The standards we apply in our own operations and require of the plant and the subcontractors that manufacture on our behalf. Version 1.0, effective 26 September 2026, signed by our Director.
This Code sets out the standards that Kaway Group Limited applies to its own operations and requires of the production facility and subcontractors that manufacture on its behalf. It applies to every director, employee, agent and supplier of Kaway Group Limited, without exception, in every country where we operate. It is grounded in the core conventions of the International Labour Organization, the Universal Declaration of Human Rights and the Ten Principles of the UN Global Compact.
We comply with the laws of Hong Kong SAR, of the People's Republic of China where our production is located, and of every market into which we sell. Where this Code sets a higher standard than local law, this Code applies. Where local law is stricter, local law applies.
We do not employ anyone under the age of 16, and we do not accept child labour anywhere in our supply chain. Age is verified against official identity documents before any person starts work, and records are retained. Workers under 18 are not assigned night shifts, hazardous tasks or work with dangerous machinery. If a child is ever found working at a facility producing for us, the child's welfare, schooling and family income come before contractual remedies.
All work is voluntary. We do not use forced, bonded, indentured or prison labour. No worker is required to surrender identity documents, pay recruitment fees or lodge a deposit as a condition of employment. Workers are free to leave the workplace at the end of their shift and to end their employment on reasonable notice.
Working hours follow applicable law. Overtime is voluntary and paid at the legal premium rate. Every worker receives at least the legal minimum wage and one day off in seven. Wages are paid in full, on time and directly to the worker, with a clear written statement of pay and deductions. Deductions as a disciplinary measure are not permitted.
We recruit, pay and promote on the basis of ability and performance. We do not discriminate on grounds of race, ethnicity, nationality, religion, sex, pregnancy, marital status, sexual orientation, disability, age, political opinion or union membership. Harassment, bullying, corporal punishment, verbal abuse and threats of any kind are prohibited.
Workers are free to associate, to organise and to bargain collectively in accordance with applicable law, and to raise grievances without fear of retaliation. Where the law restricts these rights, we do not obstruct alternative means of independent worker representation.
We provide a safe workplace: risk assessment of machinery and chemical processes, guarding on cutting, laminating and punching equipment, ventilation and personal protective equipment where printing inks and solvents are used, unobstructed and marked fire exits, extinguishers, first aid provision and periodic evacuation drills. Safety training is given before a worker operates any machine, and accidents are recorded and investigated.
We hold the environmental permits and licences required for our activity and comply with their conditions. We work to reduce waste, offcuts and packaging weight, we segregate and dispose of chemical and material waste through authorised channels, and we do not discharge untreated process effluent. We offer recycled PVC, PETG, FSC certified wood and bamboo as alternatives to virgin plastic, and we will state honestly what each material is rather than overstate its environmental benefit.
Wood used in our wooden cards and accessories is produced at a facility holding FSC chain of custody certificate FSC-C195226. Products are manufactured to ISO/IEC 7810 and ISO/IEC 14443 where those standards apply, and materials comply with RoHS and REACH restrictions. We do not substitute a specified chip, material or finish for a cheaper one without the customer's written agreement.
We do not offer, give, request or accept bribes, kickbacks or improper payments, whether directly or through an intermediary, and whether to a public official or a private counterparty. Facilitation payments are prohibited. Modest business hospitality is acceptable only where it is transparent, proportionate, lawful in both countries, not intended to influence a decision, and permitted by the recipient's own rules. Anything that could not be disclosed openly to the recipient's employer must not be offered.
We compete on product, price and service. We do not fix prices, allocate markets or rig bids, and we do not seek a competitor's confidential information by improper means. Employees disclose any personal, family or financial interest that could conflict with their duties to the company, and take no part in decisions affected by it.
Customer artwork, designs, key files, encoding data, specifications and commercial terms are confidential and are used only to fulfil that customer's order. We do not reproduce, resell or display a customer's branded product as our own sample without written permission, and we do not manufacture a customer's design for a third party. We do not infringe the trademarks, copyright or designs of others, and we will refuse an order that asks us to. Personal data is processed lawfully, kept secure and retained no longer than necessary.
We do not subcontract production to an undisclosed facility. Where part of an order is subcontracted, the subcontractor is made aware of this Code and is expected to meet it. We reserve the right to visit, and to allow our customers or their appointed auditors to visit, facilities producing on our behalf, subject to reasonable notice and confidentiality.
Anyone, inside or outside the company, may report a suspected breach of this Code in confidence to conduct@kawaygroup.com, or directly to the Director. Reports may be made anonymously. We do not tolerate retaliation of any kind against a person who raises a concern in good faith, and a report made in good faith that turns out to be mistaken will never be held against the person who made it. Every report is reviewed and the person who raised it is told the outcome where that is possible.
Breach of this Code by an employee is a disciplinary matter. Breach by a supplier or subcontractor is grounds for corrective action and, where the breach is serious or repeated, for ending the relationship. This Code is reviewed at least every two years and whenever our operations or applicable law change materially.
Signed for and on behalf of Kaway Group Limited
Marco Palau, Director
Hong Kong, 26 September 2026
Version 1.0
Kaway Group Limited, Room 2105, SH2822, Trend Centre, 29-31 Cheung Lee Street, Chai Wan, Hong Kong. Business Registration 65561489. A signed and sealed copy of this Code is available on request from hello@kawaygroup.com.