Chef prefers sustainably certified wood products (e.g. FSC).

5.11 Packaging 
Le Nouveau Chef is the brand owner of its packaging and therefore acts as the manufacturer for the purposes of EU Regulation 2025/40 on packaging and packaging waste (PPWR). Le Nouveau Chef is responsible for drawing up and signing the Declaration of Conformity (DoC) for its packaging. Suppliers are not asked to sign this DoC; they are required to provide the underlying data and a data warranty. 

For all packaging supplied to, or used for, Le Nouveau Chef products, suppliers shall:

• provide accurate and complete composition data (materials, weights, recycled content, substances of concern) for each packaging item and its components, including shipping labels and polybag labels;

• complete and sign the Le Nouveau Chef Supplier Packaging Declaration & Data Warranty, provided to suppliers separately, warranting that the data supplied is accurate and that the packaging meets the applicable substance limits set out in the RSL, including the heavy-metals sum limit of 100 mg/kg (lead, cadmium, mercury, hexavalent chromium) and the MOSH/MOAH limits under Regulation 2025/40;

• notify Le Nouveau Chef of any change to packaging composition, supplier or specification that may affect conformity;

• support recyclability and minimisation by offering reusable, recycled and reduced packaging, and by providing design-for-recycling and recycled-content evidence on request.

5.12 Plastic
Suppliers shall prioritise preferred plastics for our products and packaging, such as recycled plastics, substantiated by GRS or equivalent certification. For plastic packaging, suppliers shall provide the recycled-content percentage with supporting evidence and shall ensure the packaging is designed for recyclability in line with PPWR requirements.

5.13 Cardboard
We ask our suppliers to use recycled or FSC/PEFC certified cardboard. We aim to only use cardboard and paper packaging which consists of 100% recycled paper fibre.

5.14 Waste reduction 
We ask our suppliers to reduce (raw) material waste as much as possible and preferably join a recycling program (packaging waste, material cutting waste etc.)

6. Management System, monitoring, documentation, verification

The supplier company shall define and implement a management system to ensure that the requirements of the Responsible Business Conduct can be met. Management is responsible for the correct implementation and continuous improvement by taking corrective measures, as well as the communication of the requirements of the RBC to all employees and subcontractors. It shall also address employees’ concerns of non-compliance with this Code of Conduct. Le Nouveau Chef will be informed about non-compliances and follow up.

• If the buying behaviour of Le Nouveau Chef impacts the compliance to this RBC we will be informed immediately.

The requirements in the Responsible Business Conduct are requirements that we want to achieve together. These are our common goals. We are open for discussion if suppliers are not able to meet these requirements. We are certain that many of our suppliers have even higher demands of themselves. Therefore, we want you to provide us with the relevant certifications and reports to confirm this. By signing this RBC statement, you commit yourself to it.

The Restricted Substances List / MRSL and the Supplier Packaging Declaration & Data Warranty are separate documents that Le Nouveau Chef provides directly to its suppliers. Le Nouveau Chef may update these documents from time to time to reflect regulatory or other developments. The version in force is the most recent version communicated by Le Nouveau Chef. By signing this RBC, the supplier accepts these documents as amended from time to time; routine updates do not require this RBC to be re-signed, unless Le Nouveau Chef indicates otherwise.

CEO Le Nouveau Chef Supplier/Subcontractor
Name: Paul van Luipen