Company Policies

 DownloadThis statement sets out the steps taken by Price Western Leather Company Ltd. (“Price Western”) to ensure that our business and supply chain are free from slavery and human trafficking.
Summary
We are committed to ensuring that we supply high quality products that are sourced and manufactured in a fair, ethical and environmentally responsible way. We have a zero tolerance approach to modern slavery of any kind
within our operations and supply chain. Our workers are encouraged to report any concerns they may have and management are required to act upon them.

We have taken and will continue to take a number of steps to ensure that slavery and human trafficking do not take place in any part of our business or supply chain. We are proud of the steps we have taken to date which include:
– implementing a formal supplier approval process across our supply base, which includes a focus upon
human rights and labour standards policies;
– directly auditing our key primary materials supply base on a periodic basis

Our policies on slavery and human trafficking
We operate an Ethical Operating Policy that reflects our commitment to acting ethically and with integrity in all our business relationships. Our Ethical Operating Policy is an important part of our framework for controlling slavery and human trafficking risk. It sets out our standards in relation to our suppliers’ treatment of workers, child labour, legal compliance, discrimination and health & safety. We monitor and measure supplier compliance with our Ethical Operating Policy through our supplier approval and audit processes.

Due diligence processes for slavery and human trafficking
We understand the risk of modern slavery taking place in our supply chain. We take a risk-based approach to our selection of suppliers and ethical trading is an important part of our risk assessment processes. In order to identify, monitor and mitigate the risk of slavery and human trafficking taking place within our supply chain we take the following steps:
– Our contract tender process requires the completion of a formal supplier approval questionnaire which includes an
assessment of our suppliers’ human rights and labour standards status; and
– Our supplier audit programme allows us to periodically assess the working conditions at our key materials
suppliers’ production sites and to verify that relevant policies are being adhered to.

Training
Our Procurement team are qualified to understand the importance of ethical trading and the risks of modern slavery and human trafficking.

This statement is made in line with the requirements of section 54(1) of the Modern Slavery Act 2015 and approved by Price Western Leather Ltd. on 31 January 2018.

 DownloadPrice Western Leather Company Limited is committed to operating as an ethical and responsible member of the business and local communities it serves. This includes the below undertakings and the relevant Anti-Bribery and Corruption laws described in, amongst other legislation, the Bribery Act 2010.

Bribery and Corruption
Price Western Leather Company Limited expressly prohibits both the offering or giving of any type of bribe as well as the acceptance or solicitation of any kind of payment or payment in kind. This applies to all our business partners, existing or potential, as well as our staff as individuals or as a body.

We believe there is a clear line between legal, responsible, ethical business practice and corrupt partnerships or gains based on bribery and illegal activities. We are clear that we will always remain a legally correct and ethically sound business partner, in terms of our suppliers, customers and staff.

Individual Responsibility
We require every individual member of Price Western Leather Company Limited to operate according to this policy, our Ethical Operating Policy and also to report any perceived infringement of this policy to his or her Line Manager promptly. We require our staff to act in a transparent, ethical and legal manner when acting at any level on behalf of Price Western Leather Company Limited.

Corporate Responsibility
We expect all our business partners to operate transparently and within their relevant legal framework. We will never offer, give, request nor accept any kind of bribe or inducement to act in a way inconsistent with our Ethical Operating Policy or our legal framework. We will report any illegal activities to the relevant authority.

Price Western Leather Company Limited will not offer any contributions of any kind to political parties either in the UK or in business partners’ locales. Price Western Leather Company Limited will not make any donations to charities or corporations that have as their purpose gaining commercial advantage.

 Download Price Western Leather (Price Western) recognises that it must bring together our company values and operations to meet the expectations of all stakeholders. Our stakeholders include customers, employees, regulators, investors, suppliers, the community and the environment.

We recognise that our responsibilities in terms of the social, economic and environmental effects of our operations to these stakeholders are key to the successful continuity of our business. We aim to demonstrate these responsibilities in both our day to day actions and within our corporate policies. We welcome feedback from all stakeholders. We regularly review all feedback received and, where possible, maintain open communications with all our partners to ensure that we fulfill the requirements outlined within this policy.

The Managing Director, working with the Senior Management Team, is responsible for the implementation of this policy and will make the necessary resources available to realise Price Western’s corporate responsibilities. The responsibility for our performance to this policy rests with each individual throughout the company.

Corporate Responsibility
We expect all our business partners to operate transparently and within their relevant legal framework. We will never offer, give, request nor accept any kind of bribe or inducement to act in a way inconsistent with our Ethical Operating Policy or our legal framework. We will report any illegal activities to the relevant authority.

Our focus:

Price Western will continue to work hard to improve its environmental performance through implementation of our ISO14001 processes and related polices.

Through effective partnerships with all our suppliers, we shall continue our initiatives on energy and raw material efficiency, staff education and the environmental impact of our operations on the community.

Price Western encourages dialogue with local communities for mutual benefit.

Price Western undertakes to register and resolve customer complaints in accordance with our published standards of service, backed up by our ISO 9001 accreditation and associated processes.

Price Western supports and encourages our employees to help local community organisations and activities in our region.

Price Western operates an equal opportunities policy for all present and potential future employees.

Price Western offers its employees clear and fair terms of employment and provides adequate resources to continue their professional development.

Price Western provides safeguards to ensure that all employees and contracted staff are treated with respect and without sexual, physical or mental harassment.

PWL will work hard to maintain, a clean, healthy and safe working environment, under the relevant legal framework, but also incorporating measures aimed to improve the well- being of our employees whilst under our duty of care.

PWL upholds the values of honesty, partnership and fairness in our relationships with stakeholders.

Our contracts clearly set out the agreed terms, conditions and the basis of our relationship.

PWL will continue to operate in a way that safeguards against unfair business practices.

PWL encourages suppliers and contractors to adopt responsible business policies and practices for mutual benefit.

Working with our Local Community
Price Western undertakes to always act responsibly in both the way it conducts it’s business with partners and customers as well as behaving in a responsible manner towards our local community – as a whole and as individuals. We will continue to encourage our staff members to actively engage with local charities, youth groups and organisations.

When required, Price Western will always be as flexible as possible to allow staff members to participate in events and family occasions. As an organisation, we will continue to sponsor and support local events and organisations both with financial donations and direct help through participation. We will offer an ‘open- door’ policy to local organisations of all kinds to whom we will extend free access to our surplus materials and expertise.

As our company grows, we endeavour to do so alongside our community – our staff members all live in the area and have a wide range of interests and commitments. We value the opportunities to support our staff and our neighbours in both their professional and domestic lives.

 DownloadThe Price Western Leather Company Ltd. (“PWL”) is committed to conducting its business according to the highest standards of honesty and fairness. This commitment to observing the highest ethical standards is designed not only to ensure compliance with applicable laws and regulations but also to earn and keep the continued trust of clients, personnel and business partners.

Overview & Guiding Principals
1) PWL will not conduct business where the business environment is such that operating in an ethical, legal way is not possible. This applies to relationships with customers, suppliers, contractors, government representatives and partners. No amount of profitability is more important than the reputation and
goodwill of PWL.
2) All employees must work together to maintain PWL’s reputation for integrity. All employees are expected to act in the best interest of PWL and to promote and protect the good name and reputation of PWL. The Policy provides a means to a better understanding of the principles and standards that must govern all of PWL’s business activities.
3) It always has been and continues to be the intent of PWL that its employees maintain the highest ethical
standards in their conduct of Company affairs. Ethical behaviour is not always easy to define. However, fairness, honesty, respect and trust are the principal characteristics of ethical behaviour. Unless the context otherwise requires, references to an “employee” within the Policy refers to any employee, director, officer or designated agent or representative of PWL (including a consultant, advisor or independent contractor) who acts on behalf of PWL. The essence of the Policy is that each employee will conduct PWL’s business with integrity, in compliance with applicable laws and in a manner that excludes considerations of personal advantage.
4) PWL has and always shall practice and promote care for the environment throughout each and every aspect of its operations. PWL holds ISO 14001 Environmental accreditation and operating guidelines and procedures recognised by this accreditation are the cornerstone of its Environmental Policy.

Compliance with Laws, Rules & Regulations
5) Obeying the law, both in letter and in spirit, is the foundation on which PWL’s ethical standards are built. All employees must respect and obey all local and national laws and the laws of any countries in which PWL does business. Employees are expected to know and adhere to the laws applicable to the scope of their employment and thus should seek advice from managers or other appropriate personnel if they have questions about such laws.
6) PWL supports the conventions of the International Labour Organisation (ILO) in relation to employment, freedom of association, safe and hygienic working conditions, child labour, wages, working hours, discrimination and inhumane treatment.
7) PWL also supports the broader rights and freedoms set out in the European Convention on Human Rights and the Human Rights Act 1998.

Corporate Communications
8) PWL is committed to conducting business in an open and honest manner. All communications, whether internal or external, should be accurate, complete and forthright. These communications may include, but are not limited to, general internal reports, media releases, marketing and sales brochures, regular company reports, government filings and illustrations.
9) PWL will provide accurate information when promoting its products and services. False or misleading claims concerning PWL’s products and services or those of PWL’s competitors are unacceptable. These same principles must be adhered to when responding to enquiries from customers, fellow employees, the media, governmental regulatory agencies and shareholders. Responses to such inquiries must be made in accordance with PWL’s policies and procedures.

Accounting Standards & Communication
10) All accounts and records shall be documented in a manner that:

i) Clearly describes and identifies the true nature of business transactions, assets, liability or equity; and properly and timely classifies and records entries on the books of account in conformity with generally accepted accounting principles.
ii) No record, entry or document shall be false, distorted, misleading, misdirected, deliberately incomplete or suppressed.
iii) PWL has established internal control standards and procedures to ensure that assets are protected and properly used, and that financial records and reports are accurate and reliable. Employees share the responsibility for maintaining and complying with required internal controls.

Employment Practices
11) Employees constitute PWL’s most indispensable asset. PWL recognizes that the inherent value of this asset is reflected in the ability, integrity, knowledge and talent of its employees. To recruit and retain employees that reflect these values, PWL’s guiding principle will be to:

i) Aspire to provide an environment where employees will adhere to the Policy and conduct themselves with fairness, honesty, integrity and professionalism in the performance of their duties and all of their business relationships, treating each other with respect and professionalism;
ii) Aspire to provide equal opportunity for all in recruiting, hiring, developing, promoting and compensating without regard to age, colour, non-disqualifying disability, gender, national origin, race, marital status, veteran status, religion or any other basis that is protected under applicable law; and foster a professional, safe and discrimination-free work environment, where mutual respect is the absolute minimum of behaviour expected from everyone.

12) It is the Company’s policy to hire, evaluate and promote employees on the basis of their ability, achievements, experience and performance.

13) Ethnic, racial, religious, sexual or any other type of unlawful harassment is unacceptable. Inappropriate or unwelcome sexual behaviour, either physical or verbal in nature, that interferes with and obstructs performance in the workplace violates PWL policy and may constitute harassment, which is against the law. In order to provide an environment that is conducive to productivity and personal growth, PWL
prohibits illegal workplace harassment of any kind, whether the harasser or the victim is a co-worker, supervisor, agent, customer, guest or supplier. PWL’s policy also prohibits retaliation against anyone who has made a harassment complaint.

14) The laws affecting employment practices are complex and constantly evolving. It is critical that each supervisor maintain awareness of current legal developments and PWL’s employment policies by seeking appropriate advice of those within PWL who are responsible.

Suppliers
15) All suppliers are required to comply with this policy as a minimum standard. In addition they must comply with all national and international laws, regulations and standards applicable in their country of business. Suppliers will also ensure that, as far a reasonably practicable, their suppliers will , in turn, comply with this policy. Any supplier whose behaviour is found to be demonstrably at odds with this policy will be de-listed.

 DownloadPrice Western Leather Co. Ltd. has systematically reviewed the context in which we operate and evaluated our actual and potential environmental aspects and impacts which might directly or indirectly result from its use of raw materials, processes, products and wastes. In this evaluation particular note was taken of customer concerns over global warming, ozone depletion, resource utilization, life cycle issues, compliance to legislation and the potential for pollution.

It was found that the activities of Price Western Leather have relatively small environmental impacts but these are addressed by the implementation of our ISO 14001 Environmental Management System and the following Environmental Policy aims.

We shall:

• Meet or, where practical, exceed all legislative, regulatory and other requirements appropriate to our business.
• Regularly review the environmental risks and opportunities identified and use this information to continually improve the Company’s environmental performance by
  setting meaningful objectives and targets.
• Promote optimum and efficient use of raw materials and energy to improve resource utilisation and reduce waste.
• Work towards the prevention, reduction and eventual elimination of any actual or potential pollution arising from our activities with particular focus on Volatile Organic Compounds used in our inks and adhesives.
• Raise the awareness and understanding of all staff about the Company’s Environmental Policy and maintain awareness of environmental issues and related matters.
• Provide the interested parties with relevant and appropriate information and establish open and on-going dialogue with persons having a bona fide interest in the Company’s activities.
• Ensure these aims are achieved by the use of appropriate procedures and management systems that will be systematically monitored, audited, reviewed and improved.
• Reduce Carbon Emissions by 50% by 2030 from Baseline of 2021

Download the Price Western Environmental Policy
Environmental Policy (January 30, 2023)

Contact:  Jonathan Littlewood
Title:  Managing Director
Email:  info@pwluk.com

Contact:  Laura Brendon
Title:  Environmental Management Representative
Email:  sales@pwluk.com

 DownloadThe aim of the Price Western Leather Company Ltd. Hospitality policy is to guard against the risk of allegations of impropriety and potential conflicts of interest between Price Western Leather Company Ltd (PWL) and both its suppliers and customers.

Offering Hospitality

1. PWL insists that staff should never offer any hospitality to representatives of any Public Sector
   organisation. PWL insists that all business contact and related activities be conducted with the utmost
   integrity, openness and professionalism at all times.
2. It may be permissible to provide hospitality in the form of refreshments or working lunches for meetings
   with Private Sector organisations. However it should be noted that alcohol should never be provided as
   part of a working lunch. Permissible hospitality should be:
   • not lavish in nature;
   • not a frequent occurrence; and
   • there is no suspicion of a conflict of interest.

Accepting Hospitality

1. PWL requires staff to ensure that any hospitality offered to them by representatives of a Public Sector
   organisation could not be construed in anyway to be improper or to risk any conflict of interest, either
   at the time of offer or in the future. If there is any doubt about the possible outcomes, the hospitality
   should be refused.
2. Members and staff should not encourage business contacts to provide hospitality to them, or indirectly
   to other colleagues, friends or relatives.
3. Offers of hospitality should be reported to the Managing Director. Some examples of hospitality which
   should be refused are payments for lunch or dinner, and tickets to sporting or leisure events.
4. In the following circumstances, it may be considered appropriate to accept a working lunch, dinner or
   attendance at an annual stakeholder event, where it is:
   • not lavish in nature;
   • not a frequent occurrence; and
   • there is no suspicion of a conflict of interest.
5. Such hospitality must be reported to the Managing Director

 DownloadPrice Western Leather Company Limited (PWL) supplies leather and synthetic uniform accessories to a global market of professional security, medical and military personnel. For over 30 years, the PWL name has been associated with the highest quality goods, excellent value for money and world class customer service.

We intend to continue the growth of our market presence through a combination of customer service,
product effectiveness and innovation of both products and our internal working practices.

In more specific terms, we have set ourselves the following key quality aims:

• Understand the needs of our customers by giving open and friendly interaction with our customer and
  provide fresh ideas to address their problems.
• Commit to continue our work practices under the guidance of the ISO 9001 quality management system.
• Meet the requirements of our customers with pro-active ground breaking design solutions.
• Combine the values of traditional craftsmanship with the efficiencies obtained from Lean Manufacturing
  methods to provide excellence in all we do.
• Encourage each individual in the organisation to meet his or her full potential through a structured training
  programme.
• Work towards continuous improvements by setting ourselves objectives to be met within structured action
  plans.

Monitoring Performance
Our ISO 9001 management system reinforces this so as to ensure that we provide our clients with the
excellences they demand and we aim to achieve. As a responsible member of the community, our ISO
14001 certification and practices help us focus on efficient use of raw materials throughout the production
process as well as responsible waste management programmes in other areas of the business.

You can download a copy of our Quality Policy by clicking here.

Contact:  Gary Parsons
Title:  Quality Management Representative
Email:  sales@pwluk.com

 DownloadWe understand that your privacy and the security of your personal information is extremely important. This notice sets out what we do with your personal information, what we do to keep it secure, from where and how we collect it, as well as your rights in relation to the personal information we hold about you.

This policy applies if you interact with us through our stores, over the phone, online, via email, through our mobile applications or otherwise by using any of our websites or interacting with us on social media.

If you don’t want to read all the detail, here are the things we think you’d really want to know:

• “Price Western” is a trading name of Price Western Leather Company Ltd. registered in England and Wales.
• Your personal information is not shared with any external organisation.
• You have a number of rights over your personal information. How you can exercise these rights is set out in this notice.
• We do not send direct marketing. We only send communication relating to either our business relationship with you, or an enquiry you have made directly either on our website or via post or telephone call.
• While you use our website, we use an anonymised set of behavioural data to identify human behaviour in order to reduce malicious use of our contact form and email communication channels.

Who Are We?
Price Western is a trading name of Price Western Leather Company Ltd. registered in England and Wales, company number 01243441. Our registered office is Ponsford Road Works, Ponsford Road, Minehead, Somerset, TA24 5DX.

What sorts of personal information do we hold?
Information that you provide to us such as your name, address, telephone number, email address, bank account and payment card details and any feedback you give to us, including by phone, email, post, or when you communicate with us via the website and/or social media;

Information about the services that we provide to you (including for example, the things we have provided to you, when and where, what you paid, and so on);

Information about whether or not you want to receive marketing communications from us;

Information from other sources such as specialist companies that provide customer information. For example, credit reference agencies such as Experian, the Royal Mail, fraud prevention agencies, claims databases, marketing and research companies, social media providers, pay TV providers and the DVLA, as well as information that is publicly available; and behavioural biometric information during any visits to our website.

Our Legal basis for collecting information
Whenever we process your personal information, we have to have something called a “legal basis” for what we do. The different legal bases we rely on are:
Consent: You have told us you are happy for us to process your personal information for a specific purpose(s);
Legitimate interests: The processing is necessary for us to conduct our business, but not where our interests are overridden by your interests or rights.
Performance of a contract: We must process your personal information in order to be able to provide you with one of our products or services;
Vital interests: The processing of your personal information is necessary to protect you or someone else’s life;
Legal obligation: We are required to process your personal information by law.

How do we use your personal information?
We may use your information in the following ways:

• To provide our products and services – we need to use your personal information to make our products and services available to you. If you then decide to order any of our products or services, or enter one of our competitions then we’re delighted, thank you. After that, we need to provide them to you and process your payment. We need to use your details to do all this.
• To improve your website experience – we try to understand our customers so we can provide you with a great online experience. Understanding how you use our website, how you interact with the Price Western, the products and services you buy helps us to do this.
• Contacting you – we use your personal information to contact you. This may be in relation to a service update, or an issue you have raised with us.

Cookies and similar technologies
We use cookies to help give you the best experience on our websites and to allow us and third parties to tailor ads you see on ours and other websites. For more information please see our full Cookie Policy.

Who might we share your information with?
Our service providers, which are:

• Scheme providers – such as Visa and MasterCard – if you hold a credit card or travel money card with us, in order to manage your account and for your payments to be processed;
• Our agents, advisers or others involved in running accounts and services for you and your business or collecting what you or your business owe Price Western.
• Credit reference agencies, if you are a new Price Western corporate customer;
• Logistics and delivery providers who enable us to deliver products you order on our websites;
• Where relevant, our professional advisors, such as lawyers and consultants;
• Security and fraud prevention companies to ensure the safety and security of our customers, colleagues and
  business;

Keeping you informed about our products and services
From time to time, we would like to tell you about our new products and services. Where we have consent or it is in our legitimate interests to do so, we may do this through the post or email.

We won’t send you marketing messages if you tell us not to, but if you receive a service from us, we will still need to send you occasional service-related message. If you wish to amend your marketing preferences, you can do so online at: https://pwluk.com/en/contact-price-western/or call us on 01643 705071.

You can download a copy of our Privacy Policy by clicking here.