FAQ

What is a Code of Conduct?
A Code of Conduct is a set of rules outlining the responsibilities of or proper practices for an individual, party or organization. In this case the EPPA Code of Conduct (hereafter called the Code) consist of proper practices for companies within the promotional products industry, contributing to the welfare of its key stakeholders and respecting the rights of all stakeholders affected by its operations.

What is The EPPA Code of Conduct?
The EPPA Code of Conduct is the European standard for responsible business behavior for the promotional products. The Code has been developed in close cooperation with specialists from the industry and is acknowledged by the individual EPPA countries as the standard. Over time it will replace existing local or national programs.

What does the Code demand?
The Code focuses on good business behavior in terms of respecting laws and regulations as well as taking on social responsibility. This will not only apply for your own company, but also for the rest of your supply chain up to the 1st tier manufacturer. The Code focuses on business processes, not on products and contains three levels. The first level, Bronze with one star, shows a company’s intent and requires the first steps in creating awareness of a company’s responsibility. This level is not certified and serves as an industry Code of Conduct. Certification is possible for the Silver and Gold levels. The Silver level, also indicated with two stars, requires specific standards on how the company guarantees that applicable law & regulations are met, whereas level 3, Gold or three stars, adds mandatory responsibility for the social standards we set as an industry.  The company that requests the certification is responsible up till the 1st tier manufacturer.
Compliance with the Code for the 2nd and 3rd level requires verification by an independent verification company. After a few years, each level requires growth towards the next to ensure the industry acknowledges its responsibility and its ability to influence.
At this very moment we are conducting a pilot and with the results we will finalize the details of the Code levels Silver and Gold. Should you require more details now, please contact EPPA on below information address.

For whom is the Code?
The Code is intended for all companies within the European industry, big and small, distributors and suppliers.

My company already undersigned a Code of Conduct. Can I automatically enter the EPPA Code now?
EPPA Code level Bronze can be instantly signed by all companies that are a member of an EPPA affiliated country association, for a small fee for PSI members and upon request by those that are not a member of affiliated country association nor a member of PSI.
For levels Silver and Gold the Code requires verification against set criteria. It depends on the program, standard or norm that your company joined/applies as there are many national industry codes of conducts, international programs, EU standards or norms. EPPA works with the country associations on the details of their Codes to identify the most efficient transition. EPPA will also publish a list of the international norms and programs that are valid as an automatic entrance for the Code Levels 2 and 3.

What are the benefits of the Code for my company?
Compliance with the Code will speed up your company’s professionalism and will give your company a recognizable and trustworthy mark. Your customers can benefit by the instant recognition of a single standard and trust that their reputation or their customers reputation is not at risk. Subscribers to the Code will also enjoy reduction cost e.g. of auditing and testing costs, optional supply chain monitoring systems, and easy access to information on law & regulations etc. For the more advanced companies please note that the Code will allow you to easily provide your customers with CSR related information in any desired standard or formats.

What are the marketing plans for the Code?
EPPA will support participating companies in communicating their professionalism and compliance to customers. They will receive marketing materials and support on how to best use this towards their customers.
A part of the fee that EPPA receives from participating companies will be used for dedicated communication towards end customers. And of course members will benefit from the fact that organizations, that promote social responsibility, will encourage their members to prefer companies with the EPPA certification. Every country has strong networks on these topics. We know for instance that in the Netherlands there are tenders that are only allowed for promotional products companies that have a MVO certificate, the Dutch equivalent for CSR certificate.

As far as social compliance is concerned, there is also the BSCI Initiative, in which many responsible promotional product companies are already members. What role does the BSCI play within the framework of the stage model of the CSR initiative?
The BSCI is a very well organized certification program. BSCI has set their own standards, has membership of mainly retailers in EU and focuses on social responsibility of the manufacturers. If a company is a BSCI member its supply chain almost automatically qualifies for the EPPA gold level. BSCI has its own teams of auditors to verify at the manufacturers premises which EPPA is looking into to allow this verification. BSCI does not check compliance with laws & regulations however and only focuses on social standards at the manufacturers location. As such, it does not sufficiently protect product and consumer safety, elements that potentially damage the reputation of our customers or the reputation of our industry as a whole.

What are the requirements a company must meet to graduate to the Silver Level.
The company recognizes its social responsibility and translates the Code elements to its daily operations. This likely means that a company identifies and documents what rules & regulations apply to its type of business and the country it does business with. This needs to be(come) part and parcel of the purchasing professionals ways of sourcing and buying products. But also sales people need to be aware of the product risks and how its colleagues ensure that products are safe for customers or end users. And besides product safety, dealing with materials but also quality of the products, knowledge of the labor and human rights situation at the locations where the products are being manufactured play an important part for purchasing experts. EPPA requires a company to have a person in its organization, assigned with keeping this necessary information up to date and accessible for the people that have to use it in their profession. This person will also be the key liaison for the mandatory company audit. In this audit the above will be verified.

What distinguishes the Gold Level from the Silver Level?
On Gold level a company integrates the Code in its daily operations throughout the organization and verifies key stakeholders in its supply chain up to 1st tier manufacturer. This means that a company on-going monitors and verifies its supply chain on social responsibility. That is the main difference from the Silver level. The first year a small percentage of the manufacturers need to be audited. EPPA requires a focus on high risk categories in high risk locations. Manufacturers that are being audited and fail to meet certain criteria will get time to correct the failures and member companies are encouraged to work with these manufacturers to get the failures solved. But if a manufacturer does not want to solve certain labor or human rights issues, a member company should also stop sourcing their products.
Each year the number of audits goes up as a percentage of the number of suppliers the member company does business with. This percentage ongoing depends on the risks involved.

What are the costs involved?
Each company who wants to enter the certification program has to pay a yearly certification fee for administration, maintenance and PR. This fee is required for each level and the exact amount depends on the size of the company and the level a company’s wants to join the program. The fees for the certified levels of the Code vary from a few hundred euros to a few thousand euros for the biggest players in the market. Fees for participation are broken down in different elements. Next to the certification fee, participating companies pay for the verification by an independent verification company, for a mandatory management training and for participation of a percentage of its employees in webinar awareness training.

Furthermore For Level 3 of the Code it becomes mandatory to verify social standards in the supply chain. The amount of audits per year depends on the number of factories and the costs are taken by the requesting company.
In addition to out of pocket costs, we know from front runners that active involvement from and time of employees is crucial. For companies that are already advanced in screening supply base, little additional time will be required. For the companies that have few systems in place to ensure responsible supply chain, we know that it requires man power and dedication.
For more information on exact numbers please contact EPPA (see details below).

If I buy products with a certificate, do I automatically qualify for the EPPA Code?
‘Products with a certificate’ are products that due to EU regulations need to have documentation that proofs that certain conditions are met relating to product safety and/or material use (e.g. toys testing). The current EU laws and regulations require testing for many of the products we use as promotional products. The EPPA Code is a process related Code and not a product related one. Companies must have procedures in place to ensure that the applicable laws and regulations requirements are met, per product and per country. It does not however, automatically give you the product related certificates.

If I do not buy directly at manufacturers but only at EPPA Code certified companies, what do I do to become certified myself?
If you buy from companies that are EPPA Code certified this means that your supply chain meets the standards EPPA sets. You will likely be easily verified for Level Silver or even Level Gold, depending on the companies downstream in your supply chain. EPPA is, at this very moment, looking into reduced costs for these companies that intend to join the Code.

If I am EPPA certified, am I allowed to sell both products with and without a certificate?
To comply with the EPPA Code your company has to be in compliance with EU law and regulations. If the law requires a certificate for a certain product (e.g. toys), you need to prove that you have all procedures in place to guarantee this is done. The law will also indicate if a product does not need to have a certificate.  Note that the EPPA Code certification program is not a product certification but a (company-) process certification. It will never guarantee that a product is made from a certain material or is produced with fair wages for all employees in the supply chain. It only guarantees that processes are in place to ensure compliance with law & regulations and careful selection of manufacturers to prevent offenses on our ethical norms on social responsibility. As such it can never be used on individual products.

How has the EPPA Code been developed?
The Code has been developed by six specialist from within the industry. These specialist work for different types of companies, big and small, both distributor as well as supplier and represent the interest and different needs. The specialists are:

Who can participate in the Code, suppliers or distributors?
The CSR program has been developed for the entire industry, so both suppliers and distributors can participate.

How must we imagine the procedure? For instance, what exactly must the owner of a medium-sized supplier/distributor do if they want to participate in the initiative? Who is the first person to contact?
Companies who are interested in joining the CSR program can contact EPPA directly or turn to their country association. They will receive information about the program and detailed information on which steps to take. One of the first steps for a company is to make a brief assessment of its situation to decide which level of the EPPA certification program would be suitable. A company that wants to join, should assign a key contact person. This person will fill out the work plan and collect the necessary data within the organization (e.g. company size, sourcing countries and main product categories). With the work plan in place, the application for the program is official and the EPPA team will regularly align with the key contact on e.g. scheduling management training, employee training, company audit and for gold level, the social audits in the supply chain should that be applicable.

How much time is involved if my company joins the certification program so Level Silver or Gold?
The total time involved is build up from different elements and varies depending on your role in the organization. For instance the management training requires half a day of your company’s  management staff. Planning, preparing and facilitating the company audit may require from a few days up to a few weeks from the responsible colleague. For a company that has well documented its processes the audits will not require not much more than the audit time itself, which tends to be one or two days for a big company. If a company has not yet documented its processes, we know this can take some time, depending on the size between a few days to several weeks.

When will the Code be ready?
The Code structure is ready. However, EPPA will conduct a pilot to calibrate all the levels and norms. This will be finalized mid-2013. The first companies will enter the certification program in September.

I am also interested in joining. Where can I apply?
For more information you can contact the EPPA office at +31 (0)70 306 69 05 or contact@eppa-org.eu.
You can sign up for the bronze level by dornloading the .pdf form here. Print out the form, fill it in and send it back to us via email at contact@eppa-org.eu. We will contact you as soon as we receive your registration form.