Corporate Social Responsibility Policy


Macnaughton Holdings seeks to be a good corporate citizen in everything that it does.
We have therefore determined to bring together our existing operating principles into one framework policy under the heading of Corporate Social Responsibility (CSR). The principles encompassed in this policy cover all areas of the Company's operations and have been developed and continue to be reviewed against and updated by reference to relevant codes of corporate governance and international standards including the United Nations (UN) Universal Declaration of Human Rights, the International Labour Organisation (ILO) Declaration on Fundamental Principles and Rights at Work, the Rio Declaration on Environment and Development and the UN Convention against Corruption.

Macnaughton's Board of Directors supports the principles set out in those codes and standards and the aim of this policy is to translate that support into a set of guidelines and standards that set a common approach for the Company and provide practical guidance for our managers and employees on the ground.


Compliance with this policy will be continuously monitored and subject to an annual review by the Board. Compliance will be reported to stakeholders through the Company's Annual Report
or its annual Corporate Social Responsibility Report.

Each manager is responsible for ensuring that the principles set out in this policy are communicated to, understood and observed by all employees and for ensuring compliance in their area of responsibility.

Employees who reasonably suspect that there has been a breach of this policy must report it to their line manager, senior management, or other mechanisms established by the Company to report such breaches. We recognise that employees may be reluctant to report concerns for fear of retaliation and will take disciplinary action against any employee who threatens or engages in retaliation, retribution or harassment of any person who has reported or is considering reporting a concern in good faith. The Board will not criticise management for any loss of business resulting from adherence to the principles set out in this policy.


This code applies to all of the operations of the Company and sets out the minimum standards which the Board expects from staff in their internal and external dealings with colleagues, customers, stakeholders and third parties.

3.1 Basic Standards of Conduct

The Company will conduct every aspect of its business with honesty, integrity and openness, respecting human rights and the interests of our employees, customers and third parties. It will also respect the legitimate interests of third parties with whom it has dealings in the course of its business, and will maintain the highest standards of integrity. For example, the Company will not knowingly promise more than it can reasonably deliver or make commitments that cannot or are not intended to be kept.

3.2 Employees

The Company is committed to creating and maintaining a safe and healthy working environment for its employees and will strive to create a workplace in which there is mutual trust and respect and where every person feels responsible for the performance and reputation of the company. It will also respect the individual and each other's rights, customs and traditions including the right to freedom of association and the right to decide whether or not to join a trade union and will negotiate in good faith with properly elected representatives of its employees.

The Company will work towards achieving a diverse workforce, recruiting, employing and promoting employees only on the basis of objective criteria in addition to the qualifications and abilities needed for the job to be performed. It will maintain good communications with employees through the provision of information and consultation procedures.

It is the Company's hope that it can assist employees in realising their potential.

3.3 Customers

The Company is committed to providing safe, value for money, high quality, consistent and reliable products to its customers.

3.4 Shareholders

The Company will conduct its operations in accordance with the principles of good corporate governance and provide timely, regular and reliable information on the business to all our shareholders.

3.5 Business Partners and Stakeholders

The Company aims to develop strong relationships with its suppliers, stakeholders and others, based on mutual trust, understanding and respect. In those dealings, partners are expected to adhere to business principles consistent with those of the Company. The Company will also conduct its operations in accordance with the principles of fair competition and applicable regulations.

3.5 Compliance with Law

All members of the Company will comply with the laws and regulations applicable wherever they do business. Appropriate training will be provided for employees as necessary.

3.6 Business Integrity

The Company shall not offer, give, seek or receive, either directly or indirectly, inducements or other improper advantages for business or financial gain and no employee may offer, give, seek or receive any gift or payment which is, or could be construed as such. If an employee is in any doubt as to whether he or she may accept an offer, that employee should discuss the issue with his or her manager, the Company Secretary or Managing Director

The Company's accounting and other records and supporting documents will accurately describe and reflect the nature of the underlying transactions and no undisclosed or unrecorded account, fund or asset will be established or maintained.

The Company will not facilitate, support, tolerate or condone any form of money laundering.

3.7 The Environment

The Company is committed to making continuous improvement in the management of its environmental impact, and will work with its partners to promote environmental care, increase understanding of environmental issues and disseminate good practice.

3.8 Community Involvement

The Company will strive to be a good corporate citizen and to fulfil its responsibilities to the societies and communities in which it operates. Wherever possible, it will seek to engage with those local community based charities particularly those organisations that operate within the textile or tartan or highland sectors.

3.8 Conflicts of Interest and Confidentiality

1. Whilst the Company respects the privacy of its employees, all employees are expected to avoid personal activities and financial interests, which could conflict with their responsibilities to the Company.
2. The Company's employees and consultants must not seek gain for themselves or others through misuse of their positions or company property.
3. All actual and potential conflicts (including those arising from the activities or interests of close relatives or partners) should be disclosed to and discussed with an employee's line manager.
4. Information received by anyone in the course of his or her employment must not be used for personal gain or for any purpose other than that for which it was given.
5. Where information is confidential, that confidentiality must be respected.


The health and safety of the Company's employees and customers is of paramount concern. Safety underpins all its operations and it has developed the following health and safety policy.

The Board of Directors of Macnaughton Holdings is committed to ensuring, so far as is reasonably practicable, the health, safety and welfare of all of its employees at work and also the safety of customers and others.

4.1 Continuous Improvement

This policy seeks continuous improvement and compliance with legislation, having proper regard to the protection of people, premises, property and the environment. It is based on the principles that:
1. all injuries can be prevented;
2. the goal is zero injuries;
3. safety is the responsibility of all employees; and
4. working safely is a condition of employment.

4.2 Safety Arrangements

Management is tasked to ensure that so far as is reasonably practicable:
1. there are adequate arrangements and organisation for health and safety in place within their area of responsibility;
2. responsibilities for carrying out these arrangements are clearly allocated;
3. all staff are given appropriate information, instruction and training;
4. adequate supervision is provided to ensure compliance with policies and safe systems of work;
5. all other legal and statutory duties on health and safety incumbent upon the Company are complied with in all their operations and locations;
6. performance targets are set to achieve a step change in safety performance; and
7. adequate resources are allocated and competent persons are appointed to support the achievement of the above objectives.

4.3 Monitoring and Reporting

The Company will continually monitor the health and safety performance of its operations which will be subjected to periodic internal and external safety audits to assess performance. The nominated director will:
1. present a quarterly report on health and safety to the Board; and
2. report to the Board all fatal and notifiable injuries to staff or other persons within 24 hours.

4.4 Safety Principles

The nine key safety principles with which all the Company's employees are required to comply are set out below:

1. Do not endanger yourself or others - Report any hazardous condition or practice that may cause injury to people property or the environment.
2. Obey all rules, signs and instructions - If you do not understand speak to your manager before you start work.
3. Keep your work area clean and tidy - Disorder causes accidents, wastes time, energy and materials.
4. Wear protective clothing and equipment as required - Keep it in good condition, wear it correctly and ask for a replacement if it becomes damaged or unfit for use.
5. All accidents, incidents and near misses must be reported to your manager - Seek immediate help and first aid (if necessary).
6. Do not adjust modify or repair any piece of work equipment unless you are competent and authorised to do so.
7. Use only the correct tools and equipment for the job - Check that they are in good condition before use and use them safely.
8. Before lifting, assess the load and your capability to move it - Make sure you get help with any heavy or awkward items, and follow approved techniques.
9. If you have any suggestions to improve safety in your workplace, tell your supervisor or manager.

4.5 External Contractors

The Company also requires contractors to comply with this policy whilst they are working at its premises.


In formulating its employment policies, Macnaughton Holdings is guided by the framework established by the Advisory, Conciliation and Arbitration Service (ACAS) these guidelines encourage companies to foster openness and respect for employee rights.

5.1 Equal Opportunities and Diversity Policy

The Board of Directors of Macnaughton Holdings (The Company) is committed to equality of opportunity both in the provision of services to the public and as an employer. This policy sets out the Company's commitment to treat equally and with fairness at all times, its employees, customers, contractors and those who come into contact with the company.

5.1.1 Continuous Improvement

The Company is committed to seeking continuous improvement and compliance with legislation based on the following principles:
" everyone has the right to be treated with dignity and respect;
" the Company will not discriminate on the grounds of race, gender, disability, nationality, religion, philosophical belief, political belief, age, sexual orientation, family status, trade union activity or any other factor;
" the Company will adopt fair and inclusive practices throughout its operations and will seek to eliminate all prejudice, discrimination, bullying and harassment;
" all employees have a personal responsibility for the practical application of this policy in their day-to-day activities and must support the policy at all times; and
" non-compliance with this policy will be treated seriously and will not be tolerated.

5.1.2 The Responsibility of the Board of Directors

The Board of Directors is required to ensure:
" the creation of a productive and safe working environment, promoting diversity and inclusion in their workforce;
" the development of new practices, as appropriate, to ensure all employees, contractors and customers are treated fairly; and
" the demonstration of continuous improvement in practices to promote diversity and equal opportunities for all.

5.1.3 Legislation and Codes of Practice

The Company will comply with all current legislation and relevant codes of practice.

5.1.4 Partner Organisations

The Company is committed to actively working with partner organisations to ensure that its policies, procedures and practices are in line with best practice.

5.1.5 Practices and Standard Operating Procedures

The Company will put in place practices and standard operating procedures to ensure the commitments in this policy are applied and implemented throughout the organisation and across all sites.

5.1.6 Access for the Disabled

The Company will take all reasonable steps to ensure that its buildings and premises are accessible to disabled employees, customers and visitors as required by the Disability Discrimination Act (DDA).

5.17 Recruitment

All recruitment will be carried out with regard to fairness, equality and consistency for all candidates at all times. Recruitment practices will be inclusive and the Company will endeavour to ensure there are no barriers to employment of suitable candidates.

5.1.8 Staff Training

The Company will provide its staff with the necessary guidance and training to ensure the effective implementation of this policy.

5.1.9 Complaints

Any employee who feels that he or she has grounds for complaint in relation to bullying, discrimination, harassment or victimisation has the right to pursue the complaint through the Company's grievance procedures. Customers who feel they have grounds for complaint may pursue these through our formal customer complaints procedures. We will ensure our complaints procedures can be accessed and used by everyone.

5.1.10 Reporting

The Company is committed to monitoring and reporting on its actions and achievements in relation to implementing this Diversity policy both internally and externally.

5.1.11 Audit

The Company is committed to ensuring that its operations comply with the requirements of this policy and will periodically audit its implementation.

5.2 Human Rights

Macnaughton Holdings supports the principles of the United Nations Universal Declaration of Human Rights and the International Labour Organisation Declaration on Fundamental Principles and Rights at Work. The Company will adhere to the following principles in respect of its staff:

1. it will treat all employees fairly and honestly, regardless of where they work. All staff will have agreed terms and conditions in accordance with law or practice and will be given appropriate job skills training;
2. it will pay a fair wage reflecting local markets and condition and will always meet any national minimum wage;
3. working hours shall not be excessive. They shall comply with industry guidelines and national standards;
4. it will not employ illegal child labour, forced or bonded labour, forced overtime or condone illegal child labour;
5. employees have the rights of freedom of association and collective bargaining. The Company respects the right of its employees to choose whether or not to join a trade union without influence or interference from management. Furthermore it supports the right of its employees to exercise that right through a secret ballot;
6. it will negotiate in good faith with the properly elected representatives of our employees;
7. it will abide by the non-discrimination laws;
8. it will not use or condone the use of mental or physical coercion or verbal abuse. The Company has disciplinary procedures for any member of staff whose conduct falls below the required standard;
9. the Company has formal grievance procedures through which staff can raise personal and work-related issues; and
10. all staff will be given reasonable access to bathroom and rest facilities.

5.3 Data Protection

The Company will comply with the relevant principles governing data protection. The Company Secretary is the registered Data Controller.


6.1 Customers

The Company would wish to treat its own customers in the manner to which it would hope to be treated by its own suppliers. By adopting this policy, it is hoped that Macnaughton Holdings will gain the respect of its customers as a company exhibiting integrity, old fashioned values and fairness.

The Company will:
1. act in accordance with fair business, marketing and advertising practices and take all reasonable steps to ensure the safety of our services
2. provide transparent and effective procedures that address customer complaints and contribute to fair and timely resolution of disputes without undue cost or burden;
3. not make representations or omissions nor engage in any other practices that are deceptive, misleading, fraudulent or unfair; and
4. respect customer privacy and confidentiality and provide protection for personal data in accordance with the relevant local law.

6.2 Suppliers

6.2.1 Ethical Purchasing Policy

The Company purchases a wide range of goods and services required in the operation of its business, and also relies heavily on a number of key suppliers for the delivery of its core products. Good working relationships with suppliers are therefore central to the success of the business. The Company is committed to obtaining and retaining competitive goods and services while at the same time ensuring they are from sources which have not jeopardised human rights, safety or the environment.

6.2.2 Supply Partnership

The Company aims to develop strong relationships with its suppliers, based on mutual trust, understanding and respect. More specifically suppliers are expected to:
1. adhere to business principles consistent with our own;
2. ensure that their products and services are produced and delivered to comply with all legislation relevant to their business;
3. seek to maintain continuous improvement in their supply chain relationship with Macnaughton Holdings; and
4. ensure they adopt and implement acceptable safety, environmental, product quality, product stewardship, labour, human rights, social and legal standards in line with the Company's own code and to ensure these issues are acceptably managed within the supply chain for any products supplied to the Company.

The Company will seek to work with our key suppliers to:
1. develop long-term meaningful relations to the benefit of both parties; and
2. improve the quality, environmental performance and sustainability of goods and services where this can be achieved to the benefit of both parties.

6.3 Community

As one of the few remaining wool textile companies remaining in original family ownership in Scotland, Macnaughton Holdings retains a higher public profile than many other companies of a similar size. In keeping with this profile, it is important that the Company plays a constructive part in the communities in which it operates.

The Company also operates from three sites spread across Scotland and has a responsibility to those living and working nearby as well as being a significant employer. The relationships with the local communities are therefore very important and are an important part in the culture of our business. The Company will therefore engage wherever possible with the community at a range of levels as customers, neighbours, potential employees, businesses and residents.

In line with our core values, our community strategy incorporates the following elements:
" offering employment opportunities to all sectors of the community through non-discriminatory policies and promoting opportunities to disadvantaged and vulnerable groups;
" promoting engagement between our staff and the community;
" supporting local community groups and charities wherever possible; and
" improving the environment in and around our operations.


7.1 Environmental Policy

Our policy is to strive to achieve continual improvement in environmental performance.

We are committed to:
" preventing pollution and reducing the overall impact of our operations on the environment;
" maintaining an internal management structure for the management of environmental issues which includes clearly defined responsibilities for environmental management capable of delivering this policy commitment;
" complying with, and where possible exceeding applicable legal and other requirements relating to the organisation;
" monitoring our environmental performance and setting objectives and targets for improvement; and
" providing appropriate training and awareness programmes for our staff.

We recognise the key role we have to play in both reducing and contributing to greenhouse gas emissions from the surface transport sector.

7.2 Climate Change Policy

Climate change has now been recognised as an international issue and the U.K Government is committed to taking action to reduce greenhouse emissions. While the Company is not a major user of fossil or other fuels, it recognises at the same time it has a role in supporting the government and communities to reduce the impacts of climate change wherever possible. The Company is therefore committed to reducing the greenhouse gas emissions from its operations in a way which supports national government strategies and in line with our commitment to our stakeholders.

The Company's key climate change commitments are:

1. To actively promote improved energy efficiency in its operations and fuel efficiency in its fleet of cars.
2. To stay abreast of alternative fuel and energy developments and continue to assess their commercial viability and appropriateness for use by the Company.

7.3 Biodiversity Policy

All businesses affect biodiversity through the use of resources and discharge of waste products. The Company's policy in respect of conserving and promoting biodiversity reflects its commitment to furthering the aims of sustainable development in the management and development of our business. The Company's Biodiversity Policy is therefore consistent with its broader Environmental Policy, which includes a stated commitment to minimise the environmental impacts of our operations and prevent pollution.

Our policy is to strive to enhance biodiversity where practicable. Accordingly the Company commits to:

1. Where it operates from sites which are designated as being of importance due to their natural habitats, the Company will work with the relevant authorities and affected parties to ensure protection of these habitats through effective pollution control measures and management plans with the aim of conserving or enhancing the biodiversity of these sites.
2. Where it is involved in the development of new premises, the Company will comply with all relevant statutory requirements and guidelines in respect of designated areas.
3. Where significant areas of landscaping are proposed, the Company will aim to promote biodiversity through, for example, sensitivity of planting taking account of any local biodiversity networks or action plans.
4. Where the Company operates from existing sites, the potential to promote biodiversity is likely to be limited. Nevertheless, the Company will seek to identify areas where potential exists for enhancing biodiversity and over time develop appropriate actions plans to achieve this.
5. Where it is considered appropriate to do so, the Company will support the implementation of the UK Biodiversity Action Plan and Local Biodiversity Action Plans, defining areas which require special protection and management to ensure that biodiversity is maintained. The Company will seek to do this in partnership with the relevant authorities and affected parties, who promote biodiversity on a local and national level and seek to identify ways in which the Company may be able to support the development of selected schemes or initiatives