ETI Base Code
ETI Base Code
The Ethical Trading Initiative's labour-rights framework and its role in responsible jewellery sourcing
The ETI Base Code is a internationally recognised labour-rights standard developed by the Ethical Trading Initiative (ETI), a UK-based multi-stakeholder alliance comprising companies, trade unions, and non-governmental organisations. First published in 1998 and grounded in the conventions of the International Labour Organization (ILO), the Base Code establishes minimum requirements for working conditions across global supply chains. Within the jewellery and gemstone industry, it functions as a foundational reference document: the Responsible Jewellery Council (RJC) incorporates its principles directly into the RJC Code of Practices, meaning that any business seeking RJC certification must demonstrate alignment with ETI Base Code provisions.
Origins and Governance
The Ethical Trading Initiative was established in the United Kingdom in 1998 as a response to growing public and governmental concern about labour exploitation in global supply chains, particularly in garment manufacturing and agriculture. Its founding model — bringing together commercial businesses, independent trade unions, and civil-society organisations as equal stakeholders — was deliberately designed to avoid the conflicts of interest that arise when industry bodies self-regulate without external accountability.
The Base Code itself was drafted with direct reference to ILO Conventions, which are the internationally agreed benchmarks for workers' rights negotiated between governments, employers, and workers' representatives under the auspices of the United Nations. This grounding in ILO instruments gives the ETI Base Code a degree of legal and normative authority that purely industry-generated standards do not possess.
The Nine Provisions
The ETI Base Code comprises nine clauses, each addressing a distinct dimension of working conditions. Together they define the minimum threshold of acceptable practice for any supplier operating within an ETI member's supply chain:
- Employment is freely chosen. Forced, bonded, or involuntary prison labour is prohibited. Workers must be free to leave employment after reasonable notice.
- Freedom of association and the right to collective bargaining are respected. Workers have the right to join or form trade unions and to bargain collectively. Where such rights are restricted by law, employers must facilitate parallel means of independent worker representation.
- Working conditions are safe and hygienic. A safe working environment must be provided, with access to clean facilities, adequate lighting, and appropriate protective equipment. This clause is particularly relevant to mining and lapidary operations, where occupational hazards are significant.
- Child labour shall not be used. The minimum age for employment follows the ILO definition — generally 15 years, or 14 in certain developing economies under ILO Convention 138. Hazardous work is prohibited for anyone under 18.
- Living wages are paid. Wages must meet national legal minimums or industry benchmark standards, whichever is higher, and must always be sufficient to meet basic needs. Deductions as a disciplinary measure are prohibited.
- Working hours are not excessive. Workers shall not routinely work more than 48 hours per week, with a maximum of 12 hours overtime, and must receive at least one day off in every seven.
- No discrimination is practised. Hiring, compensation, training, promotion, and termination must be free from discrimination based on race, caste, national origin, religion, age, disability, gender, marital status, sexual orientation, or political affiliation.
- Regular employment is provided. Obligations to employees must not be avoided through the use of labour-only contracting, sub-contracting, or home-working arrangements designed to circumvent legal protections.
- No harsh or inhumane treatment is allowed. Physical abuse, the threat of physical abuse, sexual or other harassment, and verbal abuse are prohibited.
Relevance to the Jewellery and Gemstone Industry
The jewellery supply chain is unusually long and fragmented, spanning artisanal and small-scale mining (ASM) operations in remote localities, cutting and polishing centres in India, Thailand, and elsewhere, component manufacturing, and retail. At each stage, the conditions described in the ETI Base Code have documented relevance. Artisanal gemstone mining in particular has been associated with child labour, unsafe working environments, and debt bondage — conditions that the Base Code's provisions directly address.
The Responsible Jewellery Council, which is the principal third-party certification body for the jewellery sector, formally references the ETI Base Code within its Code of Practices. RJC-certified members — including miners, dealers, manufacturers, and retailers — are audited against requirements that map onto ETI Base Code provisions. This integration means that ETI compliance is not merely aspirational within the sector but is embedded in a structured, auditable certification framework with defined consequences for non-conformance.
Beyond RJC certification, many large jewellery retailers and luxury groups that are direct ETI members require their gemstone and precious-metal suppliers to demonstrate ETI Base Code alignment as a contractual condition of supply. This creates a cascading effect through the supply chain, extending the Code's reach beyond the immediate membership of the ETI itself.
Limitations and Criticisms
The ETI Base Code is widely respected, but it is not without criticism. Auditing supply chains that extend to artisanal mining communities in jurisdictions with weak regulatory infrastructure is methodologically challenging. Social audits — the primary verification mechanism — have been criticised by labour-rights scholars and NGOs for their susceptibility to coaching of workers, short audit windows, and the difficulty of detecting informal or home-based labour. The ETI itself has acknowledged these limitations and has invested in developing more participatory audit methodologies and worker-voice mechanisms.
A further limitation is that the Base Code establishes minimum standards rather than aspirational targets. Meeting the Code's provisions does not, by itself, guarantee that workers receive a genuinely living wage in the economic sense, or that supply-chain relationships are equitable in terms of value distribution. Complementary frameworks — such as the Fairtrade and Fairmined standards for gold, or the Alliance for Responsible Mining's ARM standard — address some of these dimensions more directly.
In the Trade
For gemmologists, buyers, and jewellery professionals, awareness of the ETI Base Code is increasingly relevant as due-diligence expectations rise. The EU's Corporate Sustainability Due Diligence Directive (CS3D) and equivalent legislation in the United Kingdom are creating statutory obligations for larger companies to identify and address labour-rights risks in their supply chains — obligations that align closely with ETI Base Code provisions. Familiarity with the Code's nine clauses therefore provides a practical reference point for understanding what responsible sourcing commitments entail in concrete, auditable terms.