Code of Conduct

Purpose

This Code sets out how Asgaardian ApS does business and what we ask of the people we do business with. Every point here is something a partner can hold us to, and something we can hold a partner to.

Who it applies to

This Code binds Asgaardian ApS, everyone working for us, and every supplier, manufacturing partner and distributor acting on our behalf. It reaches their own suppliers and subcontractors too. A partner who uses a subcontractor stays responsible to us for how that subcontractor behaves.

Where a partner has its own equivalent code, whichever standard is higher applies. Where this Code conflicts with the law of the country a partner works in, the law applies, and we expect to be told about the conflict.

1. Law comes first

We follow the law wherever we operate, and we expect the same of our partners. Where this Code asks for more than local law requires, this Code applies.

Our reference points are the UN Global Compact, the Universal Declaration of Human Rights, the core conventions of the International Labour Organization, and the OECD Guidelines for Multinational Enterprises.

2. Human rights and labour

• No child labour. No one under the legal minimum working age, or under the age at which compulsory schooling ends, whichever is higher. No one under 18 in hazardous work. If we ever find a child in a supply chain of ours, the child's welfare governs our response.
• No forced labour. No bonded, indentured or involuntary work. No retention of identity documents. No recruitment fees charged to workers, and no deposits or bonds. Every worker is free to leave the job.
• Employment is declared. Workers are hired lawfully, registered and paid through the books. Undeclared and clandestine employment breaches this Code.
• Freedom of association. Workers may organise and bargain collectively without fear.
• No discrimination. In hiring, pay, training, promotion, maternity protection or termination, on any ground.
• Fair pay and hours. Wages meet or exceed the legal minimum and are paid on time, at least monthly. Pay is never docked as a punishment. Working hours respect legal limits, overtime is voluntary and paid at the legal rate, and every worker gets at least one day off in seven.
• Dignity at work. No harassment, no abuse, no threats. No corporal punishment, and no physical, sexual, verbal or psychological mistreatment of any kind.

3. Health and safety

Workplaces must be safe. Hazards are assessed and controlled, protective equipment is provided and used, emergency routes are clear and drilled, and machine safety is maintained. Workers are trained for the risks the job carries. Accidents are recorded, investigated and acted on. Where a partner houses workers, the accommodation is held to the same standard.

4. Environment

We make a plastic product. Our environmental statements are specific and documented.

• Materials are chosen for compliance and durability. Our sleeves are polypropylene, acid-free and PVC-free, REACH compliant on the basis of supplier declarations, and packed in a retail box of paperboard from an FSC-certified supplier.
• Our sleeves are designed in Denmark and produced in Europe (CZ).
• We publish environmental claims only where we hold documentation for them. Vague or unsupported environmental language is not permitted in our own marketing, or in a partner's marketing of our products.

5. Product quality and safety

Our sleeves are a consumer product under EU product safety law, and we keep the safety documentation that goes with them. Every production run carries a batch code printed on the packaging, so any batch traces back to its own quality record. We publish a Declaration of Conformity.

A partner may not change materials, specification, production site or sub-supplier on our products without our written agreement. Stock carrying our name that we did not order, or that we rejected, is never sold or released through another channel. It is destroyed or returned to us on our instruction.

Quality is never settled, and we keep improving it. A partner who tells us about a problem early helps us do that.

6. Business integrity

• No bribery or corruption, in any direction, including facilitation payments, extortion and fraud.
• No money laundering. Payments have a lawful origin that can be traced.
• No anti-competitive conduct. No price fixing, no market sharing, no exchange of commercially sensitive information with competitors.
• Sanctions, export controls and customs law are observed. Customs declarations are accurate, and goods are not routed to disguise where they came from.
• Gifts and hospitality stay modest, open and lawful. Nothing is given or accepted in the expectation of something in return.
• Conflicts of interest are declared to us in writing.
• Confidential information and intellectual property, ours, our partners' and third parties', are protected. Tooling, designs and specifications we pay for remain ours.
• Public statements. A partner does not speak for Asgaardian, and does not attribute a statement to us, without our agreement.
• Say what is true. What a partner tells us about materials, methods, production sites and the products themselves is accurate and complete. Misleading claims breach this Code.

7. Personal data

Personal data is handled under the GDPR. We collect it for a stated purpose, keep it no longer than we need it, and never sell it. How we handle customer data is set out in our Privacy Policy.

8. Community

Play is worth defending as a social good. We support education and access to play, and we work with local communities on their terms, with respect for the culture and customs of the places we operate in.

9. Making it real

• Communication. Partners receive this Code and pass its substance to their own workers, suppliers and subcontractors.
• Self-assessment. We may ask a partner to confirm in writing how it meets this Code.
• Records. Partners keep records that show they meet it, and give us access to the originals when we ask.
• Audit rights. We reserve the right to visit, inspect and request records, ourselves or through a third party, on written notice.
• Corrective action. Where a gap is found, we agree a corrective plan and a deadline. Child labour, forced labour and immediate danger to life require action before a plan.

10. Raising a concern

Anyone can report a suspected breach of this Code to support@asgaardian.com. That includes a worker at a partner site, a customer, a retailer, and anyone on our own team.

Reports may be anonymous. We do not tolerate retaliation against anyone who raises a concern in good faith, and a report made in good faith that turns out to be mistaken carries no consequence.

11. Consequences

Breach of this Code is a contractual matter. Depending on how serious it is, and on whether it is put right, it can lead to a corrective plan, to orders being suspended, or to the end of the relationship. Where a breach also breaks the law, we report it.