A supplier code of conduct is a promise about how work should be organised. It is not proof that those conditions exist. For apparel brands, the useful question is whether each commitment can be checked against records, worker testimony and what actually happens on the production floor. A signature is only the beginning.
This guide maps the nine headings of the Ethical Trading Initiative (ETI) Base Code to evidence a buyer might request. It also explains where a supplier code of conduct reaches its limits. The ETI code is a voluntary labour-practice framework grounded in International Labour Organization conventions; it is not itself a law or a universal certification.
What a supplier code of conduct does, and what it does not
A supplier code of conduct sets out expectations for employment, safety, pay, working hours and treatment of workers. A buyer may incorporate it into contracts, supplier onboarding and corrective-action procedures. The code should identify the sites and business relationships it covers, who investigates concerns, and what happens when an issue is found. Those operational details matter as much as the principles.
National employment and safety laws still apply. ETI says companies applying its Base Code should follow applicable law and, where the code and law address the same subject, use the provision offering greater worker protection. A buyer should not assume that adopting ETI wording satisfies every local legal requirement. Nor does signing a code confer an ETI certification.
For related context, see our guides to supplier audits versus due diligence and responsible purchasing practices. The first distinguishes a point-in-time assessment from ongoing responsibility; the second asks how buyer decisions can create pressure on suppliers.
The nine ETI Base Code areas: commitment, evidence and verification
The table below is an editorial evidence-mapping aid, not an official ETI audit checklist. A document may support a finding without establishing that the practice is followed consistently. Evidence should be assessed with appropriate confidentiality and worker safeguards.
| ETI heading | Potential evidence | What still needs checking |
|---|---|---|
| 1. Employment is freely chosen | Recruitment contracts, fee policies, passport custody rules, resignation records | Private worker accounts of deposits, debt, threats and freedom to leave |
| 2. Freedom of association and collective bargaining | Worker-representation procedures, agreements, grievance records | Whether representatives can act without retaliation |
| 3. Safe and hygienic conditions | Risk assessments, training logs, maintenance and incident records | Exit access, machine guards, ventilation and conditions on the floor |
| 4. Child labour shall not be used | Age-verification procedures, hiring records, remediation process | Actual hiring practice and safe remediation if a child is identified |
| 5. Living wages are paid | Payroll, payslips, benefit records, deductions policy | Pay received by workers and how it compares with legal and code requirements |
| 6. Working hours are not excessive | Time records, overtime consent, payroll reconciliation | Off-clock work, double books and peak-season patterns |
| 7. No discrimination is practised | Recruitment, promotion, disciplinary and complaint records | Patterns of exclusion and whether reporting is safe |
| 8. Regular employment is provided | Contracts, agency arrangements, subcontractor lists | Whether employment obligations are avoided through indirect arrangements |
| 9. No harsh or inhumane treatment | Disciplinary policy, confidential reporting channel, investigation records | Worker experience of intimidation, harassment or retaliation |
Hours and wages require particular care
The ETI Base Code’s working-hours section specifies a normal working week not exceeding 48 hours, a general 60-hour limit for any seven-day period, and tightly defined exceptional conditions for exceeding that total. It also addresses voluntary overtime, premium compensation and rest days. These are code provisions, not a claim that every jurisdiction has the same statutory limit. The complete conditions are in ETI clause 6.
Similarly, ETI’s wages clause refers to legal or industry benchmark standards, whichever is higher, and states an expectation that wages meet basic needs and allow discretionary income. A payroll total alone cannot settle whether every worker received the correct pay. Review deductions, hours, the definition of a standard week and any recruitment or accommodation charges.
What auditors can sample, and why a pass is not a guarantee
An assessment may combine document review, observations, management interviews and confidential worker interviews. A buyer can compare a timecard against payroll, or a machine-safety procedure against the machine actually operating. But sampling does not continuously observe every shift, subcontractor or recruitment intermediary.
Better Work’s transparency guidance explicitly warns that a factory with no evidence of non-compliance on the selected publicly reported issues may still fail other standards outside that reporting scope. That is an important distinction for buyers tempted to treat a clean public record as a blanket endorsement.
Nor should the names of different frameworks be swapped. ETI’s Base Code is a set of labour principles. SMETA is an audit methodology. A certification scheme, where applicable, has its own requirements and verification rules. A supplier may use several tools, but one does not automatically substitute for another.
Three blind spots that a signed code can miss
Undisclosed subcontracting
A purchase order names one supplier, but printing, embroidery, washing, packing or sewing may be carried out elsewhere. If the buyer has not mapped authorised production sites, the signed code may cover a legal entity without showing where a particular order was made. Require site disclosure, approval before transfers and records linking each operation to the order. Our subcontracting controls guide explains the handoff problem.
Homeworking and informal labour
Work may be performed outside the main facility through intermediaries. Banning homework on paper does not reveal whether it exists. Buyers need to ask what tasks are outsourced, how workers are paid and what practical protections can reach them. ETI clause 8 specifically addresses the avoidance of employment obligations through subcontracting or homeworking arrangements.
Recruitment fees and migrant-worker debt
A supplier may prohibit forced labour but still depend on recruitment agencies that charge workers fees or hold documents. Ask who recruits workers, what workers pay before arrival, who keeps original identity documents and how complaints are resolved. Workers must be able to speak without fear of punishment. A policy signed by factory management cannot replace that inquiry.
Turning a code into a working supplier process
Start with scope. Identify the contracting supplier, actual production sites, relevant intermediaries and the categories of workers covered. Translate the commitments into languages workers and managers understand. Name accountable owners for wages, safety, recruitment, grievance handling and subcontracting approvals.
Next, establish a verification cycle. Review risk before placing an order, check evidence at agreed intervals, and respond to specific findings. Each corrective action should have a description, responsible person, due date, evidence requirement and follow-up decision. Closing an action because a supplier uploaded a policy is not the same as verifying that the underlying condition changed.
Buyer conduct belongs in the process. Repeated last-minute changes, unrealistic lead times or pricing below an agreed cost basis can make working-hour and wage commitments harder to deliver. A credible code should be paired with procurement practices that do not routinely undermine it.
Twelve questions before accepting a supplier’s signature
- Which legal entities and physical production sites does this code cover?
- Are temporary, agency, migrant and homeworker arrangements included?
- Who approves subcontracting, and where is that approval recorded?
- Can workers access the code in a language they understand?
- How are recruitment agents selected and monitored?
- Can workers keep control of their identity documents and leave employment?
- How are actual hours reconciled with wages and production output?
- What evidence supports wage calculations and deductions?
- Who checks safety conditions beyond the written risk assessment?
- How can workers report problems without retaliation?
- Who owns corrective actions, and how is closure verified?
- What will the buyer do if the supplier cannot demonstrate compliance?
A useful code produces decisions, not just documents
A supplier code of conduct is most useful when it changes sourcing decisions: which sites are approved, which evidence is missing, what must improve, and whether an order can proceed responsibly. Keep the signed text, but also keep the scope, findings, worker safeguards and follow-up record. Without those, the document says more about a buyer’s intentions than about working conditions.
Primary sources and further reading
- Ethical Trading Initiative: ETI Base Code, clauses 1–9.
- Better Work Transparency Portal: scope and limitations of published compliance findings.
- Better Work: Transparency Portal overview.
Editorial verification date: 25 October 2026. This article is a practical sourcing guide, not legal advice or an official ETI audit protocol.
